Thar Coalfield Block VI 2x330MW Coal-fired Power Plant Volume II: Environmental and Social Impact Assessment (ESIA)
March 2017
Oracle Coalfields PLC
Mott MacDonald Victory House Trafalgar Place Brighton BN1 4FY United Kingdom
T +44 (0)1273 365000 F +44 (0)1273 365100 mottmac.com
Oracle Coalfields PLC 6th Floor Two Kingdom Street Thar Coalfield Block VI London 366982 02 B W2 6BD 2x330MW Coal-fired Power Mott MacDonald Plant Volume II: Environmental and Social Impact Assessment (ESIA)
March 2017
Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Roa d, Croydon CR0 2EE, Oracle Coalfields PLC United Kingdom
Mott MacDonald | Thar Coalfield Block VI 2x330MW Coal-fired Power Plant Volume II: Environmental and Social Impact Assessment (ESIA)
Issue and Revision Record
Revision Date Originator Checker Approver Description A Februar Various Various G. Clamp Draft for client comments y 2017 L. Stone I Scott B March Various Various G. Clamp Final 2017 L. Stone I Scott
Document reference: 366982 | 02 | B
Information class: Standard
This document is issued for the party which commissioned it and for specific purposes connected with the above- captioned project only. It should not be relied upon by any other party or used for any other purpose.
We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties.
This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.
This report has been pr epared sol el y for use by the party which commissi oned it (the ‘Client’) i n connecti on with the capti on ed proj ect. It should not be used for any other purpose. N o person other than the Client or any party who has expressl y agreed ter ms of r eliance with us (the ‘Reci pien t(s)’) may rel y on the content, i nformati on or any views expressed i n the repor t. We accept no duty of care, responsi bility o r liab ility to any other r eci pient of thi s document. T his r eport is confi denti al and contains pr opri etar y intell ectual property.
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Contents
Glossary 1
1 Introduction 4 1.1 Overview 4 1.2 Project summary 4 1.3 Financing of the Project 6 1.4 Purpose of the ESIA report 6 1.5 Structure of the ESIA report 6
2 Project description 8 2.1 Overview 8 2.2 Site location 8 2.3 Power plant components 11 2.4 Construction phase 6 2.5 Operation phase 6 2.6 Decommissioning 7 2.7 Associated facilities 7
3 Project need and alternatives 9 3.1 Introduction 9 3.2 Project need 9 3.3 Analysis of alternatives 13 3.4 Summary 16
4 Policy, legal and institutional framework 17 4.1 Introduction 17 4.2 National institutional and legal framework 17 4.3 Sindh Environmental Protection Act 2014 17 4.4 Sindh Environmental Quality Standards 18 4.5 Requirements for environmental impact assessment in Sindh Province 18 4.6 International treaties and conventions 20 4.7 National and international non-governmental organisations 21 4.8 International standards and guidelines 21
5 ESIA process and methodology 22 5.1 Introduction 22 5.2 Impact assessment methodology 22 5.3 Cumulative impacts and transboundary impacts 25
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6 Information disclosure, consultation and participation 26 6.1 Overview 26 6.2 Consultation requirements 26 6.3 Stakeholder identification and analysis 27 6.4 Introducing stakeholders to the Project and the developments in Block VI 31 6.5 Disclosure and consultation on the draft ESIA 33 6.6 Stakeholder engagement planned throughout the lifetime of the Project 33 6.7 Project grievance redress mechanism 34 6.8 CLO contact details 37
7 Air quality 38 7.1 Introduction 38 7.2 Applicable legislation 39 7.3 Methodology and assessment criteria 42 7.4 Baseline description 55 7.5 Impact identification and assessment 56 7.6 Mitigation and enhancement measures 72 7.7 Residual impacts 73
8 Greenhouse gas 74 8.1 Introduction 74 8.2 Applicable legislation 74 8.3 Guidelines and policies 74 8.4 Methodology and assessment criteria 75 8.5 Baseline description 78 8.6 Impact identification and assessment 79 8.7 Mitigation and enhancement measures 80 8.8 Summary 80
9 Noise and vibration 82 9.1 Introduction 82 9.2 Applicable legislation 83 9.3 Methodology and assessment criteria 85 9.4 Baseline description 86 9.5 Impact identification and assessment 87 9.6 Mitigation and enhancement measures 92 9.7 Residual impacts 92
10 Waste and materials 93 10.1 Introduction 93 10.2 Applicable legislation 93 10.3 Methodology and assessment criteria 95
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10.4 Baseline description 96 10.5 Impact identification and assessment 102 10.6 Mitigation and enhancement measures 110 10.7 Residual impacts 115
11 Hydrology, hydrogeology and flood risk 117 11.1 Introduction 117 11.2 Applicable legislation 117 11.3 Methodology and assessment criteria 121 11.4 Baseline description 123 11.5 Impact identification and assessment 131 11.6 Mitigation and enhancement measures 136 11.7 Residual impacts 137
12 Landscape and visual 141 12.1 Overview 141 12.2 Assessment methodology 141 12.3 Baseline description 144 12.4 Likely impacts and assessment of significance 155 12.5 Mitigation and enhancement measures 162 12.6 Residual impacts 162
13 Ground conditions 165 13.1 Introduction 165 13.2 Methodology criteria 165 13.3 Baseline description 167 13.4 Impact identification and assessment 171 13.5 Mitigation and enhancement measures 175 13.6 Residual impacts 178
14 Ecology & biodiversity 181 14.1 Introduction 181 14.2 Applicable legislation 181 14.3 Methodology and assessment criteria 183 14.4 Baseline context 188 14.5 Impact identification and assessment 195 14.6 Mitigation and enhancement measures 198 14.7 Residual impacts 202
15 Social impact assessment 206 15.1 Introduction 206 15.2 Applicable legislation and standards 207 15.3 Methodology and assessment criteria 208
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15.4 Baseline description 211 15.5 Likely impacts and assessment of significance 226 15.6 Potential risks 228 15.7 Mitigation and enhancement measures 229 15.8 Residual impacts 234
16 Cumulative impact assessment 236 16.1 Introduction 236 16.2 Employment generation cumulative impacts 236 16.3 Influx of workers’ cumulative impacts 237 16.4 Landscape and visual amenity cumulative impacts 237 16.5 Noise cumulative impacts 238 16.6 Air quality cumulative impacts 238 16.7 Dust cumulative impacts 239 16.8 Hydrology and hydrogeology cumulative impacts 239 16.9 Summary 239
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Glossary
Acronym Definition AEWA African-Eurasian Waterbird Agreement AIS Alien invasive species AoI Area of influence BAP Biodiversity action plan BAT Best available techniques BOD Biological oxygen demand CBD Convention on Biological Diversity CDDIT Community Development Department of Information Technology CEDD Coal and Energy Development Department CFB Circulating Fluidised Bed CIP Community investment plan CITES Convention on International Trade of Endangered Species of Wild Fauna and Flora CLO Community liaison officer CMS Conservation of Migratory Species COD Chemical oxygen demand CPEC China-Pakistan Economic Corridor CPPA Central Power Purchasing Authority DEMP Decommissioning environmental management plan ECA Employment of Children Act EHS Environment health and safety EIA Environmental impact assessment EMF Electro-magnetic fields EPC Engineering procurement and construction EPRP Emergency preparedness and response plan ESIA Environmental and social impact assessment ESMP Environmental and social management plan ESMS Environmental and social management system ESP Electrostatic precipitator EWC European waste catalogue FGD Flue-gas desulphurisation GDP Gross domestic product GHG Greenhouse gas GIIP Good international industry practice GLVIA Guidelines for Landscape and Visual Assessment GPS Global positioning system HFO Heavy fuel oil HSE Health safety and environment IAI Immediate area of influence IAIA International Association of Impact Assessment IBA Important biodiversity area
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Acronym Definition IECC Information and Education Communication Centre
IEE Initial environmental examination IEMA Institute of Environmental Management and Assessment
IFC International Finance Corporation ILO International Labour Organisation
IUCN International Union for Conservation of Nature KBA Key biodiversity area
LAA Land Acquisition Act LCA Landscape character area
LAI Local area of influence LBOD Left bank outfall drain
LFO Light fuel oil LI Landscape Institute
LOR Limit of reporting LNG Liquified natural gas
LVIA Landscape and visual impact assessment MIGA Multilateral Investment Guarantee Agency
MSDS Material safety data sheet NEPRA National Electricity Pricing and Regulatory Authority
NEQS National Environmental Quality Standards NGO Non-governmental organisation
NIAP National Impact Assessment Programme NOC No objection certificate
NTDC National Transmission and Dispatch Company OHS Occupational health and safety
O&M Operations and maintenance Pak-EPA Pakistan Environmental Protection Agency
PAP Project affected people PEC Process environmental concentration
PEPA Pakistan Environmental Protection Act PC Pulverised coal
PMCCC Prime Minister’s Committee on Climate Change PPE Personal protective equipment
PPIB Private Power Infrastructure Board RO Reverse osmosis
SCA Sindh Coal Authority SEP Stakeholder engagement plan
SEPA Sindh Environmental Protection Agency SEPCO Shandong Electric Power Construction Company
SEQS Sindh Environmental Quality Standards SMEDA Small and Medium Enterprises Development Authority
SPDC Social Policy Development Center SWMP site waste management plan
TDS Total dissolved solids PAA Project affected area
UNFCCC United Nations Framework Convention on Climate Change WAI Wider area of influence
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Acronym Definition WAPDA Water and Power Development Authority WHO World Health Organization WHS World heritage site WRB World Reference Base ZTV Zone of theoretical visibility
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1 Introduction
1.1 Overview Pakistan currently imports much of its fuel for the production of electricity to power homes and businesses. Electricity demand outweighs supply within the country; as such the Government of Sindh is considering options for power generation. The Government of Sindh is pursuing coal to power generation since the identification of the Thar Coalfield and as it is believed to be one of the least costly energy generation options for Pakistan.
The Thar Coalfield which is located in the southeast of Sindh Province was discovered in 1980 and cover an area of 9,100km 2 with total lignite coal resources estimated to be in excess of 175 billion tonnes. The development of the Thar Coalfield and the associated establishment of coal to power projects are major objectives of the Government of Sindh, to achieve increased power production, with associated economic growth to ultimately reduce poverty in the country. The Thar Desert has one of the largest coal reserves in the world.
A mining lease was granted by the Directorate of Coal Mines Development, Government of Sindh, in April 2012 for the Block VI area for a 30 year period, extendable for a further 30 years. A major drilling programme was carried out as part of a technical feasibility study, undertaken by SRK Consulting on behalf of Oracle Coalfields PLC (“the Developer), which confirmed the in- situ coal deposit of 1.4bn tonnes within the Block VI area of the Thar Coalfield. The study confirmed that an open-pit mine could be developed with a production capacity of 5 million tonnes per annum (Mtpa) to support the first phase 660MW mine-mouth power plant (‘the plant’). A second phase is to increase the capacity of the power plant to 1,320MW is expected at a later date.
The Developer has commissioned Mott MacDonald Limited to undertake an environmental and social impact assessment (ESIA) for the proposed 2 x 330 megawatt (MW) coal-fired power plant (“the Project”) to be located in Block VI of the Thar Coalfield. The Project will be will be constructed adjacent to the open-cut lignite coal mine that will be developed in Block VI.
1.2 Project summary The Project will consist of a lignite fired power plant capable of generating 660MW gross of electricity through 2 x 330MW generation units. Two circulating fluidised bed (CFB) boiler units will be installed at the plant. Each boiler will provide steam for a steam turbine/generator unit 1 with a minimum electrical (gross) rating of 330MW e . The Project will be connected to the local grid through a 500kV substation which will be located at the boundary of Block VI. A project description providing further detail is given in chapter 2.
Coal will be supplied to the Project from the Block VI open pit coal mine, which will also be the responsibility of the Developer. Lignite coal will be transported from the mine stockpile to the power plant by a covered belt conveyor, which will be owned and operated by the Developer.
In September 2014, the Developer signed an engineering, procurement and construction (EPC) contract framework agreement with the Shandong Electric Power Construction Company (SEPCO) for the construction of the Project. The Developer has registered the project with the
1 Two steam turbines will be provided for the project
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Private Power Infrastructure Board (PPIB).
Figure 1 below details the development process for the Block VI mining project and the Project.
Figure 1: Block VI project development process
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1.3 Financing of the Project It is understood that China Exim Bank (and a number of other Chinese banks yet to be determined at this stage) will provide finance for the Project. China Exim Bank expects that a project’s host country EIA laws and regulations will be met in order for them to provide finance.
1.4 Purpose of the ESIA report The Developer is required to complete an ESIA which will comply with the requirements of the Pakistan Environmental Protection Act (1997) (PEPA) and the Pakistan Review of Initial Environmental Examination (IEE) and the Environmental Impact Assessment (EIA) Regulations (2000) to obtain the national approvals from the Sindh Environmental Protection Agency (SEPA) and to seek finance for the Project.
Where appropriate, reference to international standards including the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability 2012 (IFC PS) and good international industry practice (GIIP) has been made.
Further detail on the regulations and international standards and guidelines applicable to this ESIA are provided in chapter 4.
The objectives of this ESIA are to:
1. Comply with Pakistan’s legal and institutional framework for undertaking an ESIA 2. Comply with China Exim Bank environmental standards 3. Identify and assess social and environmental impacts caused by the project, both adverse and beneficial, in the Project’s area of influence (AoI) 4. Avoid, or where avoidance is not possible, minimise, mitigate or compensate for adverse impacts on workers, affected communities and the environment 5. Promote social and environmental performance through the use of management systems A gap analysis of previous assessments undertaken for the Project was completed to define the terms of reference for this assessment and to identify the key environmental and social aspects and potential impacts relevant to the Project. The degree of appraisal required for each aspect will differ in accordance with potential significance of impact. While this ESIA aims to identify both positive and negative impacts associated with the development of the project, it is inherently more focused on describing and mitigating potential negative impacts. Where possible, opportunities to enhance positive impacts have been identified. Further discussion relating to the ESIA methodology is addressed in chapter 5.
A separate EIA for the lignite mining activities at Block VI has been completed by Hagler Bailly and later updated by Wardell Armstrong and necessary permits have been obtained.
1.5 Structure of the ESIA report This ESIA comprises of four volumes organised as presented in Table 1. This document forms Volume II of the overall ESIA documentation.
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Table 1: Structure of this ESIA Volume No. (and contents) Title Volume I Non-technical summary Volume II Environmental and social impact assessment Chapter 1 Introduction Chapter 2 Project description Chapter 3 Project need and analysis of alternatives Chapter 4 Policy, legislative and institutional framework Chapter 5 ESIA process and methodology Chapter 6 Information disclosure, consultation and participation Chapter 7 Air quality Chapter 8 Greenhouse gas Chapter 9 Noise and vibration Chapter 10 Waste and materials management Chapter 11 Hydrology, hydrogeology and flood risk Chapter 12 Landscape and visual Chapter 13 Ground conditions Chapter 14 Biodiversity and ecology Chapter 15 Social impact assessment Chapter 16 Cumulative impact assessment Volume III Technical appendices Volume IV Environmental & social management (and monitoring) plan (ESMP)
Contact details for enquiries on this ESIA are given in Table 2 below:
Table 2: Contact details Project proponent Information Name of Company Oracle Coalfields PLC Address 6th Floor 2 Kingdom Street London W2 2PY Telephone 02035804314 E-mail [email protected] Website www.sindhcarbonenergy.com
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2 Project description
2.1 Overview This chapter provides a description of the project location, proposed Project and its associated facilities.
2.2 Site location The Project site is located in the southeast corner of the Sindh Province of Pakistan in the Thar Desert. Block VI occupies the southern part of the Thar Coalfield and covers an area of approximately 66km 2. The Project site within Block VI is located approximately 380km northeast of Karachi and 20km northeast of Islamkot and 77km east of Mithi. Figure 2 presents the regional location of Block VI and Figure 3 shows the location of Block VI within the Thar Coalfield.
Two main villages Ranjho Nun and Kharo Jani are located within Block VI, with other small villages located in and around Block VI. Figure 4 shows the Project in the setting of Block VI.
Figure 2: Regional location of Block VI
Source: ESIA for Block VI Lignite Mining Project, Hagler Bailly Pakistan, 2013
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Figure 3: Location of Block VI within Thar Coalfield
Source: The Developer
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Figure 4: Project setting
Source: Mott MacDonald
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2.3 Power plant components Thermal power plants generate electricity by burning fuel (in this instance lignite), which heats water to generate high temperature, high-pressure steam, which drives a steam turbine. At one end of the steam turbine is a condenser. As steam passes from the boiler to the condenser, it passes through the steam turbine thereby rotating the turbine blades and generating electricity.
The key components of the Project to be located within Block VI include:
● Coal yard ● 2 x 330MWe generation units ● A substation that will connect to an existing 500kV transmission line ● One 210m exhaust stack ● Cooling water system ● Ash yard (providing temporary storage) ● Ash disposal area ● Access roads ● On-site accommodation, office facilities, fire station, workshop and open materials storage area. Figure 5 illustrates the plant layout.
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Figure 5: General plant layout
Source: SEPCO (2016)
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Figure 6 provides a conceptual visualisation of the Project. The coal stockyard is in the foreground with a conveyor delivering coal to the boiler in the centre and the two generating units. The two cooling towers towards the rear of the plant.
Figure 6: Power plant conceptual view
Source: SEPCO (artist’s impression)
2.3.1 Fuel The Developer will operate the Block VI open pit lignite mine will supply coal to the plant from the Block VI coal deposits. Covered belt conveyors owned and operated by the Developer will transport coal from the mine to the plant.
The Plant will be designed to meet performance objectives (ie output) and all emissions limits applicable with the fuel specification design range.
2.3.2 Additional key operating materials An injection of limestone directly in to boiler is required to reduce sulphur emissions to appropriate levels. The limestone powder is transported to the project by truck. It is combusted in the boiler for desulphurisation of the flue gas at an estimated rate of 600 tonnes/day over 24 hours.
Light diesel oil will be used for boiler start-up and flame stabilisation during low-load operation. The fuel oil system stores fuel oil in tanks and supplies it with transfer pumps to the boilers during start-up or shut-down activities.
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2.3.3 Coal handling and storage A three-part conveyor system will be utilised for unloading the delivered coal, transferring crushed or pulverised coal from a stockpile to the storage bunkers and delivery of the pulverised coal to the boiler. Two coal storage yards will be utilised for the project. Dust from the coal storage yards will be controlled by a permanently mounted water sprinkler system using recycled process water.
The estimated storage capacity of the coal storage yards is a combined 65,000 tonnes, which is equivalent to five days’ consumption while operating two boilers at full capacity. The coal stocking area is concreted and will be uncovered. Water drainage, collection and subsequent treatment will be provided. Temperature monitoring equipment will be used to reduce spontaneous combustion fire risk from the coal stockpiles (lignite is prone to spontaneous combustion during transport and storage).
The boiler fuel system will comprise four coal storage bunkers (per boiler) with an estimated total capacity of 625m 3 and eight coal feeders per boiler.
2.3.4 Generation units Two circulating fluidized bed (CFB) boiler units will be installed at the Plant. The fluidized bed material will be made from sand sourced from the desert. Each boiler will provide steam for a 2 steam turbine/generator unit with a minimum electrical (gross) rating of 330MW e . CFB technology allows for relatively high combustion efficiency of the fuel. It separates solid particles from the hot flue gases. The larger solid particles that have not been fully combusted in the furnace will be returned to the furnace to undergo the combustion process again.
The benefits of using CFB boiler technology are as follows:
● Reduction in levels of nitrogen oxides (NO x) as a result of the low combustion temperatures ● Reduction of sulphur dioxide (SO 2) emissions – through the use of limestone and low combustion temperatures. ● Fuel flexibility – a wide range of fuel characteristics can be used in a single boiler. It is estimated that approximately each boiler will consume 718,896 tonnes coal per year.
2.3.5 Boiler air and gas system Flue gas will be transported through the boiler by the boiler air and gas system, which also supplies combustion air to the boiler. The flue gas leaving the furnace passes through large cyclones which recirculate larger particles transported with the flue gases back to the fluidized bed. Lighter fly ash and the remaining flue gas pass through the convective elements of the boiler i.e. the superheater, reheater and economiser, which transfer heat from the flue gases to the water and steam of the steam cycle. The feed water is heated in the economiser, while the superheater and reheater heat the steam supplied to the turbine.
To remove the entrained fly ash and un-reacted limestone from the desulphurisation process, cooled flue gas is passed through an electrostatic precipitator (ESP) flue gas cleaning system. An ESP is a filtration device that removes fine particles from flue gas using the force of an induced electrostatic charge. Fans will then discharge the cleaned flue gas into the atmosphere via the stack. The project will also allow for the future installation of fabric filters.
2 Two steam turbines will be provided for the project
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2.3.6 Steam turbines The boiler steam system transfers superheated and reheated steam between the boiler and the turbine. The main steam system delivers superheated steam to the high-pressure turbine, while the reheat steam system returns exhaust steam from the high-pressure turbine to the boiler, where it is again heated before being supplied to the intermediate pressure turbine. Steam from the boilers feed to the condensing and reheat turbine generators.
2.3.7 Cooling towers A closed-cycle circulating water system with natural draft cooling towers will be adopted by this project. In closed systems the warm process water is cooled down by recirculating it through cooling towers. Although there are some evaporative losses of water in closed systems, the majority of the water is conserved. Evaporation losses are estimated to be 1,160m 3/h and drift losses are expected to be approximately 38m 3/h. Each cooling tower will be 125m in height with a diameter of 98.8m at the base of the structure.
2.3.8 Flue stack and emissions abatement technology A single cylinder stack is proposed for the project which will be 210m in height.
Table 3 provides a summary of the abatement technologies that will be used to control emissions from the plant and the emissions levels that the project will achieve.
Table 3: Emissions abatement technology implemented on the Project Guaranteed plant Emissions Emissions abatement emissions
3 Sulphur oxides (SO x) Direct injection of limestone powder ≤650mg/Nm into the CFB boilers 3 Oxides of nitrogen (NO x) Relatively low combustion ≤350 mg/Nm temperatures and staged air injection in the CFB boilers generally result in less generation of thermal NOx compared to other boiler technologies. Particulates ESP’s will be installed to remove ≤50 mg/Nm³ particulate matter from the flue gas prior to exiting the stack.
The provision for retrofitting for further emissions abatement (i.e. fabric filters) and carbon capture and storage has been incorporated in the project design.
2.3.9 Ash handling, storage and disposal Through the coal combustion process both bottom ash and fly ash will be generated as residuals and will be disposed of through the ash handling system. Bottom ash will be collected with slag-coolers, conveyed to a bucket and the bucket will be lifted to a slag storage silo. There will be one bottom slag storage silo with the capacity for holding the production for 24 hours. The dry fly ash system will consist of the conveying system, fly ash storage, unloading system and fluidising air system. Fly ash in the electrostatic precipitators will be discharged into the fly ash silo through a conveyor system and pipeline. Currently, three concrete fly ash silos are planned to be installed with the capacity to store 30 hours of production at the site.
The ash removal volume for the project is detailed in Table 4.
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Table 4: Ash removal volumes Item Design coal Ash volume t/h 48.5 t/d 1,067. 4 t/a 343,600 Slag volume t/h 48.6 t/d 1,070. 3 t/a 344,700 Total volume of ash and slag t/h 97. 2 t/d 2,137.6 Source: EPC contactor – technical description
Note ：
1. Utilisation hours in a day is counted as 22h; Utilisation hours in a year is counted as 7000h.
2. The ratio of fly ash shall be 0.5; dust collection efficiency is 99.7%
The Developer will be responsible for transportation and disposal of ash, which is expected to be at the Block VI mine site. The ash disposal facility will be located in the worked out mine. Ash will be transported form the project site to the mine via trucks with a capacity of approximately 50 tonnes. Although conceptual designs of the facility are not available at this stage in the project development, the following features and components are recommended:
● 25 years of capacity for ash storage ● A geomembrane and geosynthetic lining designed to international requirements ● Cellular design ● Appropriately designed slope gradient and height to facilitate water run-off ● Storm-water drainage system that separates clean and dirty water. In addition, discussions between the Developer and relevant stakeholders will be consulted to ascertain whether there is a potential for commercial use for the fly ash (eg blocks or cement manufacturing) and bottom ash (eg road construction) within Pakistan.
2.3.10 Water supply and demand There are no rivers within Block VI; however, three primary aquifers have been identified in the mine EIA report, comprising the Deep, Middle and Top aquifers. Three options have initially been proposed for water supply for the Project:
● The Deep aquifer ● Top and Middle aquifers which will be dewatered during the mining process and sent to a mining dewatering facility located outside of the project area. ● Pipeline / reservoir from a Government source. Based on information available it is expected that large volumes of water will be required to be extracted from this aquifer for the lifetime of the Project, which could supply the Project.
Water in the Project area is considered saline/brackish, with high levels of chloride, and will therefore require demineralisation prior to use as process water. A reverse osmosis (RO) treatment facility is proposed and will be located within the Project site.
In addition, the Government of Sindh is constructing an alternative water supply from the Left Bank Outfall Drain (LBOD) at Nabissar, along with a large RO plant and lined reservoir, and is
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linking this with the Thar Coalfield via a pipeline to Vejihar where a further large lined reservoir has been constructed. The total supply capacity of this scheme is approximately 3,100L/s (269,000m 3/d) and individual block holders can apply for a water supply agreement to allow them to access the reservoir at Vejihar and pipe water to their block. It is understood that the Government of Sindh has approved the provision of approximately 1,080L/s (93,000m 3/d or 38 Cusec) for Block VI from the LBOD phase II water source or Makhi Faresh link canal, subject to the execution of a water use agreement between the relevant parties.
These combined water resources should safeguard water supply throughout the duration of the Project. A summary of the water demands for the Project is presented in Table 5.
Table 5: Projected water demand Power Plant Use Water demand (m 3/day) Fresh water Potable water 240 Brackish / fresh water Cooling / wash down / dust suppression 44,400 Source: RPS Aquaterra Thar Block VI Water Supply & Disposal (February 2017)
The plant will have a potable water pond, with a capacity of approximately 100m 3, and a potable water system with a treatment capacity of approximately 10m3/h.
2.3.11 Wastewater treatment
2.3.11.1 Sewage treatment Domestic wastewater will be treated biochemically. The design capacity of this system is 240t/d domestic wastewater. The treated wastewater will then be discharged into an adjustment pool before being discharged to two buried treatment facilities, where the wastewater will be biochemically treated.
2.3.11.2 Oily waste water treatment The oil waste water from the fuel oil storage and unloading area, boiler room and transformer yard area will be collected in a sump before being treated by an oil separator, in which the treatment capacity is 10m 3/h. The treated oily wastewater will then flow to a central monitoring basin. Grey water will be recycled and reused for coal dust suppressing and by the ash wetting system. Opportunities for the reuse of waste oils will be investigated by the EPC contractor. Final disposal will be included in the site waste management plan (SWMP).
2.3.11.3 Coal yard storm water treatment
Storm water from the coal yard will be collected by a drainage system and discharged to a coal particle settling basin. The coal particle settling basin will have two chambers, one operating and one standby. When one chamber will be full, the second chamber will utilised. A coagulant aid/polymer dosing facility will be provided at the inlet to the settling basin. Wastewater will be discharged via a pipeline to a final settling lagoon and will then be discharged into the mine stormwater drainage system.
2.3.11.4 Storm water drainage system
An open ditch drainage system shall be adopted for the storm drainage system for the rest of the project. The design and drainage ditch size/capacity is yet to be finalised. The storm water
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from the Power Plant complex will either flow by gravity or will be pumped into the mine storm water drainage system prior to discharge from Block VI.
2.3.12 Emergency power supply Two 630 kilowatt (kW) diesel generating sets will supply power to the essential loads in the whole plant in the event of complete loss of normal supply. The diesel generators will provide power for the safe shut down of the boilers and turbines and for the essential operation of the critical loads and facilities such as the plant control system, communication system, emergency lighting and small power outlets.
2.3.13 Site access Site access will be from Karachi by a road that runs through the towns of Thatta, Badin, Mithi and Islamkot. An access road of approximately 6km in length will be constructed as part of the EPC contracts for the mine and power plant to facilitate access to Block VI. There will be two entrances and exits at the site and will include 20m wide extending gates.
2.4 Construction phase The construction area will consist of a boiler assembly yard, turbine maintenance and assembly yard, concrete batching plant and sand/stone yard, concrete reinforcement processing yard, equipment yard and temporary spoil dump which is expected to occupy an area of approximately 157,500m2.
Approximately 1,000 workers are expected to be employed during peak construction, 60% of which will be Pakistani nationals. The accommodation camp area is separated from the construction area, adjacent to the project site, and will occupy an area of approximately 22,500m2. In total the land area for construction is about 180,000m2.
The construction phase is expected to start in 2018, last for 40 months and will involve key activities including:
● Site clearance ● Vegetation removal ● Earthworks ● Water supply, waste disposal and wastewater treatment ● Site access, traffic and transport. Temporary facilities, including temporary offices and accommodation blocks will be provided for both the mine and the power plant whilst the permanent site facilities are constructed.
A landfill will be constructed in the worked out mine and will be designed to international standards. Further details are provided in Table 6.
2.5 Operation phase Commissioning of the Project is planned to commence in 2020 and operational by 2021. The operation phase is estimated to be for a minimum of 30 years. The plant is expected to operate at 100% capacity for 7,400 hours per annum. Local labour will be used as much as possible during the operation phase through upskilling or capacity building in the area.
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2.6 Decommissioning Upon end of life of the Project all hazardous wastes will be removed and sent for safe disposal, either within the industrial areas solid waste disposal area or under license by a third party contractor. A full ground investigation, including soil and groundwater monitoring, will be undertaken in and around all project areas to identify any contamination. If contamination is identified, a remedial programme should be elaborated as part of decommissioning.
Remaining plant will be considered for re-use and recycling following dismantling. A dedicated decommissioning strategy should be developed in advance of the end of Project life which includes industry best practice at the time of decommissioning.
2.7 Associated facilities Table 6 overleaf details the Project’s associated facilities and supporting infrastructure. Associated facilities are items of infrastructure that are required to enable or support the Project but do not form part of the project responsibilities of the Developer with other agencies responsible for their development. Supporting infrastructure will also be required to facilitate the operation of the Project and is the responsibility of the Developer to construct and operate; at the time of writing, no conceptual designs had been produced.
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Table 6: Associated facilities and supporting infrastructure for the Project Associated/ supporting components Summary Detail Responsible party Associated facilities Transmission line Power will need to be exported from A new transmission line is National Transmission the power plant to the national grid. proposed which will connect the and Dispatch Company power plant to the existing 500kV (NTDC) Jamshoro substation. The transmission line will be approximately 160km in length. The transmission line will largely traverse rural areas and is being designed and developed by the Government of Sindh. Substation To export the electricity generated by A new substation will be NTDC the Plant, developed at Block VI. The substation will connect the project and the transmission line to the national grid. Access roads Permanent paved access roads To facilitate access to the mine Government of Sindh required for construction and operation and power plant, the vehicle and plant access. Government of Sindh have commissioned construction of an 8km access road, which will be connected to a local highway to the south of the project. Wastewater discharge Any wastewater which cannot be The detailed route of the Government of Sindh pipeline reused in the process will be wastewater discharge pipeline is discharged off site in accordance with yet to be determined. national discharge limits. Supporting infrastructure Landfill site No appropriate waste disposal Details of the landfill site have The Developer facilities are located in the area. The not been provided; however, it is Developer will have a duty of care to expected that the landfill will be ensure that the waste is disposed of in developed within the mine. an environmentally sound manner Ash disposal facility Ash disposal facility required to Details of the ash disposal facility The Developer dispose of fly and bottom ash have not been provided; generated during operation however, it is expected that the landfill will be developed within the mine. Raw water supply Government of Sindh will be The detailed route of the water The Developer pipeline responsible for providing a water supply pipeline is yet to be supply source (in addition to the determined. The pipeline is dewatering undertaken at the mine) to expected to be approximately the site, which is sourced from the 15km in length. Vejhiar Reservoir. The Government of Sindh Energy Department has confirmed that the project will be considered for the provision of 38 cusecs either from left bank outfall drain (LBOD) phase II water source or the Makhi Farash link canal.
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3 Project need and alternatives
3.1 Introduction This chapter sets out the needs case for the Project in the context of economic, socio-economic and market factors in order to evaluate whether there are sufficient drivers to justify development of the Project. This section also provides analysis of the suitability of the site selection and potential alternatives.
The significant alternatives considered for the Project are broadly categorised as follows, and discussed in more detail below:
● Project need ● No project option ● Site alternatives ● Options and alternatives for key technical and process aspects of the Project.
3.2 Project need
3.2.1 Introduction Historically, electricity in Pakistan was generated, transmitted, distributed and supplied to consumer by a single entity, the Pakistan Water and Power Development Authority (WAPDA), except in Karachi where the functions was carried out by the Karachi Electric Supply Company. Structural changes and new policies developed during the past two decades have resulted in devolution of WAPDA into 11 separate companies for thermal and hydroelectric power generation, transmission and distribution. In addition, there are around 20 independent power producers that contribute significantly in electricity generation in Pakistan.
Despite these measures, Pakistan is not meeting the country’s electricity needs resulting in chronic power cuts in the main cities and prolonged power outages in rural areas of between 12 and 16 hours per day. Electricity generation in Pakistan has shrunk by up to 50% in recent years due to an over-reliance on fossil fuels. In its state of industry report 2014, the National Electricity Pricing and Regulatory Authority (NEPRA) projects that the existing shortfall in generating capacity of 5,500MW will continue until at least 2020 despite new capacity coming on stream during this period as demand continues to rise. In 2016, the IFC also estimated that the power shortage was between 3,000 and 6,000MW. Although, the Government of Pakistan has taken various measures to bridge the gap between supply and demand of the electricity, the energy crisis is anticipated to worsen in the coming years due to increase in demand and a host of other factors on the supply side. The most critical of these are the depleting natural gas reserves in the country which are the primary fuel for thermal power plants, failure to develop new hydroelectric energy resources and inadequate investment in the power sector. The country has increased its dependency on imported fuel. It is essential to take measures that decrease the dependence of the country on imported fuel and improve energy security through the development of Thar coal deposits to generate electric power from in-country coal resources. The Government of Pakistan is also committed to increasing energy supply to foster economic and social development.
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3.2.2 Energy production in Pakistan Currently Pakistan’s energy portfolio, detailed in Figure 7, is primarily dominated by natural gas and oil with at least one third of power being reliant on imported oil.
Pakistan’s discovered crude oil reserves are about 937 million barrels of which 583 million barrels have already been produced. Oil dominates Pakistan’s energy portfolio not only because of the need for liquid fuels for transport but also because one third of installed power generation capacity is reliant on imported furnace oil. Furthermore, dependence on imported oil is increasing as oil takes a larger share in generated energy due to domestic gas shortages.
Figure 7: Primary energy supply mix
Source: HDIP Pakistan Energy yearbook 2014
There is future potential for electricity imports from large-scale regional electricity transmission projects, gas imports through regional pipelines and liquified natural gas (LNG) imports but these all remain under discussion with long lead times.
The country has started diversifying its energy producing capacity by investing in wind and solar energy parks to help offset the energy shortage while larger hydroelectric projects and new nuclear plants are under construction; however the country still faces electricity shortages.
The Thar Coalfield based thermal generation projects are one viable option that will provide the necessary resource which is indigenous, so that it provides energy security, economical and less dependent on availability of foreign exchange. Its key advantages are discussed inthe sections below.
3.2.3 Pakistan’s future energy requirements
The Government of Pakistan has given the highest priority to improving the efficiency of the electricity supply; and also to implement conservation measures. Installed generation capacity was 19,566MW in June 2008 and current transmission and distribution losses (technical and non-technical) are estimated at about 25% of total generated power. The Government of Pakistan has recognised that the electricity distribution system requires considerable upgrading.
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The Power Policy 2013 committed to improving the efficiency of the current system and encouraging future generation projects throughout the country.
As set out in the Energy Sector Assessment for USAID/Pakistan (2007), the Government of Pakistan aims to enhance energy supply in Pakistan sustainably while reducing the dependence on imported oil and gas. Policy measures identified in this document include: ● Enabling a financial recovery, especially in the power sector ● Implementing a social protection programme to assist the poor in receiving a minimum amount of affordable energy ● Streamlining Government of Pakistan’s institutional set-up in the energy sector to increase decision-making efficiency ● Increasing private sector participation including through public private partnerships (PPPs) ● Enhancing regional energy trade. Based on information provided by the NTDC 3, it is expected that total energy demand is expected to increase by factors of between 5.6 to 8.2 times over from 2007 to 2030.
The Government of Pakistan expects a significant demand supply gap to remain in the short to medium term, even after the concerted promotion of energy conservation and energy efficiency, and the expanded deployment of lower-carbon energy resources such as indigenous hydropower, natural gas, and renewables. In order to address both the overall economic downturn and energy shortages within this framework it is essential that Pakistan moves forward with its energy sector reform program. The Government of Pakistan, together with the World Bank and other development partners, have been working closely to address current challenges as well as to devise and implement a strategy for sustainable sector development for the medium to long term. Development of the domestic coal-to-power sector is seen as part of a broader portfolio and the Government of Pakistan is aiming to increase coal’s share in Pakistan’s power consumption from 1% to 25% by 2025. This will include parallel action to develop domestic renewables including hydropower (to complement base-load energy production) and low carbon options, including potential for coal bed methane development, as well as improved energy efficiency and demand side management. These actions will provide increased energy security.
3.2.4 Government support The project has strong support from both the federal and Sindh Governments and a number of fiscal and financial incentives are in place:
● The Thar Coalfield provides fiscal incentives and tax breaks for the life of the Project ● The China-Pakistan Economic Corridor (CPEC) has included coal and power projects being developed in Thar as being priority projects. The Chinese Government and Chinese banks will finance Chinese companies investing in approved commercial projects in the corridor. Total financing is expected to be approximately $46bn USD with the financing of energy projects expected to be $34bn USD. The inclusion of the Developer’s Block VI integrated coal mine and 660MW power plant is indicative of the support given by the Chinese and Pakistani Governments. ● The Government is promoting the use of Thar Coalfield as an alternative to imported oil and gas
3 NTDC (2008) Electricity demand forecast (2008-2030) http://www.ntdc.com.pk/LoadForecast.pdf
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● The Government of Sindh has committed strong support for Thar coal through the establishment of: – The Energy Department – Sindh Coal Authority – Coal Mines Development Department – Thar Coal and Energy Board ● The Central Power Purchasing Authority (CPPA), a division of the NTDC, a government body which owns and operates the high voltage network in Pakistan, has issued a no objection certificate in November 2015 for the construction of the project. ● The Government is in the process of constructing major infrastructure improvements in Thar to facilitate mine and power development, including upgrading and constructing new roads from Karachi to Thar, constructing a new airport to serve the coalfield, as well as constructing and upgrading new high voltage transmission lines for power evacuation.
3.2.5 Current status of development of the Thar Coalfield As of January 2013, the Government of Sindh had identified 12 potential coal development blocks towards the south of the coalfield area where the coal seams are thickest and nearest to the surface, with two more blocks nearby in the development stage. The blocks occupy an extensive area which has implications for ease of access and servicing.
The blocks, which are to be leased to developers, vary in size from 48km 2 to over 200km 2. Each block developer will be expected to develop their own block but certain infrastructure may be shared. It should be noted that the blocks are not likely to be exploited simultaneously and there could be significant gaps of 20 years or more between the development of adjacent blocks. Block VI covers an area of 66km 2.
3.2.6 Fuel supply The Thar desert has one of the largest coal reserves in the world. SRK Consultants assessed a JORC 4 mineral resource in Block VI of 529 million wet tonnes of lignite (refer to Table 7). Although the coal is low grade lignite, it is commercially viable with a low sulphur and ash content and a high moisture (46%) content. Average gross calorific value of the lignite is 3,182 kcal/wet kg.
Table 7: JORC compliant mineral resources Mineral Tonnage Moisture Gross CV resources (Mt) (%) RD (wg/cm 3) (kcal/wkg) Ash (%) Sulphur (%) Measured 151 48.0 1.15 3,025 5.10 0.60 Indicated 308 45.3 1.15 3,257 5.60 0.91 Subtotal 459 46.2 1.15 3,181 5.44 0.81 Inferred 70 45.4 1.15 3,193 8.90 1.58 Total 529 46.1 1.15 3,182 5.89 0.91
Electrical power generation in Pakistan from coal is projected to increase from its current 1% to 25% by 2025 according to the Government of Pakistan’s national power policy. This will significantly increase the share of electricity from indigenous sources.
4 The Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves ('the JORC Code') is a professional code of practice that sets minimum standards for Public Reporting of minerals Exploration Results, Mineral Resources and Ore Reserves
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As the Project will be at the mouth of the Block VI mine, coal does not need to be transported far, which makes the process very efficient.
3.3 Analysis of alternatives
3.3.1 ‘No project’ alternative The ‘no project’ option considers the position if the proposed Project does not proceed. It assumes that no development would take place and the existing baseline situation would remain.
This option was not considered as an option due to the energy crisis in Pakistan and the need for power to boost the national economy. The importance of a power generation project in overcoming Pakistan’s energy shortages is evident and is discussed in Section 3.2. The proposed project could help to close approximately 10% of the current gap of 3,000MW to 6,000MW between supply and demand during peak hours. Without the proposed Project, this gap will continue to grow and have a negative impact on Pakistan’s economy and electricity supply.
The proposed Project could also help to attract future investments into the area where Thar coal has thus far remained untapped. By proving the business case for such developments, not only can Pakistan’s electricity supply increase but business prospects and investor confidence can also be boosted thereby reducing pressure on the country’s balance of payments.
The Project will result in job opportunities during the construction and operational phases. It is expected that the Project will provide good quality direct employment and training opportunities for local people. The Project will also stimulate secondary economic activity in the form of suppliers and other local service providers that will be supported by the increased income of people working at the Project.
With a ‘no project’ alternative, the current situation would remain and none of these benefits would be realised.
3.3.2 Site alternatives When assessing the suitability of a project site the location is often driven by all or a selection of the following factors:
● Designation of site for the use of land – the Project site is within an area designated for strategic coal to power development by the Sindh Government. ● Proximity to sensitive receptors – no settlements are expected to be impacted by the proposed power plant development. It is not located in an area of ecological significance and the impacts on flora and fauna are not expected to be significant. ● Proximity to raw materials/fuels - the proposed project is located adjacent to the Block VI mine, which will minimise the need for transportation of the lignite. The Thar region lacks rail connection to the rest of the country so other location options are limited. ● Proximity to connections for utilities – the Government of Sindh will construct a 500kV transmission line for power evacuation and is investing in infrastructure development initiatives such as building new roads to the coal fields. ● Proximity to newly created or refurbished infrastructure to transport raw materials to the site during construction. ● Availability of water for the closed-cycle cooling system to be sourced from the mines and a pipeline to be developed by the Government of Sindh.
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As discussed in section 1.1, the development of the Thar Coalfields and the associated establishment of coal to power projects are one of the major objectives of the Government of Sindh, to achieve increased power production, with associated economic growth to ultimately reduce poverty in the country.
3.3.3 Technology alternatives review The choice of system employed at a facility is based on economic, technical, environmental and local considerations such as availability of fuels, operational requirements, market conditions and network requirements. This section briefly appraises the options available for the project following the principles of best available techniques (BAT) which is used to assess best practice given the context of a development, as well as highlighting which options have been chosen.
This section references the European Commission’s BAT Reference (BREF) Notes for Large Combustion Plants (LCP) 2006 and Best Available Techniques (BAT) Reference Document for the Large Combustion Plants Draft 1 (June 2013) which set out what would constitute BAT in terms of a coal fired power plant in Pakistan. This is relevant because it demonstrates that the techniques being employed by the project are considered the best available based on economic, technical, environmental and local considerations such as the availability of fuels, the operational requirements, market conditions, network requirements.
A clear and comprehensive definition of BAT is provided within the European Union Directive 96/61/EC in article 2.11:
● "best available techniques" shall mean the most effective and advanced stage in the development of activities and their methods of operation which indicate the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where that is not practicable, generally to reduce emissions and the impact on the environment as a whole: ● "techniques" shall include both the technology used and the way in which the plant is designed, built, maintained, operated and decommissioned; ● "available" techniques shall mean those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator, ● "best" shall mean most effective in achieving a high general level of protection of the environment as a whole. The main issues relevant to this review were deemed to be the choice of combustion technology and the techniques proposed to control the key emissions generated by the project. A summary of the projects chosen option against the technology alternatives has been presented in Table 8.
Table 8: Technology alternatives System Technology Alternatives Chosen option Combustion ● Pulverised coal (PC) firing: ● The project will utilise CFB boiler technology technology – Dry bottom ash furnace ● The benefits of using this technology are as – Wet bottom ash furnace follows: ● Fluidised bed combustion furnace: – A high level of combustion efficiency – Non-pressurised systems – Low levels of NO x as a result of the low combustion temperatures. – Pressurised systems
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System Technology Alternatives Chosen option
● Grate firing – Low SO 2 emissions – through the ● Techniques to increase coal-fired injection of limestone and low combustion efficiency: temperatures. – Unburnt carbon in ash – Ability to combust a range of fuels as this technology is not highly sensitive to fuel – Air excess specifications and as such, lower grade – Flue-gas temperature coals can be combusted. ● Techniques to improve combustion – Supercritical technology is being used efficiency more for CFB technology – Supercritical – Combined heat and power Techniques to reduce ● Electrostatic precipitators (ESPs) ● ESPs have been selected which have very particulate emissions ● Fabric filters high efficiency, even for smaller particles ● Wet scrubbers and can handle large gas volumes with low pressure drops ● ESPs also reduce the emissions of aerosols and heavy metals ● ESPs can operate over a wide range of temperature, pressure and dust burden conditions ● Option to add fabric filters retrospectively ● The following specified particulate emission limits will be guaranteed: ≤50mg/Nm³ in compliance with the SEQS Techniques to reduce Primary measures: ● Pulverised limestone is fed into the CFB sulphur oxides ● Use of low sulphur fuel boiler to reduce the SO2 content of flue emissions (in particular ● Use of adsorbents in fluidised bed gases. sulphur dioxide SO2) combustion systems ● A SOx limit of ≤650mg/Nm 3 in compliance Secondary measures: with the SEQS will be guaranteed. ● Wet flue-gas desulfurization (FGD) - water ● Given the achievable emissions levels from + limestone as reagent the CFB boiler, FGD is not considered ● Semi-dry FGD - lime as reagent necessary. ● Seawater FGD Techniques to reduce Primary measures: ● Staged air injection will be used to convert nitrogen oxide ● Combustion modifications: nitrogen oxides formed back to nitrogen emissions ● Low excess air which is a simple technique, compatible with other measures to reduce NO x, low NO x ● Air staging combustion will also be used which can ● Air staging in the furnace (burner out of reduce NO x by 25-35% with staged air service, biased burner firing, over-fire air) injection ● Low NO x burners ● The following specified NO x limit of ≤350 ● Flue gas recirculation mg/Nm 3 will be guaranteed. ● In furnace ● Reduced air preheat ● Fuel staging ● In furnace (re-burning) Secondary measures: ● Selective catalytic reduction (SCR) ● Selective non catalytic reduction (SNCR) Cooling system ● Open once-through systems A closed-cycle circulating water system with ● Open wet cooling tower natural draft cooling towers was chosen for the project which uses approximately one- ● Open hybrid cooling tower twentieth of the water used in a once-through ● Natural draft cooling system. The water will be sourced from the ● Dry air-cooled condenser ground water produced from mine dewatering and if necessary from a Government water pipeline.
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3.4 Summary The Project will generate 2 x 330MW which will contribute towards bridging the gap between electricity supply and demand. The chosen location is preferred as it provides access to infrastructure being developed by the Government, has easy access to coal (mine mouth power plant) and will be developed within a designated strategic area for coal to power generation). The CFB boiler technology selected is highly efficient and significantly reduces NO x emissions as a result of low temperature combustion. Coal/lignite is the most appropriate fuel for the project because of its abundance in the Thar region.
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4 Policy, legal and institutional framework
4.1 Introduction There are a number of national and regional requirements that the project will have to comply with in addition to appropriate international standards. This section provides a brief overview of the applicable legislation, associated regulations and relevant standards that will be applied to the Project.
4.2 National institutional and legal framework
4.2.1 Historical and constitutional context Major national environmental legislation which have direct relevance to the Project are the Pakistan Environmental Protection Act (1997; PEPA) and the Pakistan Review of Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) Regulations (2000).
PEPA is the basic legislative tool empowering the Government of Pakistan to frame regulations for the protection of the environment and the promotion of sustainable development. It applies to a wide range of issues and extends to air, water, soil, noise pollution and to the handling of hazardous wastes.
The key features of PEPA that have a direct bearing on the proposed Project relate to the requirement for an environmental assessment. Section 12 requires that “No proponent of a development project shall commence construction or operation unless he has filed an IEE or, where the project is likely to cause an adverse environmental effect, an EIA, and has obtained from the Federal Agency approval in respect thereof.” The Pakistan EPA has delegated the power of review and approval of environmental assessments to the provincial EPAs in line with the 18 th Amendment of the Constitution of Pakistan in April 2010. This constitutional amendment delegated powers to the provincial governments, including on environmental matters and made the provincial EPAs independent authorities in terms of environmental decision-making. The Pakistan Review of IEE and EIA Regulations (2000) set out the requirements on the preparation, submission and review of IEEs and EIAs.
In 1993, the National Environmental Quality Standards (NEQS) were established. Section 11 and Section 15 of PEPA prohibits any emissions or discharges in excess of the NEQS which determine limit values or maximum allowable concentrations for parameters of wastewater, ambient air, motor vehicles’ exhaust gases and noise emissions, drinking water quality and ambient noise. The NEQS are applicable to pollutant discharges irrespective of the type of source and location.
All provinces have now enacted their own environmental protection laws. These provincial laws are largely based on Pak-EPA 1997 and provide the same level of environmental protection as the parent law. The provincial assembly of Sindh passed the Sindh Environmental Protection Act 2014 (the ‘Sindh Act 2014’) in March 2014.
4.3 Sindh Environmental Protection Act 2014 The Sindh Environmental Protection Act 2014 (SEP Act 2014) is the main legislative tool empowering SEPA to frame and govern regulations for the protection of the environment. The
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act is applicable to a broad range of issues and extends to air, water, industrial liquid effluent, marine and noise pollution, as well as to the handling of hazardous wastes.
Under the Sindh Act 2014, SEPA is an autonomous agency. For administrative purposes, it is part of the Forest, Environment and Wildlife Department of the Government of Sindh. SEPA is a regulatory agency with the following main functions:
● Enforcement of Sindh Act 2014 ● Implement environmental policies ● Ensure implementation of Sindh Environmental Quality Standards (SEQS) ● Establish systems and procedures for environmental management ● Issue licence for handling of hazardous substance ● Specify safeguards for the prevention of accidents which may cause pollution ● Review and approve mitigation plans and give guidance for clean-up operations ● Carry out any other task related to the environment assigned by the government.
4.4 Sindh Environmental Quality Standards Section 6 of the SEP Act 2014 prohibits any emissions or discharges in excess of the SEQS, which determine limit values or maximum allowable concentrations for parameters including wastewater, ambient air, motor vehicles’ exhaust gases and noise emissions, drinking water quality and ambient noise. The SEQS are applicable to pollutant discharges irrespective of the type of source and location.
4.5 Requirements for environmental impact assessment in Sindh Province SEPA will be responsible for the review and approval of the EIA of the Project. The articles of Sindh Act 2014 that have a direct bearing on the environmental assessment of the proposed project are: ● Article 17(1): ‘No proponent of a project shall commence construction or operation unless he has filed with the Agency an initial environmental examination or an environmental impact assessment, and has obtained from the Agency approval in respect thereof.’ ● Article 17(3): ‘Every review of an environmental impact assessment shall be carried out with public participation.
4.5.1 Objectives of ESIA The following are objectives of the ESIA study based on the Pakistan’s national and provincial environmental laws:
● Undertake consultation with the stakeholders to scope out the study and again to provide them with the feedback on the outcome of the study ● Prepare a physical, ecological and social baseline of the area of influence (the ‘Study Area’) in order to evaluate the potential environmental impacts of the proposed activities, and serve as reference for future ● Assess the potential environmental impact of the proposed activities and, where necessary, suggest mitigation measures to reduce any potential adverse impact to acceptable levels ● Prepare an environmental management plan to ensure that the proposed mitigation measures and corrective action measures are implemented ● Prepare an ESIA report complying with the legal requirements and the international guideline for submission to the SEPA.
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4.5.2 EIA approval procedure The national EIA approval procedure is shown in Figure 8.
Figure 8: EIA approval procedure
Source: EIA Guidance for Coal Fired Power Plants in Pakistan 2014
4.5.3 Other relevant legislation In addition to the environmental and social legislation presented in the previous sections, there is a range of further sectorial legislation that is relevant to the Project. This is summarised in Table 9.
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Table 9: Other legislation relevant to the Project Legislation (Year of issuance) Brief description Thar Coal and Energy Board Act, 2011 Thar Coal and Energy Board Act, 2011 was passed by the Provincial Assembly of Sindh on 8 June, 2011 and assented to by the Government of Sindh on 28 June, 2011 and is published as an act in the Legislature of Sindh. Under this act a board is required to be set up, and the membership of the board is made up of representatives from multiple government agencies with an interest in the Thar region or in the development of coal mining and power production. The Thar Coal and Energy Board (TCEB) will have a central role with its mandate for inter-agency support for Thar coal development especially related to policy formulation, programme/project monitoring and project facilitation at every stage of Thar coal projects. Pakistan Penal Code 1860 The Pakistan Penal Code deals with offences where public or private property and/or human lives are affected, due to intentional or accidental misconduct of an individual or body of people. In context of the environment, the penal code empowers local authorities to control noise, noxious emissions and disposal of effluents. Factories Act 1934 The Factories Act provides regulations for handling and disposal of toxic and hazardous materials. As construction activity is classified as ‘industry’, these regulations will be applicable. Sindh Wildlife Ordinance 1972 and Sindh Wildlife Ordinance 1972 and Amendments 2001 details the rules, Amendments 2001 regulations and permits for hunting, trapping, capturing of game animals; conservation of national parks, game reserves; and the laws and guidelines of working in protected area and sanctuaries. The Antiquities Act, 1975 and Sindh These acts deal with protection, preservation and conservation of Cultural Heritage Act 1994 archaeological/historical sites and monuments. It binds project proponents to notify the department if anything of archaeological value is discovered during project construction. The National Mineral Policy (NMP), This policy aims at promoting and developing the mining sector in Pakistan 1995 mainly through private investment. It includes environmental safeguards and compensation for injury. Sindh Coal Act 2012 The Sindh Coal Act 2012 has been designed to provide for regulation and development of coal in the Province of Sindh. Sections 6 and 7 of the Act stipulate that an environmental impact assessment, social assessment and environmental management plan are required for all projects engaged in exploration and exploitation of coal. Coal-based power generation or any other use of coal shall comply with the resettlement policy of the Government of Sindh. National Resettlement Policy 2002 and The National Resettlement Policy 2002 was developed to ensure equitable Interim Resettlement Framework and uniform treatment of resettlement issues across Pakistan and applies Guidelines 2011 to all development projects involving adverse social impacts, land acquisition, loss of assets, income and businesses. The Interim Resettlement Framework Guidelines 2010 set out the institutional, legal, and implementation framework to guide the resettlement and rehabilitation of project affected people (PAP) who will be adversely affected by the development of a project.
4.6 International treaties and conventions Pakistan is a signatory to a number of international E&S related treaties, conventions, declarations and protocols. The following are the relevant international treaties and conventions to which Pakistan is a party (Pakistan’s ratification, signatory or accession date is indicated behind each convention or treaty):
● Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention) – 1987 ● Convention on Wetlands of International Importance (Ramsar Convention) – 1976 ● Convention on International Trade of Endangered Species of Wild Fauna and Flora (CITES) – 1976
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● United Nations Convention on Biological Diversity – 1994 ● Stockholm Convention on Persistent Organic Pollutants – 2001 ● Rotterdam Convention on the Prior Informed Consent Procedures for Certain Hazardous Chemicals and Pesticides in International Trade – 2005 ● Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal – 1994 ● International Covenant on Economic, Social and Cultural Rights – 2004 ● International Labour Organisation’s (ILO) Core Labour Standards on: – Freedom of association and collective bargaining (conventions 87 and 98) – 1951 and 1952 – Elimination of forced and compulsory labour (conventions 29 and 105) – 1957 and 1960 – Elimination of discrimination in respect of employment and occupation (conventions 100 and 111) 2001 and 1961 – Abolition of child labour (conventions 138 and 182) – 2006 and 2001 Other ILO Conventions that Pakistan has ratified or signed ● United Nations Convention on the Rights of the Child – 2001 ● United Nations Framework Convention on Climate Change – 1994 ● Kyoto Protocol to the Convention United Nations Framework on Climate Change – 2005
4.7 National and international non-governmental organisations National and international environmental non-governmental organisations (NGOs) have been particularly active in advocacy, promoting sustainable development approaches. Much of the government’s environmental and conservation policy has been formulated in consultation with leading NGOs, who have also been involved in drafting new legislation on conservation such as the International Union for Conservation of Nature (IUCN) in Pakistan, which has developed a Red List at the Tharparkar regional level and at the national level.
4.8 International standards and guidelines Substantial information/data exists from previous assessments and studies undertaken in the area. As such, the air quality and waste and materials management chapters were able to be prepared in accordance with the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability 2012 (IFC PS).
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5 ESIA process and methodology
5.1 Introduction The ESIA has identified negative and positive, direct and indirect and cumulative impacts of the Project related to the bio-physical and the socio-economic environment .
The definition of the Project includes all infrastructure and facilities that are directly part of the proposed development. Given the limited detail available regarding the associated facilities at the time of this ESIA, a high level qualitative assessment of this infrastructure has been completed, noting that further assessment will be undertaken prior to their development.
5.2 Impact assessment methodology
5.2.1 Overview Following the review of the studies undertaken to date and the findings of the site visit, specialist assessments were carried out in order to predict potential impacts associated with the Project and propose measures to mitigate the impacts as appropriate. Each assessment chapter follows a systematic approach, with the principal steps being:
● Description of assessment methodology used ● Identification of the spatial and temporal scope of potential impacts (area of influence) ● Description of baseline conditions ● Impact assessment ● Identification of appropriate mitigation measures as required ● Assessment of residual impacts
5.2.2 Area of influence and temporal scope The area of influence (AoI) indicates where proposed works, including related facilities and infrastructure, will have a direct or indirect impact on the physical and social environment. This can result from aspects such as physical land-take or as a result of the extent of the potential impact that extend beyond the developments physical boundary such as noise emissions or emissions to air. The AoI can also vary according to the stage of the Project being assessed such that construction impacts may have a different area of impact than for operation.
For each impact assessment chapter, the spatial and temporal zones of influence are defined. It is important to note that the area of influence has primarily been based on the impacts associated with the Project itself. However, as far as reasonably practical and for the purposes of this ESIA consideration of the potential locations of the associated facilities has been taken into account in the defined spatial scope for each environmental and social aspect.
It should be noted that this approach has been adopted given that the detailed design and routing arrangements have not yet been finalised for the associated facilities. Further assessment will be undertaken for each of these components by the relevant developer/lending. agency once the design of these components has been confirmed.
5.2.3 Baseline data The primary sources of information for baseline assessment have been the existing information (secondary information) as well as some site surveys undertaken in 2016.
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5.2.4 Assessment of impacts
5.2.4.1 Overview The assessment of the significance of impacts and identification of residual impacts has taken account of any inherent mitigation measures incorporated into the project by the nature of its design. The significance of the resultant impact is largely dependent on the extent and duration of change, the number of people or size of the resource affected and their sensitivity to the change. The criteria for determining significance are specific for each environmental and social aspect but generally for each impact the magnitude is defined (quantitatively where possible) and the sensitivity of the receptor is identified. Generic criteria for the definition of magnitude and sensitivity are summarised below.
5.2.4.2 Magnitude The assessment of impact magnitude is undertaken in two steps. First, the key impacts associated with the Project have been categorised as beneficial or adverse. Second, the magnitude of potential impacts have been categorised as major, moderate, minor or negligible based on consideration of the parameters such as:
● Duration of the impact – ranging from temporary with no detectable impact to beyond decommissioning ● Spatial extent of the impact – for instance, within the site boundary to regionally, nationally, and internationally ● Reversibility – ranging from no change to permanent requiring significant intervention to return to baseline ● Likelihood – ranging from unlikely to occur to occurring regularly under typical conditions ● Compliance with legal standards and established professional criteria - ranging from meets standards or international guidance to substantially exceeds national standards and limits/international guidance. Table 10 outlines the generic criteria for determining magnitude.
Table 10: Generic criteria for determining magnitude Magnitude (beneficial or adverse) Description Major Fundamental change to the specific conditions assessed resulting in long term or permanent change, typically widespread in nature, and requiring significant intervention to return to baseline; exceeds national standards and limits. Moderate Detectable change to the specific conditions assessed resulting in non-fundamental temporary or permanent change. Minor Detectable but minor change to the specific condition assessed. Negligible No perceptible change to the specific condition assessed. Source: Mott MacDonald
5.2.4.3 Sensitivity Sensitivity is generally site specific and criteria have been developed from baseline information gathered and secondary information sources. The sensitivity of a receptor will be determined based on review of the population (including proximity/ numbers/vulnerability) and presence of features on the site or the surrounding area. Generic criteria for determining sensitivity of receptors are outlined in Table 11. Each detailed assessment defines sensitivity in relation to their topic if required.
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Table 11: Criteria for determining sensitivity Sensitivity Definition High Vulnerable receptor (human or ecological) with little or no capacity to absorb proposed changes or minimal opportunities for mitigation. Medium Vulnerable receptor (human or ecological) with limited capacity to absorb proposed changes or limited opportunities for mitigation. Low Vulnerable receptor (human or ecological) with some capacity to absorb proposed changes or moderate opportunities for mitigation Negligible Vulnerable receptor (human or ecological) with good capacity to absorb proposed changes or and good opportunities for mitigation Source: Mott MacDonald
5.2.4.4 Impact evaluation and determination of significance The significance of an impact can be described by the interaction of magnitude and sensitivity as depicted in the significance matrix shown in Table 12.
Table 12: Significance matrix
Magnitude
Adverse Beneficial
Major Moderate Minor Negligible Minor Moderate Major
High Major Major Moderate Negligible Moderate Major Major
Medium Major Moderate Minor Negligible Minor Moderate Major
Low Moderate Minor Negligible Negligible Negligible Minor Moderate
Sensitivity Negligible Minor Negligible Negligible Negligible Negligible Negligible Minor
Source: Mott MacDonald
The objective of the ESIA is to identify the likely significant impacts of the Project on the environment and people. Impacts that have been evaluated as being ‘moderate’ or ‘major’ are significant effects and identified as such in the specialist chapters. Consequently, impacts that are ‘minor’ or ‘negligible’ are not significant. The significance of impacts is given without mitigation being applied and following the implementation of mitigation (residual impacts).
5.2.4.5 Mitigation and enhancement measures Where feasible the following hierarchy of mitigation measures will be applied to reduce, where possible, the significance of impacts to acceptable levels:
● Mitigation/elimination through design ● Site/technology choice ● Application of best practice
5.2.4.6 Uncertainty Any uncertainties associated with impact prediction or the sensitivity of receptors due to the absence of data or other limitation will be explicitly stated. Where applicable, the ESIA will make commitments concerning measures that should be put in place with monitoring and /or environmental or social management plans to deal with the uncertainty. This is summarised in the Project ESMP that forms Volume IV of this ESIA.
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5.3 Cumulative impacts and transboundary impacts Cumulative impacts are those impacts that may result from the combination of past, present or future actions of existing or planned activities in a project’s area of influence. While a single activity may not itself result in a significant impact, it may, when combined with other impacts in the same geographical area and occurring at the same time, result in a cumulative impact that is significant.
A strategic environmental and social assessment (SESA) was previously completed on behalf of the Coal and Energy Development Department, Government of Sindh for the whole Thar Coalfield development to identify potential environmental and social impacts arising from the development of this area.
A cumulative impact assessment (CIA) which focuses on the development of the Project and the lignite mining activities within Block VI is presented in chapter 16 to provide an understanding of the likely combined environmental and social impacts.
The Convention of Transboundary Effects of Industrial Accidents (1992) states that “transboundary effects mean serious effects within the jurisdiction of a Party as a result of an industrial accident occurring within the jurisdiction of another Party”. The Project will not have any impacts to other countries; its effects are on a local/regional scale. Transboundary impacts have therefore not been considered as part of this ESIA.
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6 Information disclosure, consultation and participation
6.1 Overview This chapter outlines the information disclosure and consultation activities that have taken place prior to and during the development of the ESIA. The key objectives of this chapter are to: present a summary of all Project consultations that took place between 2011-2012 and served to inform stakeholders about the Project; outline the outcomes of the ESIA consultation activities undertaken in June 2016; detail the planned activities for the public disclosure of and consultation on the ESIA as required by Pakistani and Sindh regulations and to provide an outline of stakeholder engagement activities for the construction and operational phases of the Project.
The chapter consists of the following sub-sections:
● Consultation requirements
● Stakeholder identification and analysis
● ESIA consultation activities and outcomes to date (August 2016)
● Disclosure and consultation on the draft ESIA
● Stakeholder engagement planned throughout the lifetime of the Project
● Project grievance redress mechanism
● Community liaison officer (CLO) contact details
6.2 Consultation requirements
6.2.1 Overview This sub-section provides an overview of the national and regional requirements contained within the Pakistani and the Sindh Province Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) Regulations, 2000 and 2014 respectively.
6.2.2 National and regional requirements The Pakistan Review of IEE and EIA Regulations (2000) and the SEPA (Review of IEE and EIA) Regulations (2014) states that in the case of an EIA being conducted for a project, the following consultation requirements are to be met by the Federal Agency in charge:
● A public notice is to be issued in English and Urdu in a local newspaper within the project area. The notice should contain: a) the name of the project, b) its exact location, c) the name and address of the proponent and d) the places where the EIA can be accessed.
● The public notice issued should contain the date, time and place of the public consultation to be held with stakeholders, where they are able to provide comments on the project and its EIA.
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● Public consultation should not be earlier than 30 days after the date of publication of the public notice.
● The EIA must be circulated to all relevant government agencies.
● All comments received by the Federal Agency from the public and/or any Government Agency shall be collated, tabulated and duly considered before finalising the EIA.
The Guidelines for the Preparation and Review of Environmental Reports (1997) state that in order for the environmental and social assessment to be credible, fair and transparent, full public involvement should be a part of the process. This should include:
● Making all environmental reports available to the public
● Publishing lists of decisions – including the requirement for an EIA and the final outcome of environmental approval
● Public availability of any recommendations for mitigation and impact management plans
According to the Guidelines for the Preparation and Review of Environmental Reports (1997), good ways to disseminate the information contained within the EIA include local language video, radio and television, presentations, newsletters and information sheets, displays (supported by members of the study team), gatherings such as local community groups, small meetings and workshops.
The Guidelines for Public Consultation (1997) deal with approaches to public consultation and techniques for designing an effective program of consultation that reaches out to all major stakeholders and ensures the incorporation of their concerns in the impact assessment. These guidelines will be applied when undertaking the consultation for this Project.
6.3 Stakeholder identification and analysis Stakeholders are persons or groups who are directly or indirectly affected by a project, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. Stakeholders for the Project include locally affected communities and their formal and informal representatives, national or provincial government authorities, civil society organisations and groups with special interests, the academic community and businesses.
A stakeholder mapping and analysis exercise as well as identification of the most appropriate communication methods was undertaken at the outset of the ESIA process and will be updated as necessary throughout the Project. The affected communities and interested non- governmental stakeholders are identified in Table 13.
The Developer recognises that marginalised and disadvantaged groups are likely to experience impacts differently from mainstream society. For instance, they may be less able to cope with change such as influx of workers into the area than a typical community household or may be less able to take advantage of benefits such as employment generation.
Vulnerable groups include seasonal workers, ethnic minorities and people living below the poverty line. Consultation and information disclosure activities will enable the involvement of vulnerable groups by applying the appropriate logistical and cultural factors such as language, physical access, literacy levels, and time availability of these groups.
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Table 13: Identification of community and non-governmental stakeholders and communication methods
Stakeholders Community population Communication methods Proposed formats
Closest communities to the Project activities Residents of the five villages in Block 2,250 people; 636 ● Consultations and ● Public consultation 6 VI: Ranjho Noon, Yaqoob ji Dhani, households . interviews with directly ● Focus groups Yousuf ji Dhani, Gangoo ji Dhani and affected communities ● SESA scoping Salar ji 5. ● Disclosure of non- meetings technical project ● Brochures and information. leaflets distributed in ● Invitation to public locations frequented consultation meeting by people ● Project website ● Local newspapers ● Radio Vulnerable groups include seasonal No data ● Consultations, ● Public consultation workers, ethnic minorities, female interviews and informal ● Focus groups headed households and people living meetings. Disclosure of ● SESA scoping below the poverty line. non-technical Project meetings information. ● Brochures and ● Consultations with leaflets distributed in village elders or locations frequented community by people representatives ● Project website ● Invitation to public consultation meetings ● Local newspapers ● Radio Other nearby communities Villages outside of Block VI: Jodho 24,189 people; 4,719 ● Consultations, ● Public consultation 6 Bheel, Baka Karan, Mithe-ji-Wandh, households interviews with key ● Focus groups Anchle-ji-Dhani, Meghay Jo Tar, informants ● SESA scoping Monhtar, Meenho Lanjo, Magho Bheel, ● Disclosure of non- meetings Banbhinyo Bheel, Kanhe-ji-Dhani, technical Project ● Brochures and Sonal Beh, Jan Mohammand Noon, information Poonje-ji-Wandh, Parbho-ji-Dhani, leaflets distributed in ● Invitation to public Mansingh Bheel, Seengaro, Aban-jo- locations frequented consultation meeting Tar, Noray Ji Wandh, Bitra, Jaman by people Samo, Kachhibo Je Dhani and Saleh ● Project website Janjhi ● Local newspapers ● Radio Project employees and job seekers
Employees, prospective employees The total workforce ● Provision of non- ● Newspaper adverts (direct/indirect) and representatives of foreseen at technical information for jobs workers’ unions construction will be about the Project ● Notices at site and 1,000 people over a ● Disclosure of job office/noticeboards three year construction advertisements regarding period. Permanent ● Meetings with staff and recruitment employment for the trade union ● Project website operations phase of the representatives power station will be regarding key Project between 200 to 300 changes that affect staff, people. for example end of construction phase ● Workers’ grievance mechanism
5 Initially there were six villages in Block VI; however the village of Kharo Jani is in the process of being resettled as part of the Block VI Lignite Mining Project. As of September 2016, the land ownership survey is underway and potential resettlement sites within the Block are being identified. 6 Mott MacDonald Pakistan Focus Groups June 2016
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Stakeholders Community population Communication methods Proposed formats
Non-government organisations (NGOs)
Baanhn Beli, Thardeep Rural Development Programme, Marooara ● Consultations, interviews ● One-to-one meetings Coordination Council, Tharparkar Social Organization, World Wide or informal meetings and workshops / focus Fund for Nature, Society for Conservation & Protection of (commensurate with the group discussions Environment (SCOPE), Thar Aid Program, Association for Water NGO’s level of interest/ or ● Applied Education & Renewable Energy (AWARE), Telenor, influence in the Project) Letters / personal Pakistan Village Development Program (PVDP ), Thardeep Rural invitations ● Disclosure of reports Development Programme (TRDP), SAMI Foundation, Registhan ● Brochures and leaflets Social Welfare Association, Social Welfare Department, Tharparkar, ● Invitation to public Annual Reports Thar Aid Program, Actions, Re-construction and Humanitarian consultation meetings Response (SEARCH), Thar Welfare Council, National Commission ● Project website for Human Development (NCHD) and Sindhi Adabi Sungat ● Local newspapers
● Regional radio stations
Others
Media: ● Project staff member ● Press articles responsible for media Geo TV Channel, ARY TV Network, KTN TV Channel, Sindh TV ● communications identified Project website Channel, Mehran TV, Dawn News TV Channel, Express News ● Channel. Daily Dawn Newspaper , Daily Jang Newspaper, The ● Disclosure of Project Brochure and leaflets Nation Newspaper, Pakistan Observer Newspaper, the express information Tribune newspaper, Daily Business Recorder newspaper, Daily Ibrat Newspaper Hyderabad, Daily Awami Awaz newspaper, Daily Kawish newspaper, Daily Hilal e’ Pakistan newspaper and Radio Pakistan
Academia: ● Project staff member ● Press articles responsible for academia Department Of Economics - University Of Karachi, Aga Khan ● identified Project website University Karachi, NED University of Engineering and Technology , ● Brochure and leaflets Mehran University of Engineering and Technology; Engineering ● Disclosure of Project Development Board, Sindh Board Of Technical Education (SBTE) information and Sindh Technical Education and Vocational Training Authority (TEAVTA)
Table 14 overleaf identifies the government stakeholders and decisions makers at the national, provincial and local levels.
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Table 14: Government stakeholders and decisions makers
Stakeholders Relevance to the Communication Proposed formats Project (interest / methods influence)
National government
Coal Energy Development Department (CEDD) Proponent of Project ● Private meetings ● On-going consultations and ● Invitation to National Commission for Human Development Interested parties working relationships participate in with the authority Public Health Engineering Department public ● State Bank of Pakistan, Pakistan National Shipping consultations Invitation to public consultations and Corporation (PNSC) ● Disclosure of meetings Ministry of Commerce, Accountant General Pakistan, reports ● Trading Corporation of Pakistan Project website
Population Census Organisation, Trade Development Authority of Pakistan
Province Level Government and Authorities Sindh Environmental Protection Agency (SEPA) Approval of Private meetings On-going environmental Invitation to consultations and procedures participate in public working relationships with the authority Planning and Development Department Interested parties consultations Invitation to public Health Department Environmental Protection Agency Disclosure of reports consultations and Forest and Wildlife Department Archaeology meetings Department Project website Agriculture Department Education and Literacy Department Information and Archives Department Home Department Environmental and Alternate Energy Department, Finance Department Departments responsible for Food and Agriculture, Human Rights, Housing and Works, Transport, Communications, Culture, Minorities, Science and Technology, Water and Power, Interior, Labour and Manpower, Social Welfare and Special Education Mines and Minerals Department Sindh Police Interested parties Sindh Coal Authority Thar Coal and Energy Board
Maroora Welfare Association Interested parties Community Development Department of Information Technology (CDDIT)
District Level Government and Authorities
District Coordination Officer, Mithi Interested parties ● Private meetings ● On-going consultations and Executive District Officer, Health ● Invitation to working relationships participate in Executive District Officer, Education with the authority public District Officer, Social welfare consultations ● Invitation to public consultations and ● District Officer, Revenue Disclosure of meetings reports Executive District Officer, Agriculture ● Project website
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Stakeholders Relevance to the Communication Proposed formats Project (interest / methods influence)
Executive District Officer, Community Development Department
Executive District Officer, Finance and Planning
Municipal Government
Tehsil Municipal Authority, Diplo Interested parties ● Private meetings ● On-going consultations and Tehsil Municipal Officer, Diplo ● Invitation to working relationships participate in Tehsil Municipal Officer, Chachro with the authority public consultations ● Invitation to public consultations and ● Disclosure of meetings reports ● Project website
A SEP 7 for the Project will be produced. This plan will be considered live, as well as Table 13 and Table 14.
6.4 Introducing stakeholders to the Project and the developments in Block VI This sub-section presents the previous consultations undertaken in order to introduce stakeholders to the Project and outline the developments to be undertaken in Block VI. The stakeholder engagement activities that were undertaken from August 2011 to May 2012 are briefly outlined in Table 15 and then summarised in more detail in Volume III. The main issues discussed during these consultations were:
● People’s views on the developments of Block VI (open pit mine and power plant)
● Resettlement and land acquisition processes and people’s concerns
● Information disclosure to affected stakeholders and their current knowledge of the developments
● Local people’s concerns regarding the availability of local employment opportunities
Table 15 outlines the stakeholder engagement activities undertaken from August 2011 to May 2012.
Table 15: Consultation for the introduction of stakeholders to the Project and Block VI developments
Date Description Stakeholders Participants
Female Male Total
25 August – Interviews and focus 70 stakeholders from the list identified in No data No data 70 17 October group discussions with section 6.3 in Karachi and Tharparkar. In 2011 Project stakeholders Tharparkar the meetings were held in
7 Expected completion date unknown.
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Date Description Stakeholders Participants
three Talukas (towns), namely Islamkot, Mithi and Diplo.
October 2011 Consultations conducted Consultations conducted with specifically No data No data No data – January as part of the development selected local stakeholders from the 2012 of the Interim affected communities, local government, Resettlement Action Plan and the Thar Coal Project team
1 – 4 May Presentation of the draft Four focus groups conducted in Diplo, No data No data Diplo: 15 2012 Strategic Environmental Nagarparkar, Chachro and Islamkot Nagarparkar: 28 and Social Assessment Scoping Report for the Chachro: 17 Thar Coal Power Plant Project Islamkot: 29
6.4.1 ESIA consultation activities and outcomes to date (August 2016) More recent ESIA consultations were held with the five affected villages in Block VI in June 2016. The date, location and number of participants that were present at the focus group discussions are summarised in Table 16.
Table 16: ESIA consultations
Date Description Stakeholders Participants
Female Male Total
15 June 2016 Data gathering Male and female focus group 18 28 46 for ESIA from Ranjho Noon baseline and 16 June 2016 disclosure of Male and female focus group 15 5 20 information from Salar-Ji-Dhani
16 June 2016 Male and female focus group 7 9 16 from Gangoo-Ji-Dhani
16 June 2016 Male and female focus group 3 5 8 from Yaqoob Ji Dhani
17 June 2016 Male and female focus group 16 9 25 from Yousuf-Ji-Dhani Source: Mott MacDonald
The main focus of the meetings was to gather data from affected stakeholders that in turn has been used to inform the baseline, impact assessment and the mitigation / enhancement measures in relevant ESIA chapters. In addition, it was to verify what information regarding the Project had been disclosed to communities. A standard questionnaire was used and the information gathered is summarised collectively in Table 17.
Table 17: ESIA consultations conducted between 15 and 17 June 2016 with five affected communities in Block VI
No. Question from Mott Stakeholder response Chapter within this ESIA where this issue and MacDonald Pakistan relevant mitigation are reflected 1 Are any of the people in the None of the people are Chapter 16 ‘Social Impact Assessment’ Project affected area considered indigenous addresses indigenous people and ethnic considered indigenous? minorities in the affected areas.
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No. Question from Mott Stakeholder response Chapter within this ESIA where this issue and MacDonald Pakistan relevant mitigation are reflected 2 Do any community members 15 people have Chapter 16 ‘Social Impact Assessment’ reflects have experience in experience in masonry in the construction experience that people in the construction work? Ranjho Noon. No other affected areas have. There are enhancement experience in the rest of measures in the ESIA to enable local people to the communities. benefit from the 1,000 construction jobs that will be created as part of the Project. 3 What are some of the Illness Chapter 16 ‘Social Impact Assessment’ has challenges that have Drought / Water scarcity reflected the major challenges that have affected negatively affected the Poverty the people in the Project area. majority of the village? Lack of resources Unemployment 4 Have there been any Yes community This chapter reflects all the consultations previous consultations? members have conducted for the Thar Coal Power Plant Project previously been to date (August 2016). consulted by members of the M/S Oracle team (Sponsor). 5 What are the general views The people expect This chapter reflects people’s opinions regarding of the community regarding positive outcomes from the Project. the Project? this development for the local community as well as for whole nation. 6 What are people’s views on People are unaware of Chapter 16 ‘social impact assessment’’ the land acquisition and these issues and have resettlement in the Project area. resettlement? Are people not been informed. willing to relocate? Where do People will discuss people expect to be amongst themselves and relocated to? make a decision if such a situation arises. 7 Have you been explained The communities state Chapter 16 ‘social impact assessment’ how the areas of cultural or that no such cultural addresses impacts on cultural heritage found in historical significance will be heritage sites exist. the Project area. protected and is that sufficient?
6.5 Disclosure and consultation on the draft ESIA The requirements for the Pakistan Review IEE and EIA Regulations (2000) and the Sindh Environmental Protection Agency (Review of IEE and EIA Regulations) (2014) for this draft ESIA are listed in section 6.2.
6.6 Stakeholder engagement planned throughout the lifetime of the Project The SEP will outline ongoing stakeholder engagement and implementation of the grievance mechanism throughout the construction and operation phases. Activities will include communications as necessary with settlement representatives, community consultation events at key Project milestones such as the beginning and end of construction, regular updating of the Project website and social media, updating the SEP and annual sustainability reporting.
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Table 18: Stakeholder engagement throughout the construction and operation phases
Stakeholders Activity
Residents of the five villages in Block VI: Ranjho Noon, ● Community visits by the CLO, including meetings with Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Salar ji. stakeholders to address grievances and concerns
Vulnerable groups include seasonal workers, ethnic minorities ● Information disclosure when the Project phases change at the and people living below the poverty line. Information and Education Communication Centre (IECC) ● Distribution of the Non-technical summary
● Making all environmental reports available to the public
● Publishing lists of decisions – including the requirement for an ESIA and the final outcome of environmental approval
● Public availability of any recommendations for mitigation and impact management plans
● Workshop to explain Project plans and timescales in non- technical language and delivered in Sindhi and Thari, timed to enable participation by local people and vulnerable groups
● Grievance mechanism
Villages outside of Block VI: Jodho Bheel, Baka Karan, Mithe- ● Information disclosure when the Project phases change at the ji-Wandh, Anchle-ji-Dhani, Meghay Jo Tar, Monhtar, Meenho IECC Lanjo, Magho Bheel, Banbhinyo Bheel, Kanhe-ji-Dhani, Sonal ● Beh, Jan Mohammand Noon, Poonje-ji-Wandh, Parbho-ji- Making all environmental reports available to the public Dhani, Mansingh Bheel, Seengaro, Aban-jo-Tar, Noray Ji ● Publishing lists of decisions – including the requirement for an Wandh, Bitra, Jaman Samo, Kachhibo Je Dhani and Saleh ESIA and the final outcome of environmental approval Janjhi ● Public availability of any recommendations for mitigation and Federal Government Agencies impact management plans
Sindh Province Government Agencies ● Distribution of the Non-technical summary
Local District offices ● Information disclosure when the Project phases change at the IECC NGOs ● Making all environmental reports available to the public Media ● Publishing lists of decisions – including the requirement for an ESIA and the final outcome of environmental approval
● Public availability of any recommendations for mitigation and impact management plans
● Distribution of the Non-technical summary
6.7 Project grievance redress mechanism
6.7.1 Overview A grievance can be defined as an actual or perceived problem that might give grounds for complaint. As a general policy, the Project will work proactively towards preventing grievances through the implementation of impact mitigation measures and community liaison. Anyone can submit a grievance to the Project if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. They may also submit comments and suggestions. The sections below consider confidentiality and anonymity and the Project’s grievance resolution process.
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6.7.2 Confidentiality and anonymity The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in annual reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognise that there may be situations when disclosure of identity is required and the Project will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities.
6.7.3 Grievance Reporting and Resolution Grievances will be logged in a formal logging system for which the CLO will be responsible. People may register grievances by contacting the CLO or reporting to their village leader, or other community representative. Contact details for the CLO will be included in appropriate Project communication materials such as the non-technical summary (NTS).
The CLO will classify grievances according to Table 19. Where investigations are required, Project staff and outside authorities as appropriate, will assist with the process. The CLO will collaborate with the project management team to identify an appropriate investigation team with the correct skills to review the issue raised. The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities.
Table 19: Grievance classification criteria and response process and timeframes
Classification Risk Level (to health, safety or Response process and timeframes environment) Low No or low CLO will conduct investigation, document findings and provide a response. Medium Possible risk and likely a one-off CLO and an appropriate investigation team will event conduct investigation. The Site Manager or Occupational Health and Safety Manager may decide to stop work during the investigation to allow the corrective preventive actions to be determined. The CLO will provide a response. High Probable risk and could reoccur CLO will get the contractor to organise an investigation team for prompt investigation and resolution. Work may be stopped in the affected area. The CLO will provide a response. Source: Mott MacDonald
Where investigations are required, Project staff and outside authorities will assist with the process. The CLO will collaborate with the CEDD to identify an appropriate investigation team with the correct skills to review the issue raised and to decide whether it is Project related or whether it is more appropriately addressed by a relevant authority outside the Project. The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities. In some cases, it will be appropriate for the CLO to follow up at a later date to see if the person or organisation is satisfied with the resolution or remedial actions. Each grievance will be given an identification number and followed through by recording details and timing for their resolution and closing out.
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The CLO will summarise grievances to report on Project performance weekly during construction and bi-annually during operation removing identification information to protect the confidentiality of the complainant and guaranteeing anonymity. The contact details of the CLO are to be advised by CEDD once the appointment has been made. This should be done immediately so that the grievance mechanism can be opened to members of the public as soon as possible. The procedure for processing grievances is depicted in Figure 9.
Figure 9: Flowchart for processing grievances
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6.8 CLO contact details All general comments, queries and grievances can be submitted to the CLO, whose contact details are listed below in Table 20.
Table 20: CLO contact details
Community Liaison Officer Name Noushaba Kamran Soomro Company Sindh Carbon Energy Postal Address: Suite No.203, Cotton Exchange Building, I.I Chundriger Road Karachi Telephone +3333917412 E-mail address [email protected] Project Website www.sindhcarbonenergy.com
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7 Air quality
7.1 Introduction
7.1.1 Overview This chapter provides an assessment of the potential impacts on air quality caused by the construction, decommissioning and operation of the Project. This assessment has been carried out in accordance with national and international guidelines.
7.1.2 Key pollutants The combustion of fossil fuel gives rise to a number of pollutants with the potential to negatively affect local air quality. With respect to lignite coal (the proposed fuel for this Project), the primary pollutants of concern are:
● Oxides of nitrogen (NO x)
● Sulphur dioxide (SO 2) ● Particulate matter (PM) ● Carbon monoxide (CO) ● Hydrogen fluoride (HF) ● Hydrogen chloride (HCl) ● Heavy metals
7.1.2.1 Oxides of nitrogen Oxides of nitrogen is a term used to describe a mixture of nitric oxide (NO) and nitrogen dioxide (NO 2), referred to collectively as NO x. These are primarily formed from atmospheric and fuel nitrogen as a result of high temperature combustion.
During the process of combustion, atmospheric and fuel nitrogen is partially oxidised via a series of complex reactions to NO. The process is dependent on the temperature, pressure, oxygen concentration and residence time of the combustion gases in the combustion zone.
Most NO x exhausting from a combustion process is in the form of NO, which is a colourless and tasteless gas. It is readily oxidised to NO 2, a more harmful form of NO x, by chemical reaction with ozone and other chemicals in the atmosphere. NO 2 is a yellowish-orange to reddish-brown gas with a pungent, irritating odour and is a strong oxidant.
7.1.2.2 Sulphur dioxide
SO 2 is a colourless, non-flammable gas with an odour that irritates the eyes and air passages. It reacts on the surface of a variety of airborne solid particles, is soluble in water and can be oxidised within airborne water droplets. The most common sources of SO 2 include fossil fuel combustion, smelting, manufacture of sulphuric acid, conversion of wood pulp to paper, incineration of waste and production of elemental sulphur. Coal burning is the single largest man-made source of SO 2, accounting for about 50% of annual global emissions, with oil burning accounting for a further 25-30%.
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7.1.2.3 Particulates PM is a complex mixture of organic and inorganic substances present in the atmosphere. Sources are numerous and include power stations, other industrial processes, road transport, domestic coal burning and trans-boundary pollution. Secondary particulates, in the form of aerosols, attrition of natural materials and, in coastal areas, the constituents of sea spray, are significant contributors to the overall atmospheric loading of particulates. In urban areas, road traffic is generally the greatest source of fine particulate matter, although localised effects are also associated with construction and demolition activity.
7.1.2.4 Carbon monoxide Carbon monoxide (CO) is a colourless, odourless gas produced by the incomplete combustion of carbon-based fuels and by biological and industrial processes. The major source of carbon monoxide is traffic, particularly in urban areas. CO is produced under conditions of inefficient combustion, is rapidly dispersed away from the source and is relatively inert over the timescales relevant for its dispersion. CO has always been present as a minor constituent of the atmosphere, chiefly as a product of volcanic activity but also from natural and man-made fires and the burning of fossil fuels.
7.1.2.5 Hydrogen fluoride HF is a colourless gas with a pungent smell. HF can cause irritation to the eyes, nose and throat, and high levels of exposure can cause muscle spasms and may damage internal organs. The main releases of hydrogen fluoride are from high temperature industrial processes.
7.1.2.6 Hydrogen chloride HCl is a colourless or slightly yellow corrosive gas. It is highly soluble in water, forming hydrochloric acid. HCl is formed by industrial activities such as coal-burning power stations and incinerators. Fossil fuels contain small amounts of naturally-occurring chlorides and HCl is produced when they are burnt.
7.1.2.7 Heavy metals Heavy metals associated with coal combustion include arsenic, cadmium, chromium, copper, mercury, nickel, lead, selenium, vanadium and zinc. Emissions of these metals result from their presence in the coal and are released during combustion.
7.1.2.8 Other In addition to the above pollutants, other substances such as dioxins and unburnt hydrocarbons can also be released. Often these pollutants are found in coal and released when incomplete combustion occurs when there is insufficient oxygen.
7.2 Applicable legislation
7.2.1 Overview This section details the legislative requirements in terms of ambient air quality standards for the protection of human health and emissions limits applicable to coal fired power plants. For comparison and reference, international standards for emissions limits have also been included.
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7.2.2 National requirements The Government of Pakistan’s Ministry of Environment published two Statutory Notifications relating to air quality on 10 August 2000 and t18 October 2010. The Statutory Notifications, known as the NEQS, set the standards in Pakistan for emission limits and ambient air quality standards.
In December 2014, SEPA issued Notification NO.EPA/TECH/739/2014, which repealed the NEQS in the Sindh Province and provides a new set of emissions limits and ambient air quality standards. The Sindh EPA standards are referred to as the SEQS for industrial gaseous emissions.
7.2.2.1 Pakistan emissions limits Relevant emission limits from the SEQS are presented and compared to international standards in Table 21.
7.2.3 International guidelines
7.2.3.1 IFC PSs The IFC provides a portfolio of standards and guidelines that should be adhered to for any Project seeking IFC finance. The IFC PS3: Resource Efficiency and Pollution Prevention aims: ‘to avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from Project activities’. To achieve this, the IFC provides both industry- specific and general guidance on Good International Industry Practice (GIIP) with respect to emissions to air. Relevant IFC emission limits are presented for comparison in Table 21.
Table 21 provides a summary of the relevant international emission limits potentially applicable to the Project.
Table 21: Relevant emission standards Pollutant Pakistani standards (mg/Nm 3) (a) IFC guidelines (mg/Nm 3) (b) Non-degraded Degraded airshed (NDA) airshed (DA) (c)
NO x 1200 510 or up to 1,100 200 if volatile matter of fuel <10% (e) SO 2 Emissions limits for SO 2 are dependent on 900-1500 400 existing ambient air quality in the Project area and specify maximum emissions limits and allowable contributions to ground level concentrations shown in Table 22. PM 500 (d) 50 30 CO 800 - - Lead 50 - - Mercury 10 - - Cadmium 20 - - Arsenic 20 - - Copper 50 - - Antimony 20 - - Zinc 200 - - Source: NO.EPA/TECH/793/2014, Government of Sindh Environment Protection Agency (2014).
Notes: (a) Reference conditions not stated
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(b) IFC EHS Guidelines for Thermal Power Plants. Nm³ is at 0ºC, dry, 6% O 2, 1 atmospheric pressure
(c) An airshed is considered to be degraded if nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly.
(d) Sectoral guidelines state that removal efficiencies from exhaust gases are over 99% for all particulates and over 98% for PM 10 . These removal efficiencies should be achieved at least 95% of the time that the plant is operating.
(e) Targeting the lower guideline values and recognising issues related to quality of available fuel, cost effectiveness of controls on smaller units, and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant).
National emissions limits for SO 2 are dependent on existing ambient air quality in the Project area. The maximum emissions limits and allowable contributions to ground level concentrations shown in Table 22.
Table 22: Standards for oil and coal fired power plants – sulphur dioxide Background Air Annual Maximum 24 Criterion I Criterion II Quality (SO 2 Average Hour Max SO 2 Max allowable ground Basis) Concentration Concentration Emissions (tpd per level increment to (µg/m³) (µg/m³) plant) ambient (µg/m³) (c) Unpolluted < 50 < 200 500 50 Moderately polluted (a) - low 50 200 500 50 - high 100 400 100 10 Very polluted (b) > 100 > 400 100 10 Source: NO.EPA/TECH/793/2014, Government of Sindh Environment Protection Agency (2014)
Notes: (a) For intermediate values between 50 and 100µg/m³ linear interpolations should be used. (b) No projects with SO 2 emissions will be recommended. (c) Annual average.
In addition to the emission limits from NO x, presented in Table 21, the SEQS also provides maximum mass emissions of NO x for stationary source discharges, based on heat input of the plant and are presented in Table 23.
Table 23: Maximum mass emissions for stationary sources – oxides of nitrogen Fuel-fired steam generator type Nanogram per joule of heat input Liquid fossil fuel 130 Solid fossil fuel 300 Lignite fossil fuel 260 Source: NO.EPA/TECH/793/2014, Government of Sindh EPA (2014)
7.2.4 Ambient air quality standards
7.2.4.1 Government of Sindh air quality standards The Government of Sindh’s EPA published updated air quality standards for Pakistan in December 2014. All ambient air quality standards and the applicable averaging periods are presented in Table 24 overleaf.
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Table 24: Sindh Environmental Quality Standards for ambient air Pollutant Time-weighted average Concentration in ambient air (a) (b)
Sulphur dioxide (SO 2) Annual 80 µg/m³ 24 hours 120 µg/m³ Oxides of nitrogen Annual 40 µg/m³ (as NO) 24 hours 40 µg/m³ Oxides of nitrogen Annual 40 µg/m³ (as NO 2) 24 hours 80 µg/m³ Ozone (O 3) 1 hour 130 µg/m³ Suspended particulate matter (SPM) Annual 360 µg/m³ 24 hours 500 µg/m³ Respirable particulate matter (PM 10 ) Annual 40 µg/m³ (c) 24 hours 150 µg/m³ Respirable particulate matter (PM 2.5 ) 24 hours 75 µg/m³ Carbon monoxide (CO) 8 hours 5 mg/m³ 1 hour 10 mg/m³ Lead (Pb) Annual 1µg/m 3 24 hours 1.5µg/m 3 Source: NO.EPA/TECH/793/2014, Government of Sindh EPA (2014)
Note: (a) Annual arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval.
(b) 24 hourly / 8 hourly values should me met 98% of the time in a year. 2% of the time it may be exceeded but not on two consecutive days.
(c) Annual Average limit of 40 µ/m³ or background annual average concentration plus allowable allowance of 9µg/m³, whichever is lower.
7.2.4.2 IFC Guidelines The IFC General Environmental Health and Safety (EHS) Guidelines advise that ‘relevant standards’ with respect to ambient air quality are national legislated standards or, in their absence, the current World Health Organisation (WHO) Air Quality Guidelines or other internationally recognised sources. As Pakistan has its own nationally legislated standards, as described above, no additional international standards have been presented for comparison purposes.
The IFC General EHS Guidelines suggest that, as a general rule, emissions should not contribute more than 25 percent of the relevant air quality standards to allow additional, future sustainable development in the same airshed and this approach has been used to help determine the significance of impacts.
7.3 Methodology and assessment criteria
7.3.1 Overview This section provides an overview of the assessment approach taken and the inputs used within the dispersion modelling.
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7.3.2 Scope of assessment
7.3.2.1 Temporal scope It is anticipated that the construction period of the Project will be a maximum of 40 months and the operational lifetime of the Project will be for a minimum of 30 years.
7.3.2.2 Spatial scope The baseline includes a review of available air quality data in the vicinity of the Project.
Construction impacts would be located close to the site and will not extend beyond 500m from the construction or decommissioning activities.
In accordance with best practice, potential impacts of emissions from the operation of the Project on ambient air quality have been assessed within 15km of the stack as all potentially significant impacts are predicted to occur within this distance.
7.3.3 Construction phase impact assessment methodology Construction activities can result in temporary effects from dust. ‘Dust’ is a generic term which usually refers to particulate matter in the size range 1-75 microns. Emissions of construction dust are predominantly associated with the movement and handling of minerals and therefore composed of the larger fractions of this range, which do not penetrate far into the respiratory system. Therefore, the primary air quality issue associated with construction phase dust emissions is normally loss of amenity and/or nuisance caused by, for example, soiling of buildings, vegetation and washing and reduced visibility.
Dust deposition can be expressed in terms of mass per unit area per unit time, e.g. mg/m 2/month. No relevant Pakistani or IFC standards exist for dust deposition; however, a range of criteria from 133 to 350mg/m 2/month is found around the world as representative of thresholds for significant nuisance.
It is considered that a quantitative approach is inappropriate and unnecessary for assessing particulate emissions associated with the construction and decommissioning phases of the Project, given their relatively short duration and limited number of sensitive receptors. The potential for construction and decommissioning activities to raise dust, and the likely consequences of dust emissions have therefore been assessed qualitatively.
The first stage of the assessment involved the identification of construction activities which have the potential to cause dust emissions, along with the degree of dust potential. Table 25 provides a generic list of potential activities at each stage of construction. Selected information for this table has been used within this assessment to determine the impact of the Project with respect to construction dust.
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Table 25: Relevant generic dust emitting activities Potential dust emitting Description Dust emission activities potential Aggregate handling Potential to be high in dust nuisance, depends on High soil dryness Loading Activities Potential to be high in dust nuisance, depends on High material characteristics Storage of materials onsite Potential to be high in dust nuisance, depends on High material characteristics Transport of materials within site Can be high depends on type of transport and Medium nature of road surface Drilling and digging activities Can be high depending on type of drilling and High (Including soil excavation) digging activities and material characteristics Transport of material offsite Generally low as transport occurs by surfaced Low roads Construction of new buildings Generally low although some activities with high Medium-Low dust raising such as material cutting can occur Assembly of plant Generally low as involves assembling Low prefabricated pieces Source: Table adapted from UK Department for Environment and Rural Affairs and Buildings Research Establishment guidance
In the second stage of the assessment, all sensitive receptors with the potential to be significantly affected by construction dust emissions have been identified. The distances from source at which construction dust effects are felt are dependent on the extent and nature of mitigation measures, prevailing wind conditions, rainfall and the presence of natural screening by, for example, vegetation or existing physical screening such as boundary walls on a site. However, research indicates that effects from construction activities that generate dust are generally limited to the areas within 350m 8 of the construction site boundary. To ensure a conservative assessment, any receptors within 500m of the construction site boundary have been identified, and their classification determined in accordance with Table 26.
Table 26: Receptor classification Classification High Medium Low Negligible Hospitals and clinics Residential property Arable farm land Pastoral farmland - School Other Industry - - Place of worship - -
It should be noted that the same approach used for the construction phase has been used for assessing operational impacts from the coal storage and handling facilities.
At this stage exact numbers of construction vehicles are not known and the routes that they will take are not defined. However, during peak construction periods the total number of vehicle movements is expected to be less than 200 per day 9. On this basis, there is not considered to be the potential for significant impacts. Nevertheless, appropriate mitigation measures have been included to further reduce effects on local air quality.
8 Holman et al (2014). ‘Guidance on the assessment of dust for demolition and construction’, Institute of Air Quality Management, London 9 Design Manual for Roads and Bridges’, HA207/07, Volume 11, Section 3 Part 1 ‘Air Quality’, Highways Agency, UK
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7.3.4 Operation phase impact assessment methodology
7.3.4.1 Dispersion model A number of commercially available dispersion models are able to predict ground level concentrations arising from emissions to atmosphere from elevated point sources such as a power plant. A new generation dispersion model - AERMOD (executable version 15181) was used to inform the basis of the air quality assessment. AERMOD is approved for use in Pakistan and is listed in the ‘EIA Guidance for Coal Fired Power Plants in Pakistan’ 10 . A model description is included below.
A committee, AERMIC (the American Meteorological Society / Environmental Protection Agency Regulatory Model Improvement Committee), was formed to introduce state-of-the-art modelling concepts into the US Environmental Protection Agency’s local-scale air quality models. AERMIC’s focus was on a new platform for regulatory steady-state plume modelling. AERMOD was designed to treat both surface and elevated sources in simple and complex terrain.
Special features of AERMOD include its ability to treat the vertical heterogeneity nature of the planetary boundary layer, special treatment of surface releases, irregularly-shaped area sources and limitation of vertical mixing in the stable boundary layer.
AERMOD is a modelling system with three separate components and these are as follows:
● AERMOD (AERMIC Dispersion Model) ● AERMAP (AERMOD Terrain Pre-processor) ● AERMET (AERMOD Meteorological Pre-processor). AERMET is the meteorological pre-processor for AERMOD. Input data can come from hourly cloud cover observations, surface meteorological observations and twice-a-day upper air soundings. Output includes surface meteorological observations and parameters and vertical profiles of several atmospheric parameters.
AERMAP is a terrain pre-processor designed to simplify and standardise the input of terrain data for AERMOD. Input data include receptor terrain elevation data. For each receptor, the output includes a location and height scale, which is an elevation used for the computation of air-flow around hills.
7.3.4.2 Emissions to air Emissions data have been based on information provided by SEPCO and additional calculations have carried out as part of this assessment.
Data provided by SEPCO including stack dimensions, exhaust gas temperature and excess air in the exhaust gas have formed the basis of data used within the dispersion modelling and this data is presented in Table 27 overleaf.
Following a review of the potential operating scenarios two scenarios have been assessed to identify the potential impacts of the Project:
● Scenario 1: Maximum load (100% boiler load) ● Scenario 2: Low load (45% boiler load)
10 Coutinho, Miguel and Butt, Hamza K. 2014. Environmental Impact Assessment Guidance for Coal Fired Power Plants in Pakistan. Islamabad: IUCN Pakistan. 149 pp.
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The Project is expected to achieve emissions lower than the SEQS emission limits for NO x, SO 2 and PM. In addition, the Project will also achieve emissions lower than the IFC non-degraded airshed emission limits for NO x and SO 2 and meet the emissions limits for PM.
Emissions of CO are related to poor combustion and therefore would be mitigated through the efficient operation of the Project. Emissions of CO have not been assessed further as they are not a key pollutant with respect to this assessment given the predicted emission rates and because relevant ambient standards are significantly higher than those for NO 2, SO 2 and PM 10 .
In addition to the pollutants included in the dispersion modelling assessment, the consideration of heavy metals is also relevant for human health (concentrations in ambient air quality). Table 28 presents the results of a study that analysed borehole lignite samples within Block I, II and III in the Tharparkar Region. These data have been used to calculate likely emission rates of a range of heavy metals after the exhaust gas has passed through the electrostatic precipitator (ESP). An International Journal of Coal Geology entry on the analyses of chemical elements and their behaviour in power plants demonstrated that heavy metals are present in fly ash downstream of ESP and in the last hopper (finest fraction) of an ESP 11 . It has therefore been assumed that all metals are present in the PM 2.5 emitted.
The only heavy metal that the SEQS set an ambient standard for is Pb, as presented in Table 24. The heavy metal emissions rates presented in Table 28 are several orders of magnitude lower than those for NO 2, SO 2 and PM. Therefore, concentrations of heavy metals would also be several order of magnitude lower than those predicted for NO 2, SO 2 and PM. The impacts from heavy metals have not been considered further within this assessment as predicted impacts are likely to be extremely low, have no ambient standards for comparison, except for Pb, and are therefore considered to be not significant.
Although the proposed abatement for the Project will not specifically reduce emissions of HCl and HF, emissions are expected to be very small relative to pollutants such as NO x, SO 2 and PM. The European Union (EU) Best Available Technique Reference document for Large Combustion Plants (BREF note) Final Draft BREF 12 note states that the BAT associated level of HCl is between 15-30mg/Nm 3. On this basis, no further assessment has been undertaken as impacts are considered to be not significant.
The EU BREF note states ‘emissions of dioxins and furans from coal plants are low due to their specific combustion characteristics and the sulphur content of the fuel which impedes the combustion of these compounds’. The BREF note provides emission levels of dioxins from a range of existing coal plants which are 2pg/Nm 3 (10 -12 g). This indicates that the maximum impacts would be over a million times smaller than the impacts predicted for PM and therefore have not been considered further as impacts are considered to be not significant.
Table 27: Emissions data Parameter Unit Scenario 1 Scenario 2 Stack Height m 210 210 Stack Diameter (b) m 7.1 7.1 Efflux Temperature °C 130 130 Plant load % 100 45 Output MWe 660 297 Actual Volumetric Flow Am 3/s 1087.4 489.3
11 Meij, R. and te Winkel, B.H. (2009) “Trace elements in world steam coal and their behaviour in Dutch coal-fired power stations: A review”, International Journal of Coal Geology, 77, 289-293. 12 European Commissions, Best Available Techniques (BAT) Reference Document for the Large Combustion Plants, Draft 1, June 2013
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Parameter Unit Scenario 1 Scenario 2 Normalised Volumetric Flow (a) Nm 3/s 685.5 308.5 Efflux Velocity m/s 27.7 12.5 3 NO x emission limit mg/Nm 350 350 3 SO 2 emission limit mg/Nm 625 625 PM emission limit mg/Nm 3 50 50
NO x mass emission g/s 239.9 108.0
SO 2 mass emission g/s 428.5 192.8 PM mass emission g/s 34.3 15.4 (a) Note: – 6% O 2, dry, 1 atm
(b) – Two boiler units, each with a 5m diameter flue will feed into a common wind shield. The combined cross sectional area of the two flues, at which the exhaust gas is released at the top of the windshield, is calculated. The 7.1m dimeter is representative of the joint cross sectional area.
Table 28: Metal content of Thar Coalfield lignite samples (Block I, II and III) Metals PPM (mg/kg) Emission Rate (g/s) after ESP Minimum Maximum Antimony (Sb) 1 4 0.00197 Arsenic (As) 1 4 0.00197 Beryllium (Be) (a) 1 1 0.00049 Cadmium (Cd) 0.1 0.4 0.0002 Chromium (Cr) 21 47 0.02319 Cobalt (Co) 2 25 0.01234 Copper (Cu) 8 38 0.01875 Lead (Pb) 36 65 0.03208 Manganese (Mn) 0.1 2 0.00099
Mercury (Hg) (a) 1 1 0.00049 Nickel (Ni) 9 75 0.03701 Selenium (Se) (a) 1 1 0.00049 Zinc (Zn) 8 116 0.05725 Source: PhD Thesis 13
Note: (a) Assumed values in the absence of other data.
7.3.4.3 Meteorological data The most important meteorological parameters governing atmospheric dispersion of pollutants are wind direction, wind speed and atmospheric stability; as described below:
● Wind direction determines the sector of the compass into which the plume is dispersed. ● Wind speed affects the distance which the plume travels over time and can affect plume dispersion by increasing initial dilution of pollutants and inhibiting plume rise. ● Atmospheric stability is a measure of the turbulence of the air, and particularly of its vertical motion. It therefore affects the spread of the plume as it travels away from the source. New generation dispersion models use a parameter known as the Monin-Obukhov length that, together with wind speed, describes the stability of the atmosphere.
13 Environmental Study of Coal Deposits of Sindh, with Special Reference to Heavy and Trace Metal Study in Thar, Sonda and Meting- Jhimpir Coal Field. Dr Imdadullah Siddiqui, National Centre of Excellence in Geology, University of Peshawar (2007)
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For meteorological data to be suitable for dispersion modelling purposes, a number of parameters need to be measured on an hourly basis. These parameters include wind speed, wind direction, cloud cover and temperature. Available data from Chorr and Mithi were reviewed and data capture and consistency found to be insufficient for modelling purposes. Data were therefore sourced from the closest and most representative meteorological monitoring site to the Project that measures all the required parameters and is internationally verified by the National Oceanic and Atmospheric Administration’s Climate Data Center and has been converted to hourly values using an internationally recognised method 14 . The meteorological monitoring site at Badin is located approximately 140km to the west of the Project.
As part of the baseline monitoring undertaken for the Project, presented in section 7.4, three days of meteorological data were collected at three separate sites; their locations are presented in Figure 14. The Project meteorological data collected, presented in Volume III: Technical Appendices, shows dominant southerly winds similar to those monitored at Badin.
On the basis that meteorological data from Badin is internationally verified and similar to Project specific meteorological data, the dispersion modelling has been based on data from Badin meteorological station from 2009-2013. Windroses presenting this data are presented in Figure 10 overleaf.
14 Atkinson. D. and Russell. F. Lee, (1992) ‘Procedures for Substituting Values for Missing NWS Meteorological Data for Use in Regulatory Air Quality Models’, USEPA.
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Figure 10: Badin meteorological windroses (2009 – 2013)
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7.3.4.4 Surface roughness and terrain Roughness of the terrain over which a plume passes can have a significant effect on dispersion by altering the velocity profile with height and the degree of atmospheric turbulence. This is accounted for in the meteorological data processing by a parameter called the ‘surface roughness length’.
The surface roughness length within the study area has been calculated based on the land uses (grassland) around the meteorological station within a 1km and a 15km area and calculated within the AERMET meteorological processor.
The presence of elevated terrain can significantly affect (usually increase) ground level concentrations of pollutants emitted from elevated sources such as stacks, by reducing the distance between the plume centre line and ground level and increasing turbulence and, hence, plume mixing. The effect of complex terrain occurs when gradients exceed 1 in 10m (10%). As the study area consists of relatively flat terrain its inclusion within the dispersion modelling is not considered necessary.
7.3.4.5 NO x to NO 2 conversion
A 100% conversion of NO x to NO 2 has been assumed for all averaging periods, in line with the first tier of the ‘EIA Guidance for Coal Fired Power Plant in Pakistan.’ A conversion rate of 100% is a conservative assumption as international methods often assume NO x to NO 2 conversion rates between 35% and 70%.
7.3.4.6 Particulate matter fraction This assessment conservatively assumes that all fly ash, known as total suspended particulates (TSP), and referred to as SPM in Table 24, is in the PM 10 size range (10µm or less). Therefore, the predicted concentration of TSP will be equal to the predicted concentration of PM 10 and assessed against the relevant SEQS. The fraction of fly ash in the PM 2.5 size range (2.5µm or less) is assumed to be 7% 15 .
7.3.4.7 Buildings and Project layout The movement of air over and around buildings generates area of flow circulation, which can lead to increased ground level pollutant concentrations in the building wakes. The buildings likely to have the dominant effect (i.e. with the greatest dimensions likely to promote turbulence) are the boiler houses, the turbine house and the deaerator bay. Table 29 presents the building dimensions assumed within the assessment and Figure 11 provides a visual representation of the building inputs in the dispersion model.
Table 29: Modelled buildings Building Name Height (m) Length (m) Width (m) Angle Turbine House 29 27 136.2 31.5 Deaerator Bay 65 9.5 136.2 31.5 Boiler House 1 69.7 79 44 31.5 Boiler House 2 69.7 79 44 31.5 Note: (a) Angle shows rotation clockwise from a line running north to south
15 Aerosol and Air Quality Research. Hui Li, Guijian Liu, Yan Cao. Content and Distribution of Trace Elements and Polycyclic Aromatic Hydrocarbons in Fly Ash from Coal-Fired CHP Plant.
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Figure 11: Buildings included within the Model
Source: Grid lines show 100m spacing
7.3.4.8 Receptors Within this chapter of the ESIA, the phrase ‘discrete receptor’ has been used to refer to a specific location where the dispersion model has been used to predict pollutant concentrations. Additionally, a ‘receptor grid’ refers to a dispersion modelling concept where pollutant concentrations are predicted over a grid in uniform arrangement. The discrete receptors allow air quality impacts to be assessed at identified existing receptor locations. The receptor grid aids the assessment of pollutant concentrations over a wide spatial area and, by interpolating between these points, allows the production of pollutant contours which illustrate how pollutant concentrations change across the study area.
In order to assess potential impacts on sensitive receptors, modelling was carried to predict pollutant concentrations across a study area with a 15km radius grid. This involved modelling a 30 x 30km grid of receptors with a receptor spacing of 300m and a 10 x 10km grid with a receptor spacing of 100m and assumed receptor heights of 1.5m.
Outputs from the modelled grids have been used to present ground level ambient pollutant concentrations from the Project, referred to as ‘process contributions’. These process contributions have been added to ‘ambient concentrations’ to report the ‘predicted environmental concentrations’.
Discrete receptors have also been modelled at locations presented in Table 30 and Figure 12 overleaf. The discrete receptors are consistent with those assessed as part of this ESIA in chapter 15.
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Table 30: Discrete receptor locations Receptor Name X Y Yusuf Ji Dhani 633578 2749593 Gangu Bhil Ji Dhani 634138 2750416 Salar Ji Dhani 634072 2751040 Jadhe Dhani 637355 2751057 Murad Dhani 638414 2752053 Mithe Ji Wand 639278 2750936 Saleh Jhanihi 642047 2749736 Bakhato Dhani 641074 2748568 Bhitro Bhill 639694 2746701 Munhan Tar 631591 2751384 Mehun Linju 629679 2750931 Mangu Bheel 626928 2747726 Ramnia Bhil 624034 2748818 Singharo 633485 2742931 Bhilan Jo Goth 633570 2741761 Aban Jo Tar 637604 2743050 Achie Ji Dhani 637929 2753663 Mangho Thakar Jo Tar 633727 2753887 Note: Coordinate System: Universal Transverse Mercator (UTM) WGS1984 Zone 42N
Receptor height is 1.5m above ground level
Figure 12: Discrete receptor locations
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7.3.5 Impact assessment criteria
7.3.5.1 Construction impacts The methodology for determining impact significance from dust is presented in Figure 13.
Figure 13: Methodology for determining the impact significance of dust
Note: [1] According to Table 32 [2] According to Table 31 [3] According to significance criteria adopted for this assessment, presented in chapter 5 of this ESIA.
A combination of dust emission potential from on-site activities (Table 31) and their expected duration has been used to determine the impact magnitude of construction and decommissioning phases (Table 32).
Table 31: Determination of impact magnitude – construction phase Dust Raising Potential (a) Duration Magnitude High Any Major Medium > 3 Months Moderate Medium < 3 Months Minor Low Any Negligible Notes: (a) Dust raising potential defined in accordance with the approach described in Section 7.3.3
In addition, receptor sensitivity has been based on the type of receptor and the distance from the construction or decommission activity boundary. Table 32 overleaf presents the criteria on which receptor sensitivity has been based.
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Table 32: Determination of receptor sensitivity – construction phase Receptor Classification (a) Distance to Activities 0-50m 50-100m 100-200m 200-500m High High High Medium Low Medium Medium Medium Low Low Low Medium Low Low Negligible Negligible/No Receptors Negligible Negligible Negligible Negligible Notes: (a) Receptors classified based on method described in Table 26
7.3.5.2 Operational impacts Guidance has been issued in the UK 16 to assist in determining the significance of operational phase impacts in air quality assessments. This guidance recommends that significance should be determined by a combination of two aspects:
● Change in concentrations (Process Contribution (PC) caused by the Project at sensitive receptors ● Resulting total concentrations (Predicted Environmental Concentrations (PEC)) at sensitive receptors as a percentage of the relevant ambient air quality standard(s) This approach is considered to represent best practice for assessments of this kind and has therefore been adopted in determining the significance of impacts on local air quality from the Project.
Changes in ambient concentrations over 25% of the relevant standards are considered to represent an impact of ‘major’ magnitude as the General EHS Guidelines note that projects should:
‘…prevent or minimize impacts by ensuring that …emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards. As a general rule, this guideline suggests 25 percent of the applicable air quality standards to allow additional future sustainable development in the same airshed.’ (IFC EHS Guidelines).
The IFC General EHS Guidelines classify ‘poor quality airsheds’ as those where relevant standards are exceeded significantly. Therefore, receptors experiencing existing ambient pollutant concentrations above the relevant standards are concluded to be of ‘High’ sensitivity.
For each of the key pollutants and averaging periods assessed, a number of ambient air quality standards are applicable.
Impact magnitude and receptor sensitivity criteria are presented in Table 33 and Table 34.
Table 33: Determination of impact magnitude– operational phase Change in concentrations as % of standard Magnitude Increase >25% Major Increase 15-25% Moderate Increase 5-15% Minor Increase <5% Negligible
16 Air emissions risk assessment for your environmental permit’ (2016), UK Environment Agency and Department for Environment, Food and Rural Affairs
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Table 34: Determination of receptor sensitivity – operational phase Baseline pollutant concentrations in relation to standard Receptor sensitivity Above standard High 75 to 100% of the standard Medium 50 to 75% of the standard Low Below 50% of the standard Negligible
7.3.5.3 Significance Based on the methods defined above for determining the magnitude of impact and sensitivity of receptors, the significance matrix specified in chapter 5 has been applied to determine overall significance.
Notwithstanding the above, any non-negligible increases causing a new exceedance of the relevant standards are considered of ‘major’ adverse significance. All impact descriptors described as ‘moderate’ or ‘major’ are considered to be significant.
7.4 Baseline description
7.4.1 Overview There is no long term air quality monitoring data within the Sindh province suitable for comparison with applicable legislative ambient air quality limits. However, SGS Pakistan (Pvt) Limited were commissioned to undertake an air quality monitoring study. The air quality monitoring data collected has been presented below along with a location map of the monitoring sites. The location map shows that site 1 was located downwind of the Project, whilst sites 2 and 3 were located upwind. The overall outcomes of the monitoring have been presented in this section.
7.4.2 Monitoring results The ambient air quality monitoring was performed on an hourly basis for a period of 24 hours at each monitoring site. Average values were calculated for each monitored pollutant at each monitoring site and the ambient air quality monitoring results are presented in Table 35 and Figure 14. The monitoring data show that average values of NO 2, SO 2 and CO and Lead (Pb) are well below the SEQS limits. Ozone (O 3) was not detected or remained below detection limit at all monitoring sites. The most significant air pollutants in the area were found to be TSP and PM 10 , which exceeded the SEQS. These higher concentrations are likely to be due to the natural soil and meteorological conditions of the Tharparkar area.
As the monitoring covered a relatively short period it is possible that the worst case 1 hour and 24 hour concentrations may have been missed. To overcome this, the ambient concentrations presented in Table 35 are assumed to be representative of annual ambient concentrations and in accordance with best practice methods have been doubled for short term averaging periods (less than 24 hours), for comparison with the short term SEQS.
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Table 35: Overall results of ambient air quality
Monitoring Location NO SO CO Pb TS PM 10 PM 2.5 O3 2 2 P 1 0.4 4.6 4500 ND 345 121 38 ND 2 0.3 6.6 2200 ND 467 297 48.1 ND 3 0.3 5.7 3700 ND 421 231 40.2 ND Average 0.3 5.6 3466.7 ND 411 216.3 24.1 ND Annual SEQS Limit 40 80 5000 1 360 40 - 80 24 Hour SEQS Limit (a) 80 120 10000 1.5 500 150 75 13 0 Units: µg/m 3
ND = not detected or below detection limits
Bold text indicated SEQS value is exceeded
(a) O3 SEQS limit is for a 1 hour averaging period
Figure 14: Air quality monitoring locations
7.5 Impact identification and assessment
7.5.1 Construction impacts As described in Section 7.3.3, consideration has been given to receptors within 500m of the Project or associated access roads. Table 36 presents receptors within these criteria and their associated sensitivity in accordance with Table 26.
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Table 36: Receptor sensitivity Construction activity Receptor type Distance from Receptor source sensitivity Access road (new and Residential 100-200m Low existing) Place of worship 100-200m Low School 100-200m Low Project Site Animal grazing 0-50m Negligible
Although no detailed construction methodology is available at present and therefore the construction assessment has been based on generic activities. The construction period is expected to commence in Q2 2017 and last for 40 months and will consist of major construction works including site clearance and considerable earthworks at the start of construction. Table 37 presents the dust raising potential of the assumed activities associated with construction of the Project whilst Table 38 presents the overall impact significance. Figure 15 presents the locations of the Project, the access road, and sensitive receptors.
Table 37: Construction activities and dust emitting activities during construction Section Description of Key activities Dust raising Duration Impact works potential at any magnitude one point Site preparation, Excavation and Earthmoving High (assumes >3 months Major clearance and moving material Excavation undertaken in groundworks Wind dry seasons)
Roads and Ancillary works and Minor excavation works. Medium > 3 months Moderate infrastructure delivery of materials to Transport of materials. site, removal of wastes Re-suspension of dust on from site unsurfaced roads. Construction of Assembly of the main Storage of materials Medium > 3 months Moderate plant components of the Preparation of materials plant (cutting) Re-suspension of dust on unsurfaced roads Landscaping Landscaping Earthmoving High (assumes < 3 months Major requirements Excavation undertaken in summer months) Transport of materials Wind Re-suspension of dust on unsurfaced roads
Table 38: Impact significance Section Worst case receptor Worst case impact Impact sensitivity magnitude significance Roads and infrastructure Low Moderate Minor All activities at Project site Negligible Major Minor
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Figure 15: Construction Dust Receptor Locations
In accordance with the significance criteria adopted for this assessment, the risk of construction dust impacts associated with the Project is minor adverse and therefore not considered significant. It should be noted that fugitive dust arising from natural lift and transport of particulate matter is a common phenomenon due to the nature of the ground and the climate in Sindh and the Tharparkar area.
In the event of decommissioning of the Project, it is likely that any potential air quality impacts would be similar to those in the construction phase, as broadly similar activities would be required. Similar to the construction phase, these impacts are considered to be minor adverse and therefore not significant.
There is some uncertainty related to the presence of receptors in the future, which, depending on the time of decommissioning, may have been introduced or removed from the study area. Therefore, at the time of decommissioning, the management plan should take due care to ensure that all receptors at that time are accounted for and that the management plan adequately minimises potential issues for receptors that could be affected.
7.5.2 Operation impacts
7.5.2.1 Emissions from coal storage and handling The proposed storage and handling of the coal would be potential sources of particulate emissions during operation:
● Coal will be transported to the power plant by a covered belt conveyor – Releases at the loading and delivery ends of the conveyor ● Storage of coal at the stockpile ● Wind erosion of pile (particularly during hot, dry conditions)
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● Plant activity around the stockpile during maintenance Particulate emissions from coal storage and handling comprise of small particles (PM10) which can have negative health effects and larger particles (referred to as ‘dust’) which can cause nuisance or a loss of amenity.
The potential for emissions of fugitive dust and PM10 from the coal storage and handling facilities is high due to wind erosion of the stockpile during hot, dry conditions and plant activity around the stockpile during maintenance and therefore is described as ‘major’.
Based on the proposed plot plan there is animal grazing land within 50m of the Project site. In accordance with the construction dust assessment these receptors are described as being ‘negligible’ in sensitivity.
In accordance with the significance criteria adopted for this assessment, the risk of operation phase dust impacts associated with the Project is minor adverse and therefore not significant.
Operation phase activities will be controlled by best practice mitigation techniques to reduce any potential impacts on grazing land to negligible and therefore not significant.
7.5.2.2 Emissions from the stack The following section presents the maximum predicted ground level concentrations as a result of emissions from the Project and provides an assessment of their significance against the SEQS.
Scenario 1 – 100% boiler load Table 39 and Table 40 present the maximum ground level concentrations predicted within the modelled grids and at discrete receptors for Scenario 1.
Table 39 shows that the impact magnitude of process contributions of NO 2 and SO 2 for the 24 hour 98 th percentile and annual averaging periods are ‘minor’. The existing ambient concentrations of these pollutants are well below the SEQS and therefore the receptor sensitivity is ‘negligible’. In accordance with the assessment approach the impact descriptor is described as ‘negligible’ and therefore not significant.
Predicted process contributions of TSP, PM 10 and PM 2.5 from the Project are ‘negligible’. As discussed in Section 7.4, the ambient concentration of these pollutants is relatively high, due to natural soil and meteorological conditions in the Tharparkar area. Therefore, the receptor sensitivity is classed as ‘high’ for TSP and PM 10 and ‘low’ for PM 2.5 . Overall, the impact descriptor for TSP, PM 10 and PM 2.5 is described as ‘negligible’ as a result of the low process contribution from the Project and therefore described as not significant.
The SEQS requires that 24 hourly ambient standards should be met 98% of the year. For the other 2% of the year, the relevant 24 hour ambient standard may be exceeded but not on two consecutive days.
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Table 41 lists the dates during which the seven maximum 24 hour concentrations (corresponding to the 24 hour 98 th percentile) were predicted and demonstrates that worst case meteorological conditions occurred sporadically throughout the year.
Table 39 shows that the predicted maximum 24 hour concentrations are below the relevant SEQS for NO 2, SO 2 and PM 2.5 ; therefore there are no predicted consecutive days where the pollutants exceed the 24 hourly SEQS.
Table 41 shows that for the worst case model year of 2010, the model predicts two consecutive days where the predicted concentration is greater than the 24 hour 98 th percentile (which is equivalent to the seventh highest predicted concentration). As discussed above, the ambient concentration of TSP and PM 10 are greater than the SEQS, which is likely due to the natural soil and meteorological conditions in the Tharparkar area. The process contributions of these pollutants is negligible and consecutive days of exceedence of the 24 hour SEQS are likely caused by the natural environment in Tharparkar and not by the Project.
According to the significance criteria adopted for this assessment, the impacts associated with Scenario 1 are not significant.
Figure 16 to Figure 21 present the results from the dispersion modelling assessment as contour plots. Contours plots of PM 2.5 have not been presented due to low process contributions. The contour plots show that process contributions reach ground level approximately 3km north east of the Project site and that the prevailing south westerly winds strongly influence dispersion patterns, as presented in Figure 10. The prevailing wind causes the area of impact to be narrow and mainly confined to the north east corner of the study area.
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Table 39: Scenario 1 – Comparison with legislated Pakistan SEQS (µg/m 3) Pollutant Averaging Max PC as a Impact AC PEC PEC SEQS Receptor Impact Significance period PC % of magnitude as a % sensitivity descriptor SEQS of SEQS
NO 2 24 hr Max 11.9 14.9 Minor 0.8 12.7 15.9 80 Negligible Negligible Not Significant 24hr 98th %ile 9.4 11.8 Minor 0.8 10.2 12.8 80 Negligible Negligible Not Significant Annual mean 3.9 9.6 Minor 0.4 4.3 10.6 40 Negligible Negligible Not Significant
SO 2 24 hr Max 21.3 17.8 Moderate 11.2 32.5 27.1 120 Negligible Negligible Not Significant 24hr 98th %ile 16.9 14.1 Minor 11.2 28.1 23.4 120 Negligible Negligible Not Significant Annual mean 6.9 8.6 Minor 5.6 12.5 15.6 80 Negligible Negligible Not Significant TSP 24 hr Max 1.7 0.3 Negligible 822.0 823.7 164.7 500 High Negligible Not Significant 24hr 98th %ile 1.4 0.3 Negligible 822.0 823.4 164.7 500 High Negligible Not Significant Annual mean 0.6 0.2 Negligible 411.0 411.6 114.3 360 High Negligible Not Significant
PM 10 24 hr Max 1.7 1.1 Negligible 432.6 434.3 289.5 150 High Negligible Not Significant 24hr 98th %ile 1.4 0.9 Negligible 432.6 434.0 289.3 150 High Negligible Not Significant Annual mean 0.6 0.5 Negligible 216.3 216.9 180.7 120 High Negligible Not Significant
PM 2.5 24 hr max 0.1 0.2 Negligible 48.2 48.3 64.4 75 Low Negligible Not Significant 24hr 98th %ile 0.1 0.1 Negligible 48.2 48.3 64.4 75 Low Negligible Not Significant Note: PC – Process contribution, SEQS – Government of Sindh’s Environmental Quality Standards , AC – Ambient concentration, PEC – Predicted environmental concentration. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m 3. Bold indicates exceedance of Pakistan SEQS
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Table 40: Scenario 1 – Maximum modelled process contributions at discrete receptors (µg/m 3)
Receptor NO 2 SO 2 TSP PM 10 PM 2.5 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Ranjho Noon 2.7 0.4 4.8 0.7 0.4 0.1 0.4 0.1 0.0 Yusuf Ji Dhani 1.6 0.2 2.9 0.3 0.2 0.0 0.2 0.0 0.2 Gangu Bhil Ji Dhani 1.7 0.2 3.1 0.3 0.2 0.0 0.2 0.0 0.2 Salar Ji Dhani 1.8 0.2 3.2 0.4 0.3 0.0 0.3 0.0 0.3 Jadhe Dhani 8.3 3.5 14.9 6.2 1.2 0.5 1.2 0.5 1.2 Murad Dhani 7.8 3.1 14.0 5.6 1.1 0.4 1.1 0.4 1.1 Mithe Ji Wand 4.0 1.2 7.1 2.2 0.6 0.2 0.6 0.2 0.6 Saleh Jhanihi 3.4 0.5 6.1 0.9 0.5 0.1 0.5 0.1 0.5 Bakhato Dhani 3.3 0.5 6.0 0.8 0.5 0.1 0.5 0.1 0.5 Bhitro Bhill 1.0 0.2 1.7 0.3 0.1 0.0 0.1 0.0 0.1 Munhan Tar 1.2 0.2 2.1 0.3 0.2 0.0 0.2 0.0 0.2 Mehun Linju 0.8 0.1 1.5 0.2 0.1 0.0 0.1 0.0 0.1 Mangu Bheel 0.6 0.1 1.1 0.2 0.1 0.0 0.1 0.0 0.1 Ramnia Bhil 0.5 0.1 0.9 0.2 0.1 0.0 0.1 0.0 0.1 Singharo 4.5 0.6 8.0 1.1 0.6 0.1 0.6 0.1 0.6 Bhilan Jo Goth 3.2 0.5 5.7 0.9 0.5 0.1 0.5 0.1 0.5 Aban Jo Tar 0.8 0.1 1.4 0.2 0.1 0.0 0.1 0.0 0.1 Achie Ji Dhani 3.3 1.1 5.9 2.0 0.5 0.2 0.5 0.2 0.5 Mangho Thakar Jo Tar 1.1 0.1 1.9 0.3 0.2 0.0 0.2 0.0 0.2 Pakistan SEQS 80 40 120 80 500 360 150 40 75 Note: Pakistan SEQS – Government of Sindh’s Environmental Quality Standards. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m3.
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Table 41: Scenario 1 - Worst Case 24 Hour Meteorological Conditions Rank 2009 2010 2011 2012 2013 1 20 March (a) 20 May 12 June 05 March(a) 31 May 2 12 May 21 June 21 August 05 March(a) 08 June 3 21 June 03 May (a) 08 June(a) 07 June 16 May 4 07 July 03 May (a) 08 June(a) 28 April 18 May 5 20 March(a) 02 May 19 June(a) 06 August(a) 24 June 6 06 September(a) 22 May 19 June(a) 06 August(a) 14 May 7 06 September(a) 19 July 16 May 16 August 11 May Note: (a) Where dates occur twice the worst case result is occurring on the same day over multiple receptors. Bold text indicates consecutive days.
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Figure 16: Scenario 1 - Maximum modelled 24hr NO2 process contribution (98th %ile) (µg/m3)
Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2011 Met year data, contour lines at increments of 2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North
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Figure 17: Scenario 1 - Maximum modelled 24hr SO2 process contribution (98th %ile) (µg/m3)
Note: Project boundary highlighted in purple. Block VI outlined in red Contour based on 2011 meteorological year data, contour lines at increments of 2.5µg/m3. Coordinate system: UTM WGS1984 Zone 42 North
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Figure 18: Scenario 1 - Maximum modelled annual mean SO2 process contribution (µg/m3)
Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2012 meteorological year data, contour lines at increments of 2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North
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Figure 19: Scenario 1 - Maximum modelled 24hr TSP and PM10 process contribution (98th %ile) (µg/m3)
Note: Project boundary highlighted in purple. Block VI outlined in red Contour based on 2011 meteorological year data, contour lines at increments of 0.2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North
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Figure 20: Scenario 1 - Maximum modelled annual mean TSP and PM10 process contribution (µg/m3)
Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2012 meteorological year data, contour lines at increments of 0.1 µg/m3. Coordinate system: UTM WGS1984 Zone 42 North
Scenario 2 – 45% boiler load Table 42 and Table 43 present the maximum ground level concentrations predicted within the modelled grids and at discrete receptors for Scenario 2. Predicted impacts from Scenario 2 are ‘negligible’. The results show that the predicted impacts from Scenario 2 are ‘negligible’ and process contributions from Scenario 2 are lower than those predicted from Scenario 1.
According to the significance criteria adopted for this assessment, the impacts associated with Scenario 2 are not significant.
Dispersion patterns associated with Scenario 2 are similar to Scenario 1. However, impacts are predicted to be even less wide spread than Scenario 1 due to lower emission rates when operating at low load.
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Table 42: Scenario 2 – Comparison with legislated Pakistan SEQS (µg/m 3) Pollutant Averaging Max PC PC as a Impact magnitude AC PEC PEC as a % of SEQS Receptor Impact Significance period % of SEQS sensitivity descriptor SEQS
NO 2 24 hr Max 8.4 10.5 Minor 0.8 9.2 11.5 80 Negligible Negligible Not Significant 24hr 98th 6.3 7.9 Minor 0.8 7.1 8.9 80 Negligible Negligible Not Significant %ile Annual mean 2.8 6.9 Minor 0.4 3.2 7.9 40 Negligible Negligible Not Significant
SO 2 24 hr Max 14.9 12.4 Minor 11.2 26.1 21.8 120 Negligible Negligible Not Significant 24hr 98th 11.3 9.4 Minor 11.2 22.5 18.7 120 Negligible Negligible Not Significant %ile Annual mean 5.0 6.2 Minor 5.6 10.6 13.2 80 Negligible Negligible Not Significant TSP 24 hr Max 1.2 0.2 Negligible 822. 823. 164.6 500 High Negligible Not Significant 0 2 24hr 98th 0.9 0.2 Negligible 822. 822. 164.6 500 High Negligible Not Significant %ile 0 9 Annual mean 0.4 0.1 Negligible 411. 411. 114.3 360 High Negligible Not Significant 0 4
PM 10 24 hr Max 1.2 0.8 Negligible 432. 433. 289.2 150 High Negligible Not Significant 6 8 24hr 98th 0.9 0.6 Negligible 432. 433. 289.0 150 High Negligible Not Significant %ile 6 5 Annual mean 0.4 0.3 Negligible 216. 216. 180.6 120 High Negligible Not Significant 3 7
PM 2.5 24 hr max 0.1 0.2 Negligible 48.2 48.3 138.0 35 High Negligible Not Significant 24hr 98th 0.1 0.2 Negligible 48.2 48.3 137.9 35 High Negligible Not Significant %ile Note: PC – Process contribution, SEQS – Government of Sindh’s Environmental Quality Standards, AC – Ambient concentration, PEC – Predicted environmental concentration. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m 3. Bold indicates exceedance of Pakistan SEQS
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Table 43: Scenario 2 – Maximum modelled process contributions at discrete receptors (µg/m 3)
Receptor NO 2 SO 2 TSP PM 10 PM 2.5 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Ranjho Noon 1.9 0.2 3.5 0.4 0.3 0.0 0.3 0.0 0.0 Yusuf Ji Dhani 1.2 0.1 2.1 0.2 0.2 0.0 0.2 0.0 0.0 Gangu Bhil Ji Dhani 1.2 0.1 2.1 0.3 0.2 0.0 0.2 0.0 0.0 Salar Ji Dhani 1.0 0.1 1.8 0.2 0.1 0.0 0.1 0.0 0.0 Jadhe Dhani 6.1 2.6 10.8 4.6 0.9 0.4 0.9 0.4 0.1 Murad Dhani 5.2 2.1 9.3 3.8 0.7 0.3 0.7 0.3 0.1 Mithe Ji Wand 2.5 0.8 4.5 1.5 0.4 0.1 0.4 0.1 0.0 Saleh Jhanihi 2.2 0.4 3.9 0.6 0.3 0.1 0.3 0.1 0.0 Bakhato Dhani 2.3 0.3 4.1 0.6 0.3 0.0 0.3 0.0 0.0 Bhitro Bhill 0.6 0.1 1.0 0.2 0.1 0.0 0.1 0.0 0.0 Munhan Tar 0.8 0.1 1.3 0.2 0.1 0.0 0.1 0.0 0.0 Mehun Linju 0.5 0.1 0.9 0.1 0.1 0.0 0.1 0.0 0.0 Mangu Bheel 0.4 0.1 0.7 0.1 0.1 0.0 0.1 0.0 0.0 Ramnia Bhil 0.3 0.1 0.5 0.1 0.0 0.0 0.0 0.0 0.0 Singharo 2.7 0.4 4.8 0.7 0.4 0.1 0.4 0.1 0.0 Bhilan Jo Goth 2.0 0.3 3.5 0.6 0.3 0.0 0.3 0.0 0.0 Aban Jo Tar 0.5 0.1 0.8 0.1 0.1 0.0 0.1 0.0 0.0 Achie Ji Dhani 2.2 0.7 3.9 1.3 0.3 0.1 0.3 0.1 0.0 Mangho Thakar Jo Tar 0.6 0.1 1.2 0.2 0.1 0.0 0.1 0.0 0.0 Pakistan SEQS 80 40 120 80 500 360 150 40 75 Note: Pakistan SEQS – Government of Sindh Environmental Quality Standards. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m 3
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Table 44: Scenario 2 - Worst case 24 Hour meteorological conditions Rank 2009 2010 2011 2012 2013 1 13 June 20 May 21 August 07 June (a) 31 May 2 12 May 21 June 12 June 04 August 19 June 3 07 July 22 May 28 April 05 March 08 June 4 21 June (a) 03 May 08 June 07 June (a) 16 May (a) 5 21 June (a) 02 May 07 July 05 July 24 June 6 13 July (a) 19 July (a) 19 June 11 June 16 May (a) 7 13 July (a) 19 July (a) 19 July 19 August 14 May Note: (a) Where dates occur twice the worst case result is occurring on the same day over multiple receptors. Bold text indicates consecutive days
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7.5.2.3 Transboundary impacts The Project is located approximately 60km east of the Pakistan and India border. As noted in section 7.5.2, the largest predicted impacts from the Project occur approximately 3km north east of the Project site. As demonstrated by the contours plots, presented in Figure 16 to Figure 21, the process contributions from the Project drop off rapidly with increasing distance from the area of maximum impact. Over 60km, it is expected the emissions from the Project will be well mixed in the atmosphere and are likely to be undetectable at the border with India beyond the current ambient concentration. Therefore, there are no anticipated transboundary effects due to the location of the Project in relation to other countries.
7.6 Mitigation and enhancement measures
7.6.1 Construction impacts The following mitigation measures (which are in accordance with international best practice) for controlling air quality impacts will be incorporated into the construction phase:
● Minimising dust from material handling sources, such as conveyors and bins, by using covers; ● Minimising dust from open sources, including storage piles, by using control measures such as appropriate locations, installing enclosures and covers ● Dust suppression techniques should be implemented, such as applying water or non-toxic chemicals to minimise dust from vehicle movements ● Manage emissions from mobile sources as per the EHS Guidelines for Air Emissions and Ambient Air Quality including: – Contractors are required to use modern, well-maintained vehicles that comply with applicable emission limits – Introduce and enforce a ‘no idling’ policy – Regardless of the size or type of vehicle, fleet owners / operators should implement the manufacturer recommended engine maintenance programs – Drivers should stick to demarcated and levelled construction routes – Minimise speeds on site to <20kph – Drivers should be instructed on the benefits of driving practices that reduce both the risk of accidents and fuel consumption, including measured acceleration and driving within safe speed limits ● No open burning of solid waste ● Planning land clearing, removal of topsoil and excess materials, location of haul roads, tips and stockpiles, and blasting with due consideration to meteorological factors (e.g. precipitation, temperature, wind direction, and speed) and location of sensitive receptors. For example, – minimise groundworks during periods of high wind (e.g. >20kph) – vegetating exposed surfaces of stockpiled materials ● Ensure grievance mechanism is in place so if air issues such as dust occur, communities can report them to the Project Company
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7.6.2 Operation impacts In order to minimise dust and particulate matter from the handling and storage of coal the following measures should be applied:
● Use of cleaning devices for conveyor belts to minimise the generation of fugitive dust ● Use of enclosed conveyors with well designed, robust extraction and filtration equipment on conveyor transfer points to prevent emission of dust ● Use of wind fences in open storage of coal or profiling ● Use of machinery to compact coal in the coal yard ● Frequent utilisation of (treated) waste water to suppress coal dust on coal yard No combustion mitigation measures in addition to those already accounted for within the dispersion modelling are proposed. The following key design features have been accounted for:
● Abatement methods included to enable the Project to meet the guaranteed emission limits, which are lower than the SEQS emission limits presented in Table 21, include:
– Low NO x burners and staged air injection – Limestone injection into the combustion chamber for desulphurisation – Electrostatic precipitators with particulate removal efficiency not less than 99.85% ● An exhaust stack height of 210m to ensure effective dispersion of emissions. Monitoring of emissions and ambient air quality should be undertaken during the operation phase using the following methods:
● Installation of a continuous emission monitoring system (CEMS) to monitor stack emissions of PM 10 , SO x and NO x ● Annual stack emissions testing of the metals regulated by the SEQS ● Ambient monitoring of pollutants consistent with the SEQS, using a minimum of two continuous ambient monitoring systems to measure concentrations at a maximum impact/sensitive receptor location and a representative background location.
7.7 Residual impacts According to the significance criteria adopted for this assessment, the impacts associated with construction activities are not significant.
As a result of the Project’s operation, there will be increases in ground level concentrations of NO 2, SO 2 and PM although these changes are small at modelled sensitive receptors. The impacts from the Project are not significant when assessed against the relevant Pakistan SEQS.
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8 Greenhouse gas
8.1 Introduction This chapter considers the potential greenhouse gases (GHG) associated with the construction and operation of the Project. The key source of GHG emissions is from combustion of fuel. Combustion GHG emissions are calculated as well as the emissions intensity (emissions of CO 2 per unit of heat and electricity).
8.2 Applicable legislation The Kyoto Protocol was ratified by Pakistan in 2005, which recognised the general commitments of the Protocol. However, as a developing county, Pakistan was not given any binding emissions targets.
Pakistan’s National Climate Change Policy 17 was drafted in 2011 and adopted in 2013, in response to Pakistan’s increasing vulnerability to adverse effects of climate change. Its goal was to “to ensure that climate change is mainstreamed in the economically and socially vulnerable sectors of the economy and to steer Pakistan towards climate-resilient development”.
The Framework for Implementation of Climate Change Policy 18 was developed later in 2013 and addresses the main sectors contributing to Pakistan’s economy. The energy sector is identified as contributing over half (51%) to Pakistan’s overall GHG emissions. Actions are focused on:
● Developing renewable energy technologies ● Developing/obtaining clean coal technologies to achieve low carbon growth ● Reducing overall energy demand. The Prime Minister’s Committee on Climate Change (PMCCC) is an overarching body that oversees climate change related issues both globally and domestically and provides climate change guidance.
Pakistan last provided data to the United Nations Framework Convention on Climate Change (UNFCC) for a national carbon assessment in 1994; however, it has produced updates to its GHG emissions data, most recently in 2012.
8.3 Guidelines and policies Pakistan published an EIA guidance for coal fired power stations – National Impact Assessment Programme (NIAP) which outlines how to assess GHG emissions for EIA purposes. The guidance suggests that the EIA should determine whether the Project may significantly change GHG emissions, and define the scope of any necessary GHG assessment. The key areas that should be addressed are whether the proposed Project will emit GHGs, and to assess the relevant emissions.
The NIAP refers to the World Banks’ Strategic Framework for Development and Climate Change, which outlines the criteria that a coal power plant should meet to obtain traditional financing from the IFC and Multilateral Investment Guarantee Agency (MIGA) for example.
17 http://www.lead.org.pk/cc/attachments/Resource_Center/NAP/pakistan.pdf 18 http://www.pk.undp.org/content/dam/pakistan/docs/Environment%20&%20Climate%20Change/Framework%20for%20Implementation% 20of%20CC%20Policy.pdf
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IFC EHS guidelines for Thermal Power Plants state that energy efficiency measures should be in place to maximise energy output from fossil fuels, were new plant should aim to be in the top- quartile of performance for the country or region for the same type of fuel and power plant size. However, the guidance also notes that local circumstances must be considered in determining the appropriate technology choice. This analysis is presented in chapter 3 of this ESIA.
The guidelines also present typical emissions rates for new thermal power planta. Typical values for a lignite CFB plant are <909 gCO 2e/kWh. Note these values do not account for differences in coal specifications across the world but provide indicative performance levels.
8.4 Methodology and assessment criteria
8.4.1 Overview This section details the methodology used for quantifying emissions associated with the operational phase of the Project. The methods adopted are consistent with the guidance set out in section 8.3 for this type of project.
8.4.2 Temporal Scope GHG emissions have been considered for a typical one-year operational period of 7,000 hours. This is based on the projected annual fuel consumption and energy production of the plant.
8.4.3 Spatial Scope The assessment identifies the major potential sources of GHG emissions as a result of the operation and construction of the plant. These are presented in Table 45.
Table 45: Potential sources of GHG emissions associated with the Project Emission source Type of Emission Quantified in assessment? Construction Combustion plant Indirect – Scope 3 Yes Transmission line Indirect – Scope 3 Yes Operation Two main boilers Direct - combustion - Scope 1 Yes Transport of fuel to site Indirect – Scope 3 No Switchgear Direct - Fugitive - Scope 1 No
Emissions associated with the construction of this type of project are insignificant compared to those released from operation over the life of the Project. Additionally, data from construction sources was not available at the time of this study so an indicative calculation of these 19 emissions is undertaken using a default value from the World Bank of 2.9 kgCO 2e/MWh .
The main source of direct GHG emissions is the combustion of fuel in the boilers which is mostly CO 2 (30%). A small amount of N 2O is also emitted. Emissions have been calculated based on the fuel combusted, and presented as net emission rates based on the electricity produced after the plant’s own consumption is accounted for.
There will be some losses of electricity through the transmissions system. This means that of the total amount of electricity generated, some of it will not be consumed by customers and is a function of how the transmission systems operate. Any emissions associated with these losses
19 http://documents.worldbank.org/curated/en/269221468178766476/pdf/903670WP0Box380HGGuidanceNoteEnergy.pdf
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have not been considered separately in this assessment and the data reflects ‘as generated’ values.
GHG emissions from fugitive emissions of sulphur hexafluoride (SF 6) insulated switchgear during normal operation are expected to be insignificant compared to the other sources of GHG associated with the Project and have therefore not been considered further in this assessment.
The coal will be delivered from the mine stockpile to the site by conveyor belts, which will be owned and operated by the Developer.
8.4.4 Calculation approach For each of the sources above which are to be calculated, the activity or consumption data was multiplied by a published emissions factor from a recognised source:
Emissions (tCO 2e) = rate of activity (unit) x emission factor (tCO2e/unit)
For each source the activity data and emissions factor are selected on the best available Project data and emissions factors.
Direct emissions from the combustion of coal have been calculated based on the estimated fuel consumption and the coal specification of the plant. The specification expected to be used for the Project estimates the carbon content of the coal (through ultimate analysis) to be 30.12% (as received).
The total coal consumed in a given scenario is multiplied by the carbon content on the conservative assumption that all carbon is consumed in the combustion process and that this consumption is at the lower heating value. It is assumed the plant operates for 7,000 hours per year.
8.4.5 Project data Activity data for the power station has been taken from a number of sources. Table 46 outlines the activity data for the Project and the source of that data.
Table 46: Project activity data- combustion Parameter Unit Output Number of units Number 2 Total electrical output MW 660 Net calorific value (LHV) kJ/kg 10,232 Net Heat Rate (LHV) kJ/kWh 8,705 Fuel carbon content % 30.1 Net power output- total GWh/y 4,300 Note: Carbon content based on Project performance coal specification
Source: Performance coal specification Project Mass Balance calculation
8.4.6 Determining significance It is good practice in an ESIA to assess the significance of impacts with reference to the magnitude of the impact and the sensitivity of the receptor. GHG emissions are global in nature and it is difficult to link the emissions of a single project to a specific receptor, unlike other environmental impacts. In addition, GHG emissions are closely related to economic growth. In international agreements, such as the UNFCC and the Kyoto Protocol, developing countries are
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given scope to increase their emissions. This is unlike developed countries which have high levels of emissions already and which are expected to reduce their emissions.
The relationship of individual project emissions to global atmospheric emission, and uncertainty about the global atmospheric response, is very complex and means that determining the significance of project emissions on a local scale is not possible. The relationship between emissions from individual projects and national or international emissions reduction targets is also difficult to resolve as national and international policies contain provisions for growth and development.
There are currently no published guidelines for determining the significance of project greenhouse gas emissions in ESIAs. However, the guidance notes for the IFC PS3 suggest the following criteria for evaluating project GHG emissions. This guidance does not recommend how to assign significance to any of the impacts associated with a project, instead recommending how to present the impacts. As such the methodology given in chapter 5 of this ESIA does not apply to this GHG assessment.
Table 47: Suggested IFC criteria for assessing GHG emission impacts IFC Criteria Comments The project’s greenhouse gas emissions relative to the host Discussed in the Residual Impacts Section country’s total national emissions (Section 8.8) The project’s greenhouse gas emissions performance relative Discussed in the National Emissions Profile to good international performance or the host country’s (Section 8.5.1) national average performance The annual trend of the project’s greenhouse gas emissions Discussed in the Impact Identification and performance over time Assessment (Section 8.6) Opportunities to further improve the project’s greenhouse gas Discussed in the Mitigation and Enhancement emissions performance. Measures section (section 8.7) Source: Guidance Notes for IFC PS3
8.4.7 Baseline conditions methodology Baseline data was collected via a desk review. The following principal sources were considered in presenting the baseline assessment:
● World Resources Institute (WRI) – CAIT emissions data 20
8.4.8 Assumptions and limitations Wherever possible, Project specific data has been used in order to inform the assessment and calculations.
Actual data on construction of the Project was not available at the time of this study, so an assumption has been used based on the World Bank average for construction of power plants. This is calculated based on the MWh generated over the Project lifetime of 30 years.
The combustion calculations were based on Project data for the heat and energy balances of the plant, which document the fuel inputs and electricity generated. The coal specification for the Project has also been used to calculate the GHG emissions per unit of coal consumed. This is the coal that will typically be consumed at the site. It is stated in the Project Technical Description that the plant would operate for 7,000 hours per year. Emissions are calculated based on all of these sources of data and assumptions.
20 http://cait.wri.org/historical
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The actual emissions from the plant during operation would be based on how the plant ultimately operates. There is therefore inherent uncertainty in what the actual GHG impact of the Project might be. However the assessment has used a worse–case assumption in determining the emissions by assuming that the plant would operate at the full loading of any given scenario for 7,000 hours in a typical year which provides an upper limit on the total GHG emissions.
8.5 Baseline description
8.5.1 National emissions profile Pakistan last reported its national GHG inventory in 2012, and these figures are published by the WRI. This contains the latest available data on emissions by sector and is shown in Table 48 below.
Pakistan’s Kyoto Protocol submissions were last reported in 2003 to the UNFCCC, and only covered emissions for 1994.
Table 48: Pakistan National GHG emissions by sector (MtCO 2e) Sector 1996 2000 2004 2008 2012 Energy 99 114 135 155 159 Industrial Processes 5 5 8 16 16 Agriculture 91 101 110 129 140 Waste 5 6 6 6 7 Bunker Fuels 0.4 0.5 0.7 1 1 Total net emissions 199 224 260 306 320 Source: World Resources Institute 21
The data shows that between 1996 and 2012, total GHG emissions in Pakistan have increased by approximately 121 MtCO 2e, or 38%.
The National Economic and Environmental Development Study (NEEDS) 22 for Pakistan predicts that energy sector emissions will grow to 2730 MtCO2e by 2030, or from 50% of total emissions to around 64%. Data on future emissions projections is not available for all sectors.
23 The grid average emission intensity for Pakistan is 416 kgCO 2e/MWh . This value is lower than the expected emissions intensity of the Project. However, the grid average for Pakistan contains hydro power stations which account for around a third of the electricity supply and have an emissions factor of zero. If the grid average factor is adjusted to account for this, it would be approximately 624 kgCO 2e/MWh. This scenario contains oil and gas powered plants which have a lower emissions value than coal.
21 http://cait.wri.org/historical/Country%20GHG%20Emissions?indicator[]=Total GHG Emissions Excluding Land-Use Change and Forestry&indicator[]=Energy&indicator[]=Industrial Processes&indicator[]=Agriculture&indicator[]=Waste&indicator[]=Bunker Fuels&year[]=1996&year[]=1997&year[]=1998&year[]=1999&year[]=2000&year[]=2001&year[]=2002&year[]=2003&year[]=2004&yea r[]=2005&year[]=2006&year[]=2007&year[]=2008&year[]=2009&year[]=2010&year[]=2011&year[]=2012&country[]=Pakistan&sortIdx= NaN&sortDir=desc&chartType=geo 22 https://unfccc.int/files/adaptation/application/pdf/pakistanneeds.pdf 23 http://www.iea.org/publications/freepublications/publication/CO2EmissionsFromFuelCombustionHighlights2015.pdf
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8.6 Impact identification and assessment
8.6.1 Construction impacts The construction of the combustion plant site itself as well as the transmission line will lead to indirect emissions of GHG through the use of materials, construction plant and construction transport.
Emissions from these sources are considered ‘scope 3 (indirect)’ as the emissions do not occur within the site boundary and are owned by others. For thermal power plants, the emissions from these sources are generally considered to be small in comparison to the operational phase combustion emissions.
The World Bank has provided an indicative emissions factor of 2.9 kgCO 2e/MWh to be used as a default value for embodied carbon in construction of power plants where actual data is not available. Based on the expected amount of generation over 30 years, the construction emissions are estimated to be around 370,000 tCO 2e. Acknowledging the uncertainty in the World Bank factor, the indirect emissions from construction are considered to be low in the context of the operational lifetime of the power plant.
The key sources of emissions in the construction phase will include the use of concrete and steel in all the major components of the Project, as well as impacts from the thermal power components such as the boilers and ducting.
8.6.2 Operational impacts This section presents the calculated GHG emissions for the operational phase based on the approach and assumptions outlined in section 8.4.
These calculations are based on the input data presented in Table 46. Emissions associated with the operational phase are presented in Table 49.
Table 49: Calculated emissions for the operational phase Source Unit Output Combustion emissions tCO 2e 3,995,007 Electricity intensity (net) gCO 2e/kWh 939
Total emissions from the plant are predicted to be approximately 4 MtCO 2e in a typical year of full-load operation. The emissions from the operation of the Project would represent a relatively small part of national GHG emissions, at around 1% per year- assuming it is operating at full load. Where the plant operates less than full load, annual emissions would be expected to be lower. Emission intensity is predicted to be approximately 939gCO 2e/kWh, which is around 4% higher than the typical emissions rate for a subcritical CFBC power plant as presented in the 24 IFC Thermal Power Guidelines (>909gCO 2e/kWh), and is above the prevailing grid-electricity rate for Pakistan. As noted earlier, the IFC Thermal Power are indicative and do not take specific account of regional variations.
24 http://www.ifc.org/wps/wcm/connect/dfb6a60048855a21852cd76a6515bb18/FINAL_Thermal%2BPower.pdf?MOD=AJPERES&id=1323 162579734
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8.7 Mitigation and enhancement measures
8.7.1 Construction phase The construction phase will lead to potential indirect emissions due to the construction of the Project and transmission line. These emissions will principally occur through the use of materials and other products, from the transport of those materials and waste to and from the site, and from the use of construction plant.
The following measures are suggested for implementation by the contractor in order to minimise these sources of emissions as far as possible.
● Keep the carbon footprint of all new assets as small as possible to minimise the overall amount of materials as far as possible. ● Use recycled materials in construction where possible, including reuse of materials won on- site. ● Source construction materials from local area where possible to minimise the amount of construction traffic movements, and consider whether certain items could be delivered by rail rather than road. ● Establish sustainable construction management practices. This includes toolbox talks for workers about switching off plant and equipment when not in use, and regular servicing of plant and equipment.
8.7.2 Operational phase An analysis of the Project alternatives is presented in chapter 3. This analysis identified the following relevant to potential GHG emissions:
● There are alternative renewable technologies being explored in Pakistan, but there are challenges to meeting an increasing energy demand and falling supply. Based on the existing fuel supply in Pakistan, one of the key drivers for this Project is to provide stable generation using an indigenous fuel source, reducing dependency on imported oil and gas. ● While the Project leads to GHG emissions, it will adopt CFB technology which offers higher levels of efficiency compared to pulverised coal firing, consequently reducing GHG emissions by a small amount. One of the key factors in determining emissions for coal power plants is the coal quality. Less high quality coal is required per unit of electricity generated compared to low-quality coals. The plant should therefore aim to maintain the quality of the coal to ensure efficiency. In addition, the plant should be well maintained in general terms to ensure it continues to run efficiently for its whole life span.
8.8 Summary
The Project will lead to emissions of GHG, principally CO 2 during the construction and operation of the plant. These emissions mainly arise from the combustion of coal to produce electricity.
Indirect emissions from construction and the delivery of coal to the plant during operation are very small in the overall context of the Project.
Like other thermal power technologies, during operation, the emissions from the Project would represent a relatively small part of national GHG emissions, at around 1% per year- assuming it is operating at full load. The emission rate is higher than the average for Pakistan at present since the amount of coal generation is relatively low compared to oil and gas power generation
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and is around 4% above the typical rate of GHG emissions for a plant of this type. It is recommended that measures are implemented to maintain operational efficiency and to keep fuel quality as high as possible to limit the amount of GHG emissions.
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9 Noise and vibration
9.1 Introduction This chapter presents an assessment of the potential environmental noise and vibration impacts that are expected to arise during the construction, operation and decommissioning phases of the Project. The purpose of the assessment is to identify potential impacts, sensitive receptors likely to be affected and identify potential significant effects so that the scope to mitigate them can be considered.
9.1.1 Scope of assessment Temporary noise impacts are expected to arise during the construction phase due to:
● Site preparation works ● Excavation and foundation works ● Erection of steel structures and duct work ● Construction of buildings ● Delivery and installation of equipment. Permanent noise impacts that are expected to arise during the operation of the Project include:
● Noise from turbine hall, stack, electrical substation ● Noise due to coal extraction and handling ● Noise due to ash disposal. The key sensitive receptors are identified as:
● The settlement of Yusuf Ji Dhani at 0.9km to the west of the Project site ● Scattered settlements at more remote locations. Noise and vibration impacts that have been scoped out of the assessment are:
● Vibration during construction and operation: Due to the distance between the site and the closest receptors it is expected that vibration impacts during all phases of the Project will not generate significant adverse effects at any receptors. It is assumed that blasting will not be required. ● The Project is expected to be operational for 30 years. Decommissioning of the Project is expected to comprise: – End of life decommissioning works – Temporary worksite decommissioning – Existing infrastructure decommissioning. The noise impacts associated with these works are likely to be similar in magnitude to those generated during the construction phase but of shorter duration. Furthermore, it is expected that the proximity of sensitive receptors to the Project during decommissioning will differ from those described in the baseline. It is not meaningful to assess potential noise and vibration impacts so far in advance as the requirements for mitigation cannot be adequately identified. Therefore, the significance of effects due to noise and vibration during decommissioning has not been assessed.
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9.2 Applicable legislation
9.2.1 National requirements
9.2.1.1 EIA Guidance for Coal Fired Power Plants in Pakistan The Government of Pakistan and the International Union for Conservation of Nature and Natural Resources published EIA Guidance for Coal-Fired Power Plants in Pakistan 25 .
The guidance states: “Noise impacts should not exceed the levels represented in the Pakistani NEQS…or result in a maximum increase in background levels of 3 dB at the nearest receptor location off-site.”
NEQS have been replaced by the SEQS in Sindh Province as of 2014. The SEQS have been reproduced in Table 50 and are applied in this assessment.
Table 50: SEQS for noise (2014) Category of Area / Zone Daytime 06:00 to 22:00 Night time 22:00 to 06:00 dB LAeq dB LAeq Residential Area (A) 55 45 Commercial Area (B) 65 55 Industrial Area (C) 75 65 Silence Zone (D) 50 45
The guidance also states: ‘According to the Pakistani legislation, silence zones are zones that are declared as such by the competent authority: an area comprising not less than 100m around hospitals, educational institutions and courts. Note that mixed categories of areas may be declared as one of the four above mentioned categories by the competent authority.’
The guidance states that where there are receptors within 500m of the Project then baseline noise measurements should be made.
9.2.2 International requirements and guidance
9.2.2.1 World Bank Group / IFC Guidelines The World Bank Group has developed a thorough programme of pollution prevention and management to ensure that it funds projects which are environmentally and socially responsible. These guidelines are adopted by many international funding agencies and banks. The IFC, a member of the World Bank Group, has produced the EHS General Guidelines that apply to investment projects in various industry sectors. The Guidelines note that “Noise impacts should not exceed the levels presented in Table 1.7.1, or result in a maximum increase in background levels of 3dB at the nearest receptor location off site”. Table 1.7.1 of the Guidelines is reproduced in Table 51 overleaf.
25 Government of Pakistan and IUCN (2014). EIA Guidance for Coal Fired Power Plants in Pakistan. http://cmsdata.iucn.org/downloads/niap___coal_fired_power_plants.pdf (accessed 19 August 2016)
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Table 51: IFC EHS noise level guidelines Table 1.7.1 – Noise level guidelines* One Hour LAeq (dBA) Receptor Daytime 07:00 – 22:00 Nighttime 22:00 – 07:00 Residential; institutional; 55 45 educational† Industrial; commercial 70 70 * Guidelines values are for noise levels measured out of doors. Source: Guidelines for Community Noise, World Health Organization (WHO), 1999.
† For acceptable indoor noise levels for residential, institutional, and educational settings refer to WHO (1999).
9.2.2.2 World Health Organization The World Health Organization (WHO) provides broad guidance on noise levels required to protect individuals from harmful levels of noise within a range of environments, which is described in ‘Guidelines for Community Noise (1999)’ 26 . The guidelines are intended for the long-term management of community noise to help meet the WHO’s core objective of “the attainment by all peoples of the highest possible levels of health”.
This is an important reference which includes guideline noise values that are founded on the results of scientific research into the effects of noise on the population. This forms the basis of standards for noise used worldwide. The specific values that are considered appropriate to the Project are given in Table 52.
Table 52: WHO Guideline values Specific Environment Critical Health Effect(s) Guideline Noise Value Outdoor living area Serious annoyance – daytime and 55 Leq,16 hours dB(A) evening Dwellings – outside bedrooms (window Sleep disturbance – night time 45 Leq,8 hours dB(A) open) Industrial, commercial, shopping and Hearing impairment 70 Leq,24 hours dB(A) traffic areas, indoors and outdoors
The Guidelines do not specify the hours of the day over which the time bases apply because what is considered to be daytimes, evenings and night-times are expected to be dependent on the social and cultural trends of a country and therefore vary around the world.
9.2.2.3 British Standard 5228 Code of Practice for Noise and Vibration Control on Construction and Open Sites British Standard 5228 ‘Code of Practice for Noise and Vibration Control on Construction and Open Sites’ (2009+A1:2014) provides comprehensive guidance on construction noise and vibration including details of typical noise levels associated with various items of plant or activities, prediction methods and measures and procedures that have been found to be most effective in reducing impacts. The guidance forms the basis for the majority of construction noise assessments in the United Kingdom and is widely recognised internationally.
26 World Health Organization (1999). Guidelines for Community Noise.
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9.3 Methodology and assessment criteria
9.3.1 Overview Noise and vibration impacts associated with the Project which can potentially result in effects to sensitive receptors have been assigned significance using the impact evaluation matrix presented in chapter 5. Under the impact evaluation, impacts of moderate and major magnitude are considered significant impacts. Consequently, impacts evaluated as minor or negligible are not significant.
9.3.2 Determining significance of impacts and effects
9.3.2.1 Sensitivity of receptor The criteria for receptor sensitivity for noise and vibration are given in Table 53 to be compatible with the SEQS.
Table 53: Criteria for determining receptor sensitivity Sensitivity High Silence zones (100 m around hospitals, educational institutions and courts) Medium Residential area Low Commercial area Negligible Industrial area
9.3.2.2 Noise impacts during construction The Example Method 2 – 5 dB(A) Change states: “Noise levels generated by site activities are deemed to be potentially significant if the total noise (pre-construction ambient plus site noise) exceeds the pre-construction ambient noise by 5 dB or more, subject to lower cut-off values of 65 dB, 55 dB and 45 dB L Aeq,T from site noise alone, for the daytime, evening and night-time periods, respectively; and a duration of one month or more, unless works of a shorter duration are likely to result in significant impact. These evaluative criteria are generally applicable to the following resources:
● residential buildings ● hotels and hostels ● buildings in religious use ● buildings in educational use ● buildings in health and/or community use.” The criteria for the magnitude of impact for noise from construction are given in Table 54 and are based on BS 5228 guidance.
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Table 54: Criteria for determining magnitude of impact – construction noise Receptor Noise from construction Magnitude of impact sensitivity alone LAeq,T dB Threshold Negligible Minor Moderate Major Daytime Night time T = 06:00 to T = 22:00 to 22:00 06:00 High and 65 45 Threshold Threshold Threshold Threshold medium not exceeded by exceeded by exceeded by exceeded less than 5 dB 5 dB or more for 5 dB or more for for any less than one one month or duration month more
9.3.2.3 Noise impacts during operation With reference to the criteria of the SEQS the magnitude of impact due to operational noise are given in Table 55. The application of this would also ensure compliance with IFC Performance Standards (PS).
Table 55: Criteria for determining magnitude of impact – operational noise Receptor Operational noise Magnitude of Impact sensitivity LAeq,1h dB Threshold Negligible Minor Moderate Major Daytime Night-time Ambient level Ambient level Ambient level increased by 3dB or increased by any increased by less more amount than 3dB High 50 45 Threshold not Threshold exceeded by less than 3 Threshold exceeded exceeded dB by 3 dB or more Medium 55 45 Low 65 55 Negligible 75 65
9.3.3 Assumptions and limitations The main limitations of the assessment are identified as follows:
● Details on the construction programme, working methods and the inventory of plant to be used (type and quantity in each stage of work) are indicative at this stage. An inventory and reference noise emission values have been assumed and stated in order to provide a preliminary assessment of the potential impacts ● The hours of working during construction phase are not certain at this stage. For the purpose of this noise assessment we have considered a worst case scenario of 24 hours a day, seven days a week which will require three shifts and include night time construction works ● Noise emission details for specific items of operational plant are not available at this stage ● Details of road traffic associated with the Project during the construction and operational phases are limited to a high level review of options at this stage.
9.4 Baseline description Baseline noise measurements were undertaken by SGS on behalf of Mott MacDonald as part of air quality monitoring for the Project 27 . Measurements were made in three positions between 6 and 11 June 2016. The results are summarised in Table 56.
27 SGS (2016). Ambient Air Quality Monitoring Report. Mott MacDonald Pakistan (Pvt.) Limited, Thar, Sindh. SGS Report No. 204/2016.
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Table 56: Summary of baseline noise levels measured by SGS in June 2016 Measured noise level dB(A) Position Location of baseline noise measurement and position 06:00 to 22:00 22:00 to 06:00 relative to the proposed Block VI site 1 Singharo ~ 6.4km to the south 49.4 41.5 2 Achle Ji Dhani ~5.6km to the north-east 51.3 41.4 3 Salar Ji Dhani at ~2.2km to the north 48.0 40.6
9.5 Impact identification and assessment
9.5.1 Construction impacts
9.5.1.1 Overview Construction is expected to take around 40 months to complete followed by a 6-week period of commissioning before full commercial operation can begin. The main activities are as follows:
● Site preparation ● Excavation and foundation works ● Erection of steel structures and duct work ● Construction of buildings ● Delivery and installation of equipment and components.
9.5.1.2 Assessment of noise impacts during construction Construction noise impacts will mainly be associated with operation of static and mobile items of plant. The inventory of plant to be brought to site is not certain at this stage; however, a representative list of items has been compiled in Table 57 with reference to BS 5228 – 1:2009+A1:2014 in order to assign reference noise levels for the calculation of noise impacts.
Table 57: Main items of noise emitting plant expected to be used during construction and reference noise levels for the prediction of impacts Activity Main items of noise emitting Reference noise level of a plant single item operating continuously LAeq,10 metres dB Site preparation Tracked excavator 78 Dozer 81 Dozer towing roller 81 Water pump 65 Dump truck 74 Excavation and foundation works Sheet steel piling – vibratory piling 88 rig Craneage for piling 67 Concrete mixer truck 80 Tracked excavator 78 Erection of steel structures and Tower crane 77 duct work Generator for welder 57 Hand held welder 73 Angle grinder 80 Tracked mobile crane 71
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Activity Main items of noise emitting Reference noise level of a plant single item operating continuously LAeq,10 metres dB Construction of buildings Tower crane 77 Tracked mobile crane 71 Diesel scissor lift 78 Delivery and installation of Lorry pulling up 70 equipment and components Wheeled mobile crane 70 Telescopic chandler 79
The methodology for the calculation of noise impacts presented in BS 5228 – 1:2009+A1:2014 has been used to predict the level of noise during each of the five main activities within the construction programme. The attenuation of sound between the Project site and the sensitive receptors is assumed to be without the application of corrections given in BS 5228 – 1:2009+A1:2014 for attenuation due to ground absorption or any screening attenuation. Therefore, the worst-case noise impacts are considered. Table 58 presents a summary of the noise impacts during each stage based on the groups of plant operating shown within the inventory of plant above.
Table 58: Summary of calculated noise impacts at key receptors during the construction phase Sensitive receptors Yusuf Ji Dhani Salar Ji Dhani Achle Ji Dhani Distance from the Project site in metres 900 2,200 5,600 Activity Calculated noise level from construction alone dB LAeq Calculated overall noise levels during site 46 39 30 preparation works Calculated overall noise levels during 50 42 34 excavation and foundation works Calculated overall noise levels during the 44 36 28 erection of steel structures and duct work Calculated overall noise levels during the 42 34 26 construction of buildings Calculated overall noise levels during 41 33 25 delivery and installation of equipment
The highest received noise levels from construction works are predicted to be during the excavation and foundation works. The received noise levels from the works alone are calculated to be up to 50 dB L Aeq free field at the closest receptor Yusuf Ji Dhani. In all cases, the lower cut-off value of 65 dB(A) for daytime is not expected to be exceeded. However, the 45 dB(A) cut-off value for night time is shown to be exceeded at the closest receptor. Table 59 presents an assessment of the worst case noise impacts of during works with reference to pre- construction noise levels for the scenario that works may be undertaken during the daytime or night-time periods.
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Table 59: Assessment of noise impacts from the noisiest phase of construction works – daytime and night time Yusuf Ji Dhani Salar Ji Dhani Achle Ji Dhani Noisiest phase of work Excavation and Excavation and Excavation and foundation works foundation works foundation works Daytime works Measured pre-construction 48* 48 51.3 ambient LAeq dB – daytime Calculated construction 50 42 34 noise alone LAeq dB Predicted ambient during 52.1 49.0 51.4 construction LAeq dB – daytime Change in ambient – daytime +4.1 +1.0 +0.1 Magnitude of impact for Negligible Negligible Negligible residential receptors – daytime
Night time works Measured pre-construction 40.6 40.6 41.4 ambient LAeq dB – night time Calculated construction noise 50 42 34 alone LAeq dB Predicted ambient during 50.5 44.4 42.1 construction LAeq dB – night time Change in ambient - night +9.9 +3.8 +0.7 time Magnitude of impact for Major adverse impact if Negligible Negligible residential receptors – night night works generate time these levels of noise for one month or more * The baseline noise levels for Yusuf Ji Dhani are taken from those measured at Salar Ji Dhani on account that it is the closest of the three measurement positions used.
Table 60 presents an assessment of worst case construction noise impacts at Yusuf Ji Dhani in the case that night works are undertaken in any phase and the duration works could be one month or more.
The results show that the corresponding impacts at the Yusuf Ji Dhani sensitive receptor are assessed as major adverse and therefore significant in the case that site preparation and excavation and foundation work is undertaken during the night period and over a period of one month or more.
At all other sensitive receptors, the impacts that are expected to arise due to noise impacts from construction work are assessed as being rated as negligible and therefore not significant during any phase and if works are carried out during the daytime or night time.
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Table 60: Assessment of noise impacts at Yusuf Ji Dhani during all phases of construction works if conducted at night time and duration of one month or more
Measured Calculated Predicted Change in Magnitude of Significance pre- constructio ambient ambient impact construction n noise during Night time dB ambient LAeq alone LAeq construction dB dB LAeq dB Night time Night time Site 40.6 46 47.1 +6.5 Major adverse if Major adverse preparation night works impact – generate these Significant if noise levels for night works one month or generate these more noise levels for one month or more Excavation and 50 50.5 +9.9 Major adverse if Major adverse foundation night works impact – works generate these Significant if noise levels for night works one month or generate these more noise levels for one month or more Erection of 44 45.6 +5.0 Negligible Negligible – Not steel structures significant and duct work Construction of 42 44.4 +3.8 Negligible Negligible – Not buildings significant Delivery and 41 43.8 +3.2 Negligible Negligible – Not installation of significant equipment and components
9.5.2 Operational impacts
9.5.2.1 Overview The acoustic emissions of the individual items of plant to be installed are not sufficiently certain at this stage. A comprehensive noise model of the proposed power plant will be developed at detail design stage.
Mott MacDonald has conducted noise measurements over a range of distances from an operating coal-fired power station with an output of 1,200MW, which is almost twice that of the proposed Project.
The results of the measurements have been used to derive a noise characteristic as a function of distance shown in Figure 21. The noise characteristic describes the overall, steady-state noise impact of the power plant due to all the associated noise sources including turbines, conveyors, stacks and fixed plant.
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Figure 21: Measured steady-state operational noise levels as a function of distance from a 1,200MW coal-fired power plant
60
55
50
45 Measured LAeq Measured LAeq dB
40
35
30 10 100 1000 10000 Distance from the centre of power plant (turbine hall) in metres
Source: Mott MacDonald
The characteristic shown in Figure 21 has been used to estimate the noise levels received at the closest receptors to the proposed plant. The closest sensitive receptor to the Project site is at 900m which falls within the range of distances of measurements made to derive the characteristic. Extrapolation is required to predict operational noise levels at more remote receptors.
9.5.2.2 Assessment of noise impacts during power plant operation Using the characteristic in Figure 21, the operational noise levels of the power plant are predicted for each receptor and the change in ambient levels are also calculated. The results are summarised in Table 61.
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Table 61: Assessment of noise impacts from power plant operation – daytime and night time Yusuf Ji Dhani Salar Ji Dhani Achle Ji Dhani Distance from the Project 900 2,200 5,600 site in metres Daytime operational noise impacts Measured pre-construction 35.4 48 51.3 ambient LAeq dB – daytime Predicted operational noise 42 39 35 alone LAeq dB Predicted ambient during 42.9 48.5 51.4 operation LAeq dB – daytime Change in ambient – 7.5 0.5 0.1 daytime Magnitude of impact for Negligible Negligible Negligible residential receptors – daytime Night time operational noise impacts Measured pre-construction 35.4 40.6 41.4 ambient LAeq dB – night time Predicted operational noise 42 39 35 alone LAeq dB Predicted ambient during 42.9 42.9 42.3 operation LAeq dB – night time Change in ambient - night 7.5 2.3 0.9 time Magnitude of impact for Negligible Negligible Negligible residential receptors – night time * The baseline noise levels for Yusuf Ji Dhani are taken from those measured at Salar Ji Dhani on account that it is the closest of the three measurement positions used.
This shows that operational noise impacts due to the power plant are expected to be negligible at all receptors. This is because the noise impact of the plant is below 45 dB(A) threshold at all receptors. The corresponding impacts are assessed as not significant.
9.6 Mitigation and enhancement measures The assessment has identified that a risk of significant adverse effects is expected only at the closest sensitive receptor to the Project site, Yusuf Ji Dhani residential area, due to worst case noise impacts from construction (site clearance and excavation and foundation works stages) and only if long–term works are carried out during the night-time. This can be avoided by limiting the noisy works to the daytime periods only. Where night works are found to be necessary, this should be limited to short periods (less than one month) and affected residents should be given prior notice of the reason for, nature and duration of works.
9.7 Residual impacts The residual impacts are not expected to result in significant impacts provided noisy night time construction works are avoided or kept to short–periods with prior notice given to the residents of Yusuf Ji Dhani. Residual impacts are therefore assessed as not significant.
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10 Waste and materials
10.1 Introduction This chapter outlines the proposed approach for managing the key solid waste streams likely to arise during the construction, operation and decommissioning phases of the Project.
Waste management is a key aspect to be assessed by the Project in order to achieve minimisation of raw material consumption, maximise opportunities for waste reuse and recycling and ensure that any final treatment or disposal of wastes generated by the Project is conducted in an environmentally sound manner, particularly for hazardous wastes, in line with international standards and local regulations.
Specific details related to the management of hazardous raw materials from a health, safety and environment perspective are also presented in this chapter given the similarities between their management and the management of waste/hazardous waste. The objective of hazardous materials management is to avoid their use or, when avoidance is not feasible, minimise uncontrolled release of hazardous materials or accidents (including explosion and fire) during their handling, storage and use.
The scope of this chapter is limited to material usage and all solid wastes and those liquid wastes that are not treated via the onsite waste water treatment works.
10.2 Applicable legislation
10.2.1 National requirements
10.2.1.1 Sindh Environmental Protection Act 2014 The SEP Act is applicable to a broad range of issues and extends to the handling of hazardous wastes.
Under the SEP Act 2014, SEPA is an autonomous agency. For administrative purposes, it is part of the Forest, Environment and Wildlife Department of the Government of Sindh and they have the following management authority:
● Issue license for handling of hazardous substance ● Assist governments agencies in implementation of waste management schemes ● Review and approve mitigation plans and give guidance for clean-up operations ● Discharge of waste is prohibited based on Section 11 of SEP Act. Currently there is no SEQS specific to solid waste.
10.2.1.2 Hazardous Wastes Currently, there is no clear regulatory guidance or requirement pertaining to the disposal of hazardous waste; however, PEPA drafted the “Hazardous Waste and Hazardous Substance Rules” under section 13 and 14 of PEPA 1997 28 . These rules are still referred to by SEPA and regulate the handling, manufacture, storage and import of hazardous waste and hazardous substances. Additionally, section 13 prohibits import of substances that might be chemically
28 http://environment.gov.pk/information-services/
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toxic, explosive, flammable, corrosive, radioactive and that have an adverse environmental impact.
10.2.2 International requirements In the absence of robust waste management practices in Sindh Province, the Developer will follow GIIP identified by the IFC PS for waste management and minimisation and the European Waste Catalogue (EWC) for segregation, handling and storage of hazardous wastes.
10.2.2.1 IFC PS (2012) IFC PS3 on Resource Efficiency and Pollution Prevention requires reference to be made to the relevant EHS Guidelines; these are technical reference documents with general and industry- specific examples of GIIP. The EHS Guidelines contain the performance levels and measures that are normally acceptable and applicable to projects.
The underlying principle of IFC PS3 is the minimisation and avoidance of pollution in the first instance. In the context of waste management this means employing strategies and implementing measures which avoid waste generation.
The following IFC EHS Guidelines contain relevant information related to all waste management and hazardous materials management for the proposed Project:
● IFC EHS Guidelines for Thermal Power Plants (2008) ● IFC General EHS Guidelines (2007) The IFC EHS Guidelines for Thermal Power Plants state that large volume coal combustion wastes (CCW) can include fly ash, bottom ash and boiler slag. Low volume wastes from coal fired power plants typically include also the wastewater treatment sludges.
An adequate waste management plan (WMP) should establish a clear strategy for solid wastes that will be generated including options for waste elimination, reduction or recycling or treatment and disposal, before any wastes are generated. A Project specific WMP documenting the waste strategy, storage (including facilities and locations) and handling procedures should be developed and should include a clear waste tracking mechanism to track waste consignments from the originating location to the final waste treatment and disposal location
The IFC EHS Guidelines for Thermal Power Plants give recommendations and methods for the prevention, minimisation and control to reduce the volume of solid wastes from thermal power plants. These are best practice guidelines and should be followed in the development and operation of all new plants.
In addition, IFC PS3 requires the Project to implement technically and financially feasible measures for improving efficiency in the consumption of material. This applies across all Project phases.
All three documents have been used to frame the materials usage and waste management approach for the proposed Project and to assess the Project’s ability to meet GIIP.
10.2.2.2 European Waste Catalogue In the absence of a national waste classification system, the EWC should be used during the construction/installation, operation and decommissioning of the Project. The EWC classifies waste materials and categorises them according to what they are and how they were produced. Reference is made to this when describing the appropriate handling and storage methods because of the absence of national legislation for waste classification.
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10.3 Methodology and assessment criteria The assessment of impacts from waste generation has been conducted on the basis of a desk- based review of Project information provided by the Project parties.
Waste impacts associated with the Project have been assigned significance using the overarching framework presented in Chapter 5 of this ESIA report. Specific magnitude criteria for waste impacts are presented in Table 62 and the sensitivity of receptors considered by the assessment are described in Table 63. The overall impact evaluation matrix presented in chapter 5 is used to determine significance.
Table 62: Criteria for determining magnitude Category Description/examples Major Mismanagement of waste generated and/or raw materials results in a significant incident which potentially causes a fundamental change to the specific environmental conditions assessed resulting in long term or permanent change. Impacts are typically widespread in nature (regional, national and international) and would require major intervention to return to baseline conditions. Moderate Mismanagement of waste generated and/or raw materials results in an incident that potentially causes a detectable change to the specific environmental conditions assessed resulting in non-fundamental temporary or permanent change. Minor Mismanagement of waste generated and/or raw materials results in an incident that potentially causes a detectable but minor change to the specific environmental conditions assessed. Negligible Mismanagement of waste generated and/or raw materials results in an incident that potentially causes no perceptible change to the specific environmental conditions assessed.
Table 63: Criteria for determining receptor sensitivity Category Description/examples High Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with little or no capacity to absorb proposed changes or has minimal opportunities for mitigation. Medium Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with limited capacity to absorb proposed changes or has limited opportunities for mitigation. Low Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with some capacity to absorb proposed changes or has moderate opportunities for mitigation. Negligible Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with good capacity to absorb proposed changes or/and has good opportunities for mitigation.
There is a range of impacts which can occur from the mismanagement of waste arising from construction/installation, operation and decommissioning of the power plant. A waste and materials handling impact assessment is primarily about identifying waste streams and adopting the appropriate best practice management approach, which seeks to avoid generation of waste in the first instance, rather than assessing and mitigating impacts. The sensitivity and magnitude approach has been adopted in order to demonstrate the different expected outcomes and impacts associated with waste generated in the non-management/management strategy scenarios. After identifying the potential sources and, where possible, quantifying waste generated, the assessment focuses on measures to eliminate, reduce, reuse and recycle, as well as solutions available for waste disposal.
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10.3.1 Baseline conditions methodology Baseline information for this assessment has been collected through a desk-based review of the Project area, utilising existing environmental and social reports prepared for the Thar Coalfields and online secondary sources.
10.3.2 Scope of assessment
10.3.2.1 Temporal scope The temporal scope covers the potential impacts related to the consumption of raw materials (including receipt, handling and storage) and subsequent management and disposal of waste arising from the construction, operation and decommissioning phases of the Project.
10.3.2.2 Spatial scope In terms of considering the consumption of raw materials (including receipt, handling and storage) and subsequent management and disposal of waste, the spatial scope of the Project encompasses the proposed Project site, including the temporary construction laydown area and ash disposal facility and a Project landfill to be established.
10.3.3 Assumptions and limitations All generated and/or managed hazardous and non-hazardous materials and waste streams presented in this chapter are based on current documents available for the Project. They are subject to change once the exact construction methodology is determined.
As discussed in Section 10.4.3, the principal materials for construction have been identified and include earthen materials, cement and steel; although, the exact quantities of each material have not yet been calculated. Similarly, there are a number of other materials, including lubricants, paints, plastics and timber that will also be procured directly by the EPC contractor; at this stage the exact quantities of these materials required for the Project are not known; detailed plans and procedures will be produced to include this information.
As discussed in 10.4.6.1, there are no approved landfill sites in close proximity to the Project and licensed waste carriers are not available in the Project area.
The principal waste streams have been identified and therefore the waste management protocols and philosophy presented in Section 10.6 of this chapter would not be expected to change significantly as a result of potentially minor modifications to the actual waste streams and quantities which are ultimately generated as a result of the Project.
10.4 Baseline description
10.4.1 Overview This section presents the baseline characterisation of the Project area’s materials use and waste management procedures, to enable comparison of the current situation with changes anticipated to the identified social and environmental receptors as a result of the Project.
The Government of Pakistan has taken some action to improve their solid waste management system. In 2005 PEPA introduced a draft Guidelines for Solid Waste Management 29 and the following year a National Sanitation Policy was announced by the Federal Government which
29 http://www.environment.gov.pk/EA-GLines/SWMGLinesDraft.pdf
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focuses on recycling, reduction and reuse of waste. No regional Sindh policy has been provided to date. Based on these guidelines it is the local municipality’s responsibility to collect and dispose of the generated waste. The government has been proactive in addressing the challenges presented with the disposal of solid waste; there is currently no appropriate management system in Pakistan and uncollected waste causes serious health problems by, for example, providing breeding habitats for mosquitos that create risks of malaria and cholera.
The main issues regarding waste management in Pakistan are as follows:
● There is no formalised/controlled waste collection system outside of major cities ● Wastes are not segregated at collection ● There are few controlled landfill sites ● There is a limited overall waste management strategy, particularly with regards to the recycling of waste Traditionally wastes are not segregated and much of waste generated does not actually reach landfill sites. In rural areas, greater segregation and reuse take place to maximise limited resources.
The Province of Sindh, where the Thar Coalfield is located, is one of the provinces of Pakistan with the largest population. Sindh Local Government Ordinance 2001 gives the responsibility of solid waste collection and transfer to the Taluka Municipal Administration; responsibility for treatment and disposal of solid waste is given to the City District Government Karachi (Rahman, 2013). Overall, the Sindh Province governing authorities have limited human resources, financial resources or the machinery or technology to properly manage waste.
There is no disposal site and treatment facility for hazardous waste in Pakistan and most solid waste is delivered to disposal areas with no classifications.
10.4.2 Materials use The principal materials that are expected to be required/consumed as part of the construction specific components of the Project are summarised in Table 64. This information is based on current designs of the Project.
Material for site profiling will be sourced from the spoil generated by the mine excavations. It is likely that cement will be sourced locally in Pakistan and steel will be sourced from China. Key plant items will be sourced from China and transported by ship to the Port of Karachi, where they will be unloaded and transported by heavy goods vehicles (HGV) to the Project site.
There will also be a number of other materials required/consumed during the construction of the plant, including: lubricants, oils, fuel (diesel), paint, plastics, packaging materials (paper, cardboard, timber) and food; the exact quantities of these materials are also not yet known.
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Table 64: Primary construction materials Work Item Earthen Steel (tons) Concrete Comments Material (m 3) (m 3) Generation 3,500 6,950 13,500 Units Stack 0 830 6,921 Based on Stack Height of 210m Coal storage 500 39 4,181 Cooling towers 65,100 36 31,000 Waste water 26,000 7 5,000 treatment facility Site profiling 200,000 - - TOTAL 295,100 7,862 60,602
Table 65 covers the activity and type of materials which are expected to be used during operations. Within this table the materials considered to be of a hazardous nature are highlighted, these will require bespoke consideration, particularly any final treatment or disposal options. Some materials will have a known consumption and storage volume, whereas the consumption and volume of other materials will be dependent on routine maintenance and outage activities therefore it is difficult to give exact volumes for all materials.
During detailed engineering design stage, a detailed materials handling and storage plan will be developed in accordance with the EPC contractors estimated material volumes for both construction and operations and suitable materials storage facilities will be provided.
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Table 65: Materials and chemicals used during operations 30 Material Activity Type Storage capacity Coal fuel Combustion Unit Non-hazardous 65,000 tonnes (270.6 t/h for each boiler)
Limestone Combustion Unit Non-hazardous (22.6 t/h for each boiler) Sand Combustion Unit Non-hazardous Diesel fuel Boiler start-up burners, auxiliary boiler, emergency Hazardous x2 overground oil diesel generator(s), diesel fire water pump storage tanks Site vehicles with a total volume of 800m 3 Hydrochloric Water treatment / steam cycle Hazardous 420kg acid (HCl) Sodium Water treatment Hazardous 250kg hydroxide (Caustic Soda) (NaOH)
Cement and Maintenance and outage activities Non-hazardous Minimal concrete
Paints, oils Maintenance and outage activities Hazardous Minimal and fuels, lubricants, cleaners, solvents Ferrous and Maintenance and outage activities Non-hazardous Minimal non-ferrous metals
Fluorescent Maintenance and outage activities Hazardous Minimal tubes
Batteries Maintenance and outage activities Hazardous Minimal
Wood and Maintenance and outage activities Non-hazardous Minimal timber
Plastic Maintenance and outage activities Non-hazardous Minimal
Glass Maintenance and outage activities Non-hazardous Minimal
Paper and Maintenance and outage activities Non-hazardous Minimal cardboard
10.4.3 Material storage A number of materials storage facilities will be provided for the construction of the Project, which includes:
30 Storage capacities to be defined in the operational site waste management plan
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● Storage facilities for cement, steel and other bulk construction materials ● Hazardous materials including oils and chemicals ● Dedicated fuel delivery, storage and handling area of fuel ● Covered and uncovered storage areas for general construction materials
10.4.4 Ash disposal Through the coal combustion process both bottom ash and fly ash will be generated as residuals and will be disposed of through the ash handling system. Information on the average approximate production quantities are provided in section 10.5.3.3.
The Developer will be responsible for the transportation and disposal of ash, which is expected to be located at the Block VI mine site. The ESIA will identify whether there are other pre- existing appropriate ash disposal areas. Discussions with the Developer and relevant stakeholders will be undertaken to ascertain whether there is a potential for commercial use for the fly ash (eg cement manufacturing) and bottom ash (eg road construction) within Pakistan.
10.4.5 In-pit and out-of-pit dumps Based on the choice of mining method there will be an in-pit dump with maximum waste dump height of 205m and berm width of 18m, and an out-of-pit dump with maximum waste dump height of 120m and berm width of 30m. The earthen material will be stripped and transferred to the in-pit dump by an excavator or to the out-of-pit dump by trucks. The out-of-pit dump will receive waste material that does not fit in the in-pit dump space.
The most significant waste stream (in terms of volume), which will be generated as a result of the construction phase of the Project is spoil due to excavation of the Project area during the site preparation and construction phases. It is expected that a substantial amount of earthen materials will be used to raise the level of the Project site, including the development of foundations for the boilers and steam turbine generator. A spoil management plan will need to be developed to ensure that the pits are appropriately managed including control of slope stability and control of erosion.
During detailed engineering design stage, detailed estimated material volumes for both construction and operations will be provided.
10.4.6 Solid waste Wastes will be generated during both the construction and operational phases of the Project and will likely include solid, liquid, hazardous, non-hazardous, and inert wastes.
Potential hazardous waste types generated during the construction and operational phases across the Project may include: waste oils and solvents, lubricants, and contaminated soils (potentially from leakage and spillage).
For the purposes of the construction phase it is envisaged that there will be the following Project staff quarters/facilities and maintenance/construction areas which will result in the generation of waste:
● Construction worker camp ● Site offices and other site facilities, which will include a concrete batching plant and mixing plant and main stores Considering the proposed facilities and construction works, the following waste streams are expected to be generated as part of the construction phase:
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● Excavation spoil associated with site levelling and site profiling activities ● Concrete and concrete washings from concrete batching plants required for the construction of the plant ● Iron and steel scrap ● Non-ferrous scrap ● Waste oil and lubricants from turbine installation and vehicle maintenance/repair ● Oil contaminated cloths from turbine installation and vehicle maintenance/repair ● Oily debris from shop sumps and spill clean-ups ● Packaging and pallets from deliveries ● Domestic waste, including glass, plastics, paper and cardboard ● Batteries ● Fluorescent tubes ● Organic household waste ● Paints and chemicals ● Tyres ● Medical waste (arising from medical facilities at the construction worker camp)
10.4.6.1 Hazardous and non-hazardous wastes Table 66 presents the hazardous and non-hazardous wastes that are likely to be produced on site during both the construction and operation phases of the Project. The quantities of these hazardous waste materials are not anticipated to be high; as part of the site waste management plan (SWMP) an estimate of waste materials to be produced will be calculated based on assessment of the materials requirements.
There are two general classifications of wastes namely non-hazardous wastes and hazardous wastes. Each waste stream has been identified as belonging to one of the following classifications:
● Non-hazardous wastes are wastes that include but are not limited to concrete, glass, wood, common garbage, office wastes, construction wastes that are not burnable such as boxes ● Hazardous wastes are materials classified as exhibiting characteristics such as explosive, flammable, spontaneous combustion potential, oxidising potential or corrosive
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Table 66: Predicted hazardous and non-hazardous waste streams Hazardous Non-hazardous Oils and lubricants and Fly ash and bottom ash Excavation spoil Paper and cardboard contaminated cloths Oily debris from Concrete Timber General domestic waste workshop sumps/spill clean-ups Batteries Concrete washings Woody debris Organic household waste Fluorescent tubes Iron and steel scrap Bricks and tiles Paints and chemicals Non-ferrous scrap Pallets Contaminated material Packaging Glass Medical waste Plastics Tyres
There are no approved landfill sites in close proximity to the Project. It is the intention of the Developer to construct and operate a landfill site for the disposal of construction and municipal waste, which is engineered with an impervious protective membrane (as a minimum for hazardous waste), and a support layer of clay which will utilised form the mine overburden and readily available within Block VI, to prevent ground contamination. Construction of the landfill site must be undertaken in accordance with national legislation and permitting requirements. The landfill site shall be equipped with a leachate collection/processing area.
Disposal of any medical waste must be undertaken at licensed facilities. The EPC contractor will be required to identify suitable sites with adequate medical waste disposal facilities (ie hospital incinerators); details will be provided in the SWMP. Licensed waste carriers are not available in the Project area; therefore it will be responsibility of the Developer and the EPC contractor handle and transport medical waste.
Regarding the recycling of non-contaminated waste material (ie paper, glass, metals and plastics) and in the absence of registered waste contractors, a local community recycling program could be put in place to take materials from the EPC contractor. These materials could be used locally or transported to Karachi for recycling.
10.4.7 Liquid waste Liquid waste will be generated from the acid cleaning of the waste heat boiler every 3 to 5 years and will be discharged to the outdoor waste liquid pond.
10.5 Impact identification and assessment
10.5.1 Introduction This section presents the identification and assessment of the potential adverse impacts from materials and waste during the Project’s construction and operational phases.
The following sections discuss the potential environmental impact and proposed handling/storage and disposal methods for each of the materials and waste streams, which may arise during the two phases of the Project. Measures to mitigate the likely adverse impacts and enhance the beneficial impacts of the Project are presented in Section 10.6.
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10.5.2 Construction impacts
10.5.2.1 Overview This section aims to characterise the raw materials to be consumed and the waste streams which are envisaged to arise from construction activities associated with the development of the Project. The same types of wastes and material are anticipated to be generated/used during decommissioning phase and are also addressed here.
10.5.2.2 Material use The main materials that are expected to be required/consumed as part of the construction phase will principally comprise the items of equipment for the Project, as well as materials used for site preparation such as rods for piling and buildings, concrete for foundations and auxiliary structures, steel for buildings and materials for fitting out the interiors of buildings.
There will also be a number of other materials (hazardous and non-hazardous) used during the construction/installation of the Project, including: lubricants, oils, fuel (diesel), paint, plastics, packaging materials (paper, cardboard, timber) and food among others. Smaller quantities of other materials will be used throughout construction. Mitigation proposed to minimise the use of materials is discussed in Section 10.6.
The principal potential impacts which can arise from the generation of waste from the construction phase of the Project are as follows:
● Use of potentially finite and/or scarce resources ● Ineffective spoil/excavated material handling, storage and disposal causing contamination of the environment ● Contamination of environments due to leakage and spillage of materials (such as fuel, oils and chemicals) from poor materials handling and storage arrangements ● Occupational health and safety from exposure to hazardous materials ● Elevated dust levels and other emissions to air as a result of the operation of the concrete batching plant at the construction site
● Embedded CO 2 associated with the chemical process and heat input required for its production ● Transportation of construction materials to site resulting in GHG emissions and nuisance effects (noise and dust)
10.5.2.3 Waste generation Table 67 summarises waste streams that are expected to be generated during the construction phase of the Project as well as their potential impacts, how they will be handled/stored and the method of disposal for each waste stream. Each waste stream has been identified as belonging to one of the following classifications:
● Inert construction wastes are wastes that are solid and when disposed of are not expected to undergo physical, chemical or biological changes to such an extent as to produce substances that may cause an adverse impact. Such wastes include but are not limited to excavated spoil, concrete, glass, ceramic materials, unpainted scrap metal, and dry timber or wood that has not been chemically treated. ● Non-hazardous wastes are all wastes that are not hazardous wastes and are not inert construction wastes. This includes common garbage, office wastes, construction wastes that are burnable such as boxes, and treated sewage effluent and sewage sludge.
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● Waste materials are classified as hazardous wastes when they exhibit one or more of the characteristics shown below or are hazardous by definition: explosive, flammable, spontaneous combustion potential, oxidizing potential, toxic and corrosive.
Table 67: Construction wastes: Potential impact, proposed handling / storage and offsite disposal methods No. Type of waste Source Potential unmitigated Mitigation and impacts management Non-Hazardous 1.1 Excavation spoil Associated with site Contamination of Spoil disposal site- handling, preparation works and the receiving environments transfer and disposal to be excavation of the Project Fugitive dust emissions undertaken by EPC contractor in area Disposal of spoil and accordance with the procedure excavation material which detailed in the framework SWMP (refer to Vol IV) occupies large amounts of land Development of in- pit and out- of-pit dumps and spoil Visual amenity associated with disposal sites management plan Transportation resulting in GHG emissions and nuisance effects 1.2 Concrete Associated with the Fugitive dust emissions Waste concrete can be crushed construction of the Plant Additional pressure on the and used as road material or fill, use of existing landfill, or where possible, buried in the where waste reuse or proposed Project landfill site. recovery is not feasible Soils contaminated by cement can also be used as landfill Transporting waste materials from the Project cover. site resulting in GHG emissions and nuisance effects 1.3 Concrete washings Associated with the Contamination of Concrete wash water to be construction of the plant receiving environments reused on site wherever possible. On site concrete batching should include wash water recirculation. Remaining wash water to be stored and allowed to evaporate. Any remaining wash water to be fully treated (fine solids removed by filtration or settlement and pH corrected to 6-9) before being discharged into adjustment pool only if properly permitted (i.e. not to bare ground). 1.4 Iron and steel scrap Associated with the The use of Project landfill, Scrap metal will be sold for Non-ferrous scrap construction of the Plant where waste reuse or recycling, as appropriate. recovery is not feasible Packaging Plastics Visual amenity impacts associated with poor Paper and Cardboard storage of waste Timber Transporting waste Woody debris materials from the Project Bricks and tiles site resulting in GHG Pallets emissions and nuisance effects Glass Tyres 1.5 General domestic Kitchen and worker The use of landfill, where Wastes to be segregated and waste facilities waste reuse or recovery is opportunities will be identified for not feasible composting biodegradable waste
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No. Type of waste Source Potential unmitigated Mitigation and impacts management Visual amenity impacts If there are no licensed disposal associated with poor sites31 , segregation of recyclable storage of waste waste and composting of the Windblown litter and organic waste are recommended potential odour and health risks by attracting vermin Hazardous 1.6 Oils and lubricants and Associated with the Contamination of Recovery and re-use options to contaminated rags construction of the Plant receiving environments be fully explored. Where Improper handling, recovery and re-use is not storage, and collection of feasible disposal of waste to the hazardous waste, where proposed Project landfill reuse, recovery recycling is not feasible 1.7 Batteries Associated with the Contamination of Handling, transfer and disposal Fluorescent tubes construction of the Plant receiving environments to be undertaken by EPC Paints and chemicals Improper handling, contractor in accordance with the storage, and collection of procedure detailed in the hazardous waste, where framework SWMP (refer to Vol reuse, recovery recycling IV) is not feasible 1.8 Medical waste First aid and on-site Contamination of Further assessment required by medical facility receiving environments the EPC contractor to identify Health and safety: risk of suitable facilities for the disposal infection and exposure to of medical waste diseases 1.9 Contaminated material Spills and leaks on site Improper handling, To be disposed of to the Oily debris from including accidental storage, and collection of proposed Project landfill worksite and spill spillage and leakage of hazardous waste clean-ups chemicals, fuels, oil and Improper transportation of lubricant from on-site fuel hazardous materials to storage tanks and the designated equipment maintenance treatment/disposal facilities may pose a risk of contamination to the land, groundwater and surface water 1.10 Used solvents Contamination of Collected in bunded, Reuse solvents as far as environments segregated drums and possible or returning them to the suitably stored on a supplier. All remaining solvents temporary basis within a will be incinerated waste management area.
The environmental impacts of generated wastes associated with the construction phase of the Project will be short term and mostly reversible. These potential impacts will be effectively managed through establishment of detailed waste management plans in line with the framework waste management plan as outlined in the ESMP. The specific details of such waste management plans will be prepared by the EPC contractor, the key elements of which are summarised in Section 10.6.2.
10.5.3 Operational impacts
10.5.3.1 Overview The operation of a large-volume coal combustion plant will generate relatively large quantities of waste, including fly ash; bottom ash and boiler slag. Within the Project these unavoidable waste
31 The EPC contractor will be responsible for identification of these companies and arranging to use their services and facilities.
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streams will be treated in recovery and / or abatement systems, recycled where possible, sold to external users or in the last resort will be disposed of as waste.
10.5.3.2 Impacts from operational material use Exact quantities of materials used during operations will depend on the optimised operating regime of the Plant; the likely quantities of each key material have been presented in the following sections.
The primary environmental impacts associated with material use during operations are:
● Contamination of environments due to leakage and spillage of materials (such as fuel, oils and chemicals) from poor materials handling and storage arrangements ● Surplus materials requiring disposal ie out of date, excess to requirement, damaged ● Disposal of packaging waste ● Occupational health and safety from exposure to hazardous materials ● Transportation of materials to site resulting in GHG emissions and nuisance effects Lignite The main material used during the operation phase of the Project will be lignite. The Thar Coalfield has one of the world’s largest lignite reserves with approximately 175 billion tonnes of capacity. There will be an open pit near the centre of Block VI. The initial mine development and production will be completed by truck and shovel due to lack of electrical power. Once full production is achieved, crushed overburden and lignite will be transported by conveyors.
The coal from conveying system will be delivered to the boiler through the feeder at the top. Coal storage will have four bunkers with the total volume of 625m 3. There will be in total eight coal feeders for one boiler.
There will be two coal storage yards for the Project, and the total capacity will be 65,000 tonnes. It will provide sufficient coal for five days for two sets of boilers. Coal will be conveyed from the storage area to a crusher and then onto the CFB boilers for combustion. To control fugitive particulates, dust collection systems are provided at the coal transfer points. The coal storage yard will be located at the northern point of the site. The coal stockpile height will be restricted to a certain level (5-6m) to prevent dust issue in a strong wind environment.
Typical environmental impacts associated with coal are as follows:
● Contamination of receiving environments due to runoff associated with poor handling and storage arrangements ● Fugitive emissions, such as dust associated with the handling and storage of the coal ● Visual amenity impacts associated with poor storage Limestone During operation, limestone will be used to reduce the levels of sulphur dioxide in flue gases released via the stack. This will be achieved by injecting pulverised limestone into the CFB boiler where it will react with the sulphur during combustion to form calcium sulphate. The limestone demand will depend on the sulphur content of the coal and coal consumption.
The required quantities of limestone for the Plant are approximately 200,000 tonnes per annum for one boiler. Limestone will be transported to site by trucks and stored in a limestone powder silo, and will be transferred to the boiler by a covered pneumatic conveying system.
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Fugitive emissions, such as dust associated with the handling and storage of the limestone, are considered to be the only likely environmental impact associated with limestone.
10.5.3.3 Waste management It is expected that waste material will be generated as a result of routine maintenance and equipment outages. The exact type and quantity of the waste arising will be dependent upon the nature of those activities. Waste streams typically associated with a major outage for a coal fired power plant are similar to those encountered during construction. Provision for the identification of suitable management of these waste streams will be required prior to any significant outage activities being carried out.
Waste streams that will arise during operation will include:
● Furnace bottom ash and fly ash ● Oily contaminated materials, such as oily rags ● Lubricating and auxiliary oils ● Trace contaminants in the fuel (introduced through the ash-handling wastewater discharges) ● Empty chemical containers ● Solvents, paints ● Spent filters and ion exchangers ● Delivery packaging ● Waste clean-up collected as a result of spills, leakages and/or accidental discharge Fly ash and bottom ash One of the most significant waste by-product streams which will be generated during the operation of the Project will be bottom ash and fly ash. Together they are considered to be coal combustion wastes, as defined by the IFC EHS Guidelines for Thermal Power Plants.
Table 68: Overview of the operational phase fly ash and bottom ash production amounts Waste Average production Bottom ash ~883 t/day (280,000 per annum) Fly Ash ~1320 t/day (420,000 per annum) TOTAL ~2,203 t/day (700,000 tonnes per annum)
Fly ash is the result of the combustion of coal and is ash which has become entrained in the flue gases which emanate from the units. The Project will install ESPs which serve to remove fly ash particles from the flue gases thereby lowering the particulate concentration prior to emission to air via the exhaust stack. The dust will fall down into hoppers which collect the ash. Fly ash will be collected from the hoppers and transported to the ash disposal area via trucks. There will be two types of fly ash; dry and slurry type.
Bottom ash is produced from the non-combustible material that settles to the bottom of the boiler and remains in the form of unconsolidated ash. Bottom ashes extracted from the boiler are mainly agglomerated. Bottom ash will be disposed of with fly ash. Commercial uses for both fly and bottom ash will be explored, such as block making.
Typical environmental impacts associated with ash production are the same as that associated with coal but also includes the use of landfill, where waste re-use or recovery is not feasible, which is a finite resource.
Discussion on the selection of a suitable site for the ash disposal site is provided in section 10.6.
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10.5.3.4 Summary Table 69 presents the high-level waste handling strategy for the operational phase of the Project. It includes the expected source of each waste stream, the potential environmental impact which could occur, along with the expected disposal / final removal method.
Table 69: Overview of the operational phase waste handling strategy for the Project Waste Source Potential environmental Disposal method Impact Bottom ash Associated with routine Potential contamination of Collected, transported and and on-going receiving environment disposed of to the ash disposal maintenance in the Fugitive emissions site to be located within the facility and outages Visual amenity impacts Block VI mine site within a lined area. Increased waste miles Options for commercial ash use Non hazardous to be periodically reviewed. Fly ash Associated with routine Potential contamination of Collected, transported and and on-going receiving environment disposed of to the ash disposal maintenance in the Fugitive emissions site to be located within the facility and outages Block VI mine site within a lined Visual amenity impacts area. Increased waste miles Options for commercial ash use Non hazardous to be periodically reviewed. Sludge from boiler feed Power plant Hazardous Collected and disposed of in water unit Potential contamination of accordance with the procedure receiving environment detailed in the framework SWMP (refer to Vol IV). Oil contaminated sludge Associated with routine Hazardous Recovery and re-use options to Oily contaminated and on-going Potential contamination of be fully explored. Where materials e.g. oily rags maintenance in the receiving environment recovery and re-use is not Lubricating / auxiliary oils facility and outages feasible then disposal of in the proposed Project landfill. Water treatment sludge Empty chemical containers Solvents, paints Spent filters and ion exchangers Spent resins Contaminated packaging Primarily associated with Hazardous Disposal of waste in the any chemical deliveries Unknown contaminants and proposed Project landfill. potential contamination of receiving environments Use of finite landfill resource Effluents collected as a Associated with routine Hazardous Disposal of waste in the result of spills, leakages and on-going Potential contamination of proposed Project landfill. and/or accidental maintenance in the receiving environments discharge. facility and outages
Fluorescent tubes Associated with routine Hazardous Disposal of waste in the and on-going Fluorescent tubes contain mercury proposed Project landfill. maintenance in facilities Use of finite landfill resource and workshops Waste oil Associated with routine Hazardous Disposal of waste in the and on-going Potential contamination of proposed Project landfill. maintenance in the receiving environment facility and outages Waste electronics and Maintenance and Hazardous Recycling options to be fully electrical equipment replacement of electrical Potential contamination of explored. Where recycling is not (WEEE) equipment receiving environment feasible then disposal in the proposed Project landfill.
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Waste Source Potential environmental Disposal method Impact May contain heavy metals depending on the item Concrete Associated with outages Recovery potential Disposal of waste in the and maintenance Visual amenity impacts proposed Project landfill. Use of finite landfill resource General domestic waste Kitchen and workers’ Potential contamination of Disposal of waste in the facilities receiving environment. proposed Project landfill. Visual amenity impacts Use of finite landfill resource Paper and cardboard From packaging and Potential contamination of Plastic deliveries receiving environment. Visual amenity impacts Glass Maintenance, deliveries, workerss facilities Iron and steel scrap Associated with outages Potential contamination of Where recycling is not feasible Non-ferrous scrap and maintenance receiving environment. then disposal in the proposed Visual amenity impacts. Project landfill. Recycling potential. Pallets Associated with Potential contamination of deliveries receiving environment. Visual amenity impacts Timber Associated with routine Recycling potential. and on-going maintenance in the facility and outages
10.5.4 Decommissioning The principal pieces of infrastructure which will require removal as part of the decommissioning phase are as follows:
● Powerhouse equipment and buildings ● Fuel storage tanks ● Wastewater treatment structures ● Coal handling storage facilities ● Ash silos From a waste management perspective, the principle waste stream likely to be generated during decommissioning are the large volumes of concrete associated with the different buildings and structures.
Advanced planning will be required in order to categorise each waste stream and identify a potential re-use/recovery option. This will be particularly important for concrete and metal given the large quantities likely to be generated.
Prior to the eventual decommissioning of the Project, a decommissioning environmental management plan (DEMP) will be prepared detailing the best practice approach that will be adopted. The DEMP will include a section on waste management detailing the environmental protection controls that will be put in place for the storage, safe handling arrangements of each waste stream and the recovery/re-use/recycling pathways, or disposal methods for those wastes which can be recovered, re-used or recycled.
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10.5.5 Impact significance The Project will be operated under best practice methods for storing and disposing of materials and waste. Table 70 provides a summary of the impact significance associated with material handling and waste management.
Table 70: Summary of impact significance Activity Potential impact Sensitivity Magnitude Impact evaluation Construction/decommissioning Use of raw Use of potentially finite and / or Medium Moderate Moderate adverse – materials scarce resources. significant Waste Contamination of environments Medium Moderate Moderate adverse – generation, due to leakage and spillage of significant handling and wastes associated with poor storage waste handling and storage arrangements. Fugitive emissions, such as dust, Medium Moderate Moderate adverse – associated with the handling and significant storage of some waste streams. Visual amenity impacts Low Moderate Minor adverse – not associated with poor storage of significant waste. Spoil handling Disposal of spoil and excavation Low Low Negligible – not significant and disposal material which results in land take. Choice of final The use of landfill, which is a Medium Moderate Moderate adverse - waste disposal finite resource significant option Increased waste miles from Low Negligible Negligible - not significant transporting waste materials from the Project site. Operation Use of raw Use of potentially finite and / or Medium Major Major adverse –significant materials scarce resources. Waste Contamination of receiving Medium Moderate Moderate adverse – generation, environments due to leakage and significant handling and spillage of waste streams from storage the operation of the Project. Fugitive emissions associated Medium Moderate Moderate adverse – with the handling and storage of significant operational waste streams Choice of final The use of landfill, which is a Medium Minor Minor adverse – not waste disposal finite resource significant option Increased ‘waste miles’ from Low Minor Minor adverse – not transporting waste materials from significant the Project site.
10.6 Mitigation and enhancement measures
10.6.1 Overview General waste management and overall management of hazardous materials will be managed for the construction and operational phases as follows:
● Detailed construction phase materials storage, handling and use plan and waste management plan and which will form part of the construction ESMP. ● Operational phase materials storage, handling and use procedures and a waste management procedure which will both form part of an overall environmental and social
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management system (ESMS). The waste management procedure will be required to include a SWMP. ● Detailed construction phase hazardous materials storage, handling and use plan and waste management plan. ● The use of material safety data sheets (MSDS) will be used for all hazardous chemicals and substances during the construction and commissioning phases of the Project. ● Best practice waste management begins with waste prevention and minimisation which is achieved through the efficient storage, handling and use of raw materials. To achieve this aim for the Project in both construction and operational phases, the following material use and handling measures will be considered and imbedded into the construction ESMP and operational phase procedures as appropriate: – Re-using materials on site wherever possible. The most significant opportunity in the construction phase is with respect to excavated spoil. – Instituting good housekeeping and operating practices, including inventory control to reduce the amount of waste resulting from materials that are out-of-date, off-specification, contaminated, damaged, or excess to plant needs. – Instituting procurement measures that recognise opportunities such as ordering the correct amount of materials to be delivered when needed, reducing the amount of packaging used by suppliers and establishing a take-back system with suppliers. – Seeking ways to reduce raw material consumption through efficiency audits in the operational phase. – Substituting raw materials or inputs with less hazardous or toxic materials wherever economically and technically feasible.
10.6.2 Materials storage, handling and use This section presents mitigation measures for the use of materials during the construction and operation of the Project.
To achieve best practice waste management during the construction and operational phases, the following material use and handling measures will be embedded in the Project ESMP:
● Re-using materials on site wherever possible; the most significant opportunity in the construction phase is with respect to excavated spoil and the overburden from the mine that will be used for site levelling ● Establishing good housekeeping and operating practices, including inventory control to reduce the amount of waste resulting from materials that are out-of-date, off-specification, contaminated, damaged, or excess to plant needs ● Implementing procurement measures that recognise opportunities such as ordering the correct amount of materials to be delivered when needed, reducing the amount of packaging used by suppliers and establishing a take back system with suppliers ● Seeking ways to reduce raw material consumption through efficiency audits in the operational phase ● Substituting raw materials or inputs with less hazardous or toxic materials wherever economically and technically feasible A materials handling and storage plan will be developed for the Project which will identify storage areas to be established during the construction phase and will require these to be specifically designed giving due consideration to the following requirements:
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● Located away from sensitive receptors ● Not at risk from theft or vandalism ● Protection from the elements ● Easily accessible in a safe manner ● Well ventilated ● Unlikely to be damaged ● Bunded and with spill kits provided close by (as necessary for hazardous liquids) The construction and operational procedures will include reference to the control measures in order to minimise the likelihood of incidents associated with materials storage, handling and use. This will include the following:
● Identification of the necessary bunding and spill kit requirements ● Details of the correct procedure for handling and storing any hazardous materials ● A map showing the material storage locations ● Vehicle and equipment fuelling to only be undertaken in designated areas on impermeable surfaces with adequate spill protection in place ● Training requirements (as necessary) with respect to materials handling procedures, use of PPE, spill procedures and emergency response procedures ● The correct procedure for reporting any environmental incidents related to spills/ leakages.
10.6.2.1 Ash disposal Sites for the ash disposal facility to serve the plant are currently being investigated and the following options are considered:
● Spoil disposal site in the mine ● Disposal with the overburden from the mine ● Industry re-use For the selected site, an ash management plan will be produced prior to operations commencing and will include the following:
● Appropriate impermeable layers of the landfill site using clays available on the site ● Quantitative balance of ash generation ● Disposal, utilisation and reuse quantities/locations ● Cell structure and their protocol within site ● Size of ash disposal site ● Information on leachate collection and drainage ● Ash transportation arrangements (open and closed rail wagons/tank trucks depending on wet/dry ash) and expected number ● Monitoring required (groundwater/noise/leachate) during operations ● Access/security arrangements ● Design of the ash disposal site in accordance with international best practice.
10.6.3 Construction and operational waste management plans This section presents the waste management measures designed to manage the solid waste generated on the Project site during the construction and operational phases.
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10.6.3.1 Temporary waste storage and handling Temporary waste storage facilities are expected to be provided for the construction and operational phases. It is envisaged that these will be scaled down once the Project moves into the operational phase. These are intended as a secure, short-term storage for all waste streams generated on site prior to being collected by relevant waste collectors for treatment and/or final disposal. They will be designed to include the following:
● Separate storage areas for hazardous and non-hazardous wastes ● Separate skips for each waste stream to allow segregation in order to maximise reuse and recycling opportunities ● All skips to have suitable coverings ● Liquid wastes/oil/chemicals to be stored in tanks or drums located in bunded areas which can hold 110% of capacity of the largest tank or drum or, for multiple drum storage, 25% of the total volume of material stored ● Spill kits to be provided in proximity to hazardous material and waste storage areas and to be regularly inspected and replenished so as to be fully available at all times ● Store hazardous waste in closed containers away from direct sunlight, wind and rain in designated storage areas ● Provide adequate ventilation where volatile wastes are stored ● Handling and storage shall be carried out by trained staff ● Provide readily available information on chemical compatibility to workers including labelling each container, demarcation of the area (eg on a facility map/site plan) ● Conduct periodic inspections of waste storage areas and document the findings ● Prepare and implement spill response and emergency response plans to address an accidental release and leakage
10.6.3.2 Wastewater management The EPC contractor will be responsible for the complete wastewater collection and neutralisation system. The treatment system will collect several process discharges from the entire power plant and auxiliary facilities such as boiler, coal yard and chemistry process systems. The consumption of water will be minimised through recycling and reuse of treated wastewater in activities such as dust suppression and ash handling. The end disposal route for wastewater is still to be confirmed.
10.6.3.3 Construction waste management strategy The SWMP will identify predicted waste streams, appropriate handling, reuse and recycle opportunities and, as a last resort, disposal methods. The SWMP will be prepared in accordance with national waste regulations and the IFC General EHS Guidelines (2007) and the EWC.
The construction SWMP will include the following mitigation measures;
● The best practice waste handling and final treatment options (ie reuse, recycling, recovery or disposal) for each waste stream ● The procedures for the reduction of waste production ● The correct methodology for establishing the spoil disposal sites (ie topsoil, overburden, and low quality materials will be properly removed, stockpiled near the site, and temporarily preserved for any necessary site rehabilitation)
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● A description of the control measures at each spoil disposal site (such as spot checking of spoil loads) ● Contractor training requirements with respect to waste handling procedures ● Waste generation data collection for each waste stream by volume. This will include the proportion of each waste stream going for reuse, recycling or disposal. Any unusual waste volumes will be investigated ● Any waste monitoring as deemed to be necessary ● An audit schedule which details the frequency of waste management audits and those responsible for undertaking them ● The correct procedure for reporting any environmental incidents related to waste ● The specific regulatory reporting requirements as they relate to waste.
10.6.3.4 Operational waste management strategy For the operational phase, the production of a detailed waste management procedure for all operations at the Project is going to be fundamental to ensuring best practice waste management is undertaken and becomes embedded into the operational philosophy of the Project. The waste management procedure will highlight the relevant policy and legislation and include a SWMP, which will contain:
● The establishment of a waste management hierarchy philosophy that considers prevention, reduction, reuse, recovery, recycling, removal and finally disposal of wastes ● A map showing each waste storage location for the Project ● A description of each waste generated by the operation of the facility, the appropriate handling methodology, the correct approach for storage and the correct route for removal/disposal off site ● Staff training requirements with respect to waste handling procedures ● Waste generation data collection for each waste stream by volume, according to the EWC. This will include the proportion of each waste stream going for reuse, recycling or disposal; any unusual waste volumes will be investigated ● Any waste monitoring as deemed to be necessary ● An audit schedule which details the frequency of waste management audits and those responsible for undertaking them ● A section related to continuous improvement and corrective actions where audit findings can be recorded and incorporated into the waste management procedure; this will also highlight any new and feasible reuse or recycling opportunities which may arise over time ● A mechanism by which to routinely track waste consignments from the originating location to the final waste treatment and disposal location ● The correct procedure for reporting any environmental incidents related to waste ● The specific regulatory reporting requirements as they relate to waste It is expected that the control measures described herein will be largely sufficient in avoiding the potential environmental impacts typically associated with waste generation.
10.6.3.5 Wastewater mitigation The waste management plan should include details on the management of wastewater during construction and operation. All liquid waste collected in a covered outdoor waste liquid pond should be tested for pH, chemical oxygen demand (COD) and biochemical oxygen demand
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(BOD) before being released to the environment. At the time of writing the waste water disposal regime was yet to be defined. However, it is understood that the Government of Sindh will provide a water disposal option for all Blocks in the Thar Coalfield.
10.6.4 Proposed monitoring Waste management monitoring for the Project will be undertaken by the EPC contractor / Developer as part of the construction and operational waste management plans detailed in the ESMP. Monitoring data will be analysed and reviewed at regular intervals and compared with the operating standards so that any necessary corrective actions can be taken.
10.7 Residual impacts The mitigation measures identified above will ensure that the vast majority of waste generated as a result of the Project will be managed according to environmental best practice and the risk to the environment is significantly reduced. Following application of the mitigation measures the resultant residual impacts are presented in Table 71.
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Table 71: Summary of residual waste and materials impacts Activity Potential impacts Sensitivity Magnitude Impact Residual impact Residual impact significance evaluation Construction Use of raw materials Use of potentially finite and / or scarce Medium Moderate Moderate adverse Minor adverse Not significant resources. Waste generation, and Contamination of environments due to Medium Moderate Moderate adverse Minor adverse Not significant storage leakage and spillage of wastes associated with poor waste handling and storage arrangements Fugitive emissions, such as dust, Medium Moderate Moderate adverse Minor adverse Not significant associated with the handling and storage of some waste streams Visual amenity impacts associated with Low Moderate Negligible Not significant poor storage of waste Minor adverse Spoil handling and Disposal of spoil and excavation material Low Low Negligible Negligible Not significant disposal which results in land take. Choice of final waste The use of landfill, which is a finite Medium Moderate Moderate adverse Minor adverse Not significant disposal option resource should be final recourse Increased waste miles from transporting Low Negligible Negligible Negligible waste materials from the Project site. Operation Use of raw materials Use of potentially finite and / or scarce Medium Major Major adverse Moderate adverse Significant resources. Waste generation and Contamination of receiving environments Medium Moderate Moderate adverse Minor adverse Not significant storage due to leakage and spillage of waste streams from the operation of the Plant. Fugitive emissions associated with the Medium Moderate Moderate adverse Minor adverse Not significant handling and storage of operational waste streams Choice of final waste The use of landfill, which is a finite Medium Minor Minor adverse Minor adverse Not significant disposal option resource should be final recourse Increased waste miles from transporting Low Minor Negligible Minor adverse Not significant waste materials from the Project site. Decommissioning Prior to decommissioning, a DEMP will be prepared.
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11 Hydrology, hydrogeology and flood risk
11.1 Introduction This chapter presents the baseline conditions and the assessment of impacts on water resources and flood risk associated with the construction and operation of the Project.
11.2 Applicable legislation
11.2.1 National requirements The Sindh Environmental Protection Act 2014 provides powers to the SEPA to issue standards for protection of the environment. The SEPA issued the Sindh environmental industrial waste water, effluent, domestic, sewerage, industrial air emission and ambient airs, noise for vehicles, air emissions for vehicles and drinking water quality standards in December 2014. Table 72 sets out the effluent standards relevant to the Project.
Table 72: Sindh Environmental Quality Standards for municipal and liquid industrial effluents S.No Parameter Standards (mg/l unless otherwise defined) Into Inland Into Sewage Into Sea 2 Waters Treatment1 1 Temperature 40 oC or Temperature increase 3 ≤3oC ≤3oC ≤3oC 2 pH value (H+) 6-9 6-9 6-9 3 Biochemical Oxygen Demand (BOD) 5 at 20 oC4 80 250 805 4 Chemical Oxygen Demand (COD) 4 150 400 400 5 Total Suspended Solids (TSS) 200 400 200 6 Total Dissolved Solids (TDS) 3,500 3,500 3,500 7 Oil and grease 10 10 10 8 Phenolic compounds (as phenol) 0.1 0.3 0.3 9 Chloride (as Cl-) 1,000 1,000 SC 6 10 Fluoride (as Fl-) 10 10 10 11 Cyanide (as CN-) total 1.0 1.0 1.0 12 Anionic detergents (as MBAS) 7 20 20 20 2 6 13 Sulphate (SO 4 -) 600 1,000 SC
14 Sulphide (S 2-) 1.0 1.0 1.0
15 Ammonia (NH 3) 40 40 40 16 Pesticides 8 0.15 0.15 0.15 17 Cadmium 9 0.1 0.1 0.1 18 Chromium (trivalent and hexavalent) 9 1.0 1.0 1.0 19 Copper 9 1.0 1.0 1.0 20 Lead 9 0.5 0.5 0.5 21 Mercury 9 0.01 0.01 0.01 22 Selenium 9 0.5 0.5 0.5 23 Nickel 9 1.0 1.0 1.0 24 Silver 9 1.0 1.0 1.0 25 Total toxic metals 2.0 2.0 2.0 26 Zinc 5.0 5.0 5.0 27 Arsenic 9 1.0 1.0 1.0
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S.No Parameter Standards (mg/l unless otherwise defined) Into Inland Into Sewage Into Sea 2 Waters Treatment1 28 Barium 9 1.5 1.5 1.5 29 Iron 8.0 8.0 8.0 30 Manganese 1.5 1.5 1.5 31 Boron 9 6.0 6.0 6.0 32 Chlorine 1.0 1.0 1.0 Source: SEPA, 2014
1. Applicable only when and where sewage treatment is operational and BOD = 80 mg/l is achieved by the sewage treatment system. 2. Provided discharge is not at shore and not within 10 miles of mangrove or other important estuaries. 3. The effluent should not result in temperature increase of more than 3oC at the edge of the zone where initial mixing and dilution take place in the receiving body. In case zone is not define, use 100 m from the point of discharge 4. Assuming minimum dilution 1:10 discharge, lower ratio would attract progressively stringent standards to be determined by the Federal Environmental Protection Agency. By 1:10 dilution means, for example that for each one cubic meter of treated effluent, the recipient water body should have 10 cubic meter of water for dilution of this effluent. 5. The value for industry is 200 mg/l 6. Discharge concentration at or below sea concentration (SC) 7. Methylene Blue Active substances assuming surfactant as biodegradable 8. Pesticides include herbicides, fungicides, and insecticides 9. Subject to total toxic metals discharge should not exceed level given at S. No. 25 Notes: 1. Dilution of liquid effluents to bring them to the Standards limiting values is not permissible through fresh water mixing with the effluent before discharging into the environment. 2. The concentration of pollutants in water being used will be subtracted from the effluent for calculating the Standards limits.
Table 73: Sindh Standards for drinking water quality Properties/parameters Standard values for Pakistan WHO Guidelines Bacterial 1 All water intended for drinking (e.Coli Must not be detectable in any 100ml Must not be detectable in any 100ml or Thermotolerant Coliform bacteria) sample sample Treated water entering the distribution Must not be detectable in any 100ml Must not be detectable in any 100ml system (E.Coli or thermo-tolerant sample sample coliform and total coliform bacteria) Treated water in the distribution Must not be detectable in any 100ml Must not be detectable in any 100ml system (E.coli or thermo-tolerant sample in case of large supplies, where sample in case of large supplies, coliform and total coliform bacteria) sufficient samples are examined, must where sufficient samples are not be present in 95% of the samples examined, must not be present in 95% taken throughout any 12-month period. of the samples taken throughout any 12-month period. Physical Colour ≤15 TCU ≤15 TCU Taste Non-objectionable/Acceptable Non-objectionable/Acceptable Odour Non-objectionable/Acceptable Non-objectionable/Acceptable Turbidity <5 NTU <5 NTU Total hardness as CaCO 3 < 500mg/l TDS < 1000 < 1000 pH 6.5 – 8.5 6.5 – 8.5 Chemical – Essential Inorganic mg/litre mg/litre
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Properties/parameters Standard values for Pakistan WHO Guidelines Aluminium (Al) < 0.2 0.2 Antimony (Sb) < 0.005 (P) 0.02 Arsenic (As) 2 < 0.05 (P) 0.01 Barium (Ba) 0.7 0.7 Boron (B) 0.3 0.3 Cadmium (Cd) 2 0.01 0.003 Chloride (Cl) < 250 250 Chromium (Cr) < 0.05 0.05 Copper (Cu) 2 2 Chemical - toxic inorganic mg/litre mg/litre Cyanide (CN)2 < 0.05 0.07 Fluoride (F)* < 1.5 1.5 Lead (Pb) 2 < 0.05 0.01 Manganese (Mn) < 0.5 0.5 Mercury (Hg) < 0.001 0.001 Nickel (Ni) < 0.02 0.02 Nitrate (NO 3)* < 50 50 Nitrite (NO 2)* < 3 (P) 3 Selenium (Se) 0.01 (P) 0.01 Residual chlorine 0.2-0.5 at consumer end - 0.5-1.5 at source Zinc (Zn) 2 5.0 3 * Indicates priority health related inorganic constituents which need regular monitoring
Chemical - organic Pesticides mg/l PSQCA No. 4639-2004, Annex II Page No. 4 Table No. 3 Serial No. 20- 58 may be consulted*** Phenolic compounds (as Phenols) mg/l < 0.002 Polynuclear aromatic hydrocarbons (as 0.01 (By GC/MS method) PAH) g/l Radioactive Alpha emitters bq/l or pCi 0.1 0.1 Beta emitters 1 1 *** PSQCA: Pakistan Standards Quality Control Authority
Proviso:
The existing drinking water treatment infrastructure is not adequate to comply with WHO guidelines for Arsenic, Lead, Cadmium and Zinc due to existing contaminants and urban water infrastructure. However, NEQs confirm for bottled water WHO limits for Arsenic, Lead, Cadmium and Zinc will be applicable and PSQCA Standards for all the remaining parameters.
Notes:
1. Most Asian countries also follow WHO standards
2.Standard for Pakistan similar to most Asian developing countries
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Source: Sindh Environmental Protection Agency, 2014
The NEQS (Self-Monitoring and Reporting by Industry) Rules 2001 (SRO 528(1)/2001) (as amended by SRO 114(1)/2005) – the NEQ S.M.A.R.T. system for industrial self reporting on monitoring of liquid or gaseous emissions to the Federal Agency (Environment) Liquid effluents and gaseous emissions from coal fired thermal power plants, and gas production (category A) require environmental monitoring reports to be submitted monthly.
The NNEQS (Certification of Environmental Laboratories) Regulations 2000 (SRO258(1)/2000) prescribe procedures for certification of laboratories where tests may be conducted to check compliance with NEQs. The proposed Project laboratory will require certification in order to comply with the self-monitoring of effluent discharges against NEQS.
11.2.2 International requirements
11.2.2.1 IFC Performance Standards The IFC PSs provide guidance on how to identify risks and impacts, and are designed to help avoid, mitigate, and manage risks and impacts as a way of doing business in a sustainable way. The following IFC PSs are relevant to this assessment.
IF PS3 Resource efficiency and pollution prevention Water consumption : ‘When the project is a potentially significant consumer of water, in addition to applying the resource efficiency requirements of this Performance Standard, the client shall adopt measures that avoid or reduce water usage so that the project’s water consumption does not have significant adverse impacts on others.’
Pollution prevention : ‘The client will avoid the release of pollutants or, when avoidance is not feasible, minimise and/or control the intensity and mass flow of their release. This applies to the release of pollutants to air, water, and land due to routine, non-routine, and accidental circumstances with the potential for local, regional, and transboundary impacts.’
IFC PS6 Biodiversity conservation and sustainable management of living natural resources The objectives of this standard are: ● To protect and conserve biodiversity ● To maintain the benefits from ecosystem services ● To promote the sustainable management of living natural resources through the adoption of practices that integrate conservation needs and development priorities Water resources, both quantity and quality, are fundamental to maintaining habitats and ecosystem services. The potential effects of changes in water management by the Project on biodiversity and ecosystem services are assessed in chapter 14.
11.2.2.2 World Bank Group EHS guidelines General EHS Guidelines The following sections of the General EHS Guidelines are relevant to this assessment:
● 1.3 Wastewater and ambient water quality ● 1.4 Water conservation ● 1.5 Hazardous materials management
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● 3.1 Water quality and availability The following industry sector EHS Guideline is applicable in this case:
Industry Sector EHS Guidelines – Thermal power plants The Guidelines set specific limit values for direct discharges of treated effluents to surface waters for general use. These levels should be achieved, without dilution, at least 95 percent of the time that the plant or unit is operating, to be calculated as a proportion of annual operating hours.
11.3 Methodology and assessment criteria
11.3.1 Area of influence for water resources and flood risk The spatial scope of the assessment of the Project includes surface water and groundwater features within 500m of the Project site, except where there is clearly no hydraulic connectivity, as outside this distance it is unlikely that direct impacts upon the water environment will be attributable to the Project. The 500m scope has been developed using professional judgement.
The Government of Sindh is working with developers in the Thar Coalfield by providing infrastructure for a dedicated supply of surface water (100 cusecs) to the area. It is understood that the Block VI developer has requested an allocation of 38 cusecs. It is assumed that this allocation of water requested by the Project from the new Vejhiar reservoir approximately 15km north east of the site does not require an extension of the study area. Vejhiar reservoir will itself be fed from the existing Chotiari reservoir by canal and pipeline.
As discussed in chapter 2, the Project is to be constructed adjacent to a large new lignite mine within Block VI. This mining operation will have a number of impacts on local water resources and flood risk as described and assessed in the mining project ESIA. When the Project and the mine are considered in combination the study area is extended to cover the mine workings or the associated mine waste water disposal facilities.
11.3.2 Desktop review Previous reports undertaken as part of the development of the Thar Coalfield and other projects in the region have been reviewed and included:
● Feasibility Study, Interim Report 5 Phase II Water Management Study for the Thar Block VI Project (SRK Consulting, 2011) including as an Annex: ● RPS Aquaterra Feasibility Study Hydrogeological Assessment Report ● RPS Aquaterra Thar Block VI water supply and disposal (February 2017) ● Block VI lignite mining project ESIA (Hagler Bailly, 2013) ● Pakistan Thar Block VI 2×330MW Coal-Electricity Integrated Project Feasibility Study (China Power, 2014) ● Thar Coal Block II Power Project ESIA (Hagler Bailly, 2014) ● Environmental and social study for Thar Coalfield (Mott MacDonald, 2013) ● Block VI Lignite mining project ESIA (Wardell Armstrong, 2016)
11.3.3 Determining significance of impacts and effects An appraisal of the water features has been undertaken through desk study to provide information against which to predict levels of potential impact and assess significance of such
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impacts. The water features which are likely to be affected by the scheme have been evaluated in terms of the short and long-term consequences to help assess the relative significance of the development (See Table 74 below). The magnitude of impact and the likely significance of any effects of the project on water features of the area have been assessed using the criteria in chapter 5.
Table 74: Water feature sensitivity criteria Sensitivity Typical characteristics Identified receptors High Surface water or groundwater body with little or no None identified capacity to absorb proposed changes or minimal opportunities for mitigation. Receptor at high risk of flooding outside normal flood plain, affecting significant region or large population Receptor used for regional water supply source or conveyance Surface water receptor at high risk of non-localised alignment change Receptor at high risk of depletion (surface waters levels falling or drying out; groundwater levels / yields falling) or pollution Large areas of soil and agricultural land use may be affected by flooding / change in hydrological conditions permanently Medium Surface water or groundwater body with some Shallow aquifer capacity to absorb proposed changes. Village wells Receptor at high risk of flooding outside normal flood Traditional water capture/storage plain, affecting a small district systems in inter-dune areas that extend Receptor used for local village water supply source seasonal water use or conveyance Surface water receptor at high risk of localised alignment change Receptor at medium risk of depletion (surface waters levels falling or drying out; groundwater levels / yields falling) or pollution Small areas of soil and agricultural land use may be affected by flooding / change in hydrological conditions permanently Low Surface water or groundwater body with considerable Deep aquifer capacity to absorb proposed changes Middle aquifer Receptor at some risk of localised flooding outside Natural ephemeral waterbodies in inter- normal flood plain, with limited local consequences dune areas for the environment Receptor used for seasonal water supply for livestock Soil and agricultural land use may be affected by flooding / change in hydrological conditions occasionally Low/ Negligible Soil and agricultural land use not sensitive to some - change in hydrological regime
Professional judgement was used to vary the predicted impact where appropriate for example where an impact of major magnitude on a highly sensitive receptor may not be of critical significance if it is considered unlikely to occur.
11.3.4 Assumptions and limitations All aspects of water use, water treatment and water discharge presented in this chapter are based on current plans available for the Project and/or for the adjacent coal mine development. These details are subject to change once the plant design is finalised.
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Since the method of disposal of waste water from the Project has not yet been confirmed, it is assumed that there will be no discharge to the environment that has not received appropriate treatment to ensure that it will meet the Sindh environmental standards for effluent discharge.
No field investigations have been carried out for this ESIA, the baseline makes use of the results of field investigations across Block VI reported in the documents set out in section 11.3.2 above.
11.4 Baseline description
11.4.1 Current baseline
11.4.1.1 Climate The Thar Desert has a semi-arid climate with between 100mm and 200mm rainfall annually; over 80% of this falls during the monsoon (mid-June to mid-September). Rainfall is variable from one year to the next - it can be as high as 500mm, but also fails once every four to six years. There have been major droughts in every decade since the 1950s typically each lasting two to three years.
The area is also characterised by extremes of temperature with the hottest period between April and June (24°C - 41°C) and the coldest between December and February (9°C - 28°C). For almost half of the year the prevailing wind direction is from the north or northeast but during the summer monsoon season the direction reverses to south-westerly and the winds become much stronger.
Table 75: Estimated mean monthly climatic parameters for the Project area Month Temperature ºC Relative Precipitation Wind humidity (%) Maximum Minimum (mm) Rain Speed Direction days (m/s) January 26.5 5.4 45.5 0.6 0.1 1.7 N February 29.2 8.7 44.5 2.0 0.3 1.9 N March 34.5 14.3 42.6 4.6 0.3 2.4 W April 39.1 20.1 42.7 3.5 0.3 3.8 SW May 41.5 24.5 46.8 3.0 0.2 5.9 SW June 39.7 27.2 56.4 19.7 0.9 5.5 SW July 36.2 26.8 67.2 79.0 3.4 5.1 SW August 34.5 25.7 70.2 74.5 3.0 4.6 SW September 35.7 23.9 64.8 23.0 1.1 3.3 SW October 37.1 18.5 50.8 2.1 0.2 1.9 SW November 33.0 11.9 44.6 3.6 0.2 1.5 NE December 28.0 6.6 46.8 0.9 0.1 1.4 NE Annual 34.5 17.8 52.1 222.0 10.0 - - Note: A day is defined as a rain day if the total amount of rainfall for that day exceeds 2.5 mm
Source: Hagler Bailly, 2013
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Table 76: Estimated mean monthly climatic parameters for the Project area Month Temperature Relative Precipitation Wind humidity (%) Maximum Minimum (mm) Rain Speed Direction days (m/s) January 26.5 5.4 45.5 0.6 0.1 1.7 N February 29.2 8.7 44.5 2.0 0.3 1.9 N March 34.5 14.3 42.6 4.6 0.3 2.4 W April 39.1 20.1 42.7 3.5 0.3 3.8 SW May 41.5 24.5 46.8 3.0 0.2 5.9 SW June 39.7 27.2 56.4 19.7 0.9 5.5 SW July 36.2 26.8 67.2 79.0 3.4 5.1 SW August 34.5 25.7 70.2 74.5 3.0 4.6 SW September 35.7 23.9 64.8 23.0 1.1 3.3 SW October 37.1 18.5 50.8 2.1 0.2 1.9 SW November 33.0 11.9 44.6 3.6 0.2 1.5 NE December 28.0 6.6 46.8 0.9 0.1 1.4 NE Annual 34.5 17.8 52.1 222.0 10.0 - - Note: A day is defined as a rain day if the total amount of rainfall for that day exceeds 2.5 mm
Source: Hagler Bailly, 2013
11.4.1.2 Hydrology There are no perennial river courses close to the Project area, although there are small ephemeral channels that capture runoff during and after large rainfall events. The runoff collects in inter-dune areas and rapidly dries out by evaporation and infiltration into the shallow aquifer.
11.4.1.3 Hydrogeology The entire Thar region is underlain by a relatively flat lying sedimentary basin that rests unconformably on crystalline basement. The generalised stratigraphic sequence is shown in Table 77; it comprises granitic bedrock, shallow marine sands and younger coal-bearing strata of the Bara Formation, alluvial deposits and dune sands.
Table 77: Summary of on-site geology Formation Age Thickness (m) Typical description name Dune sand Recent Typical: 50 m Sand, Silt, Clay Range: 30 m – 110 m Alluvial deposits Sub-Recent Typical: 80 m Sandstone, siltstone and claystone Range: 11 m – 127 m Bara formation Palaeocene to Early Range: 50 m – 150 m Claystone, shale, sandstone and Eocene coal Basement Pre-Cambrian - Granite and Quartz Diorite complex Source: SRK, 2011
Groundwater recharge is low (as a result of the low rainfall and high evapotranspiration) and there are no perennial streams. Water is scarce and the groundwater is brackish to saline. However, following monsoon rains, fresh water can accumulate in the inter-dune areas creating
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temporary fresh water ponds (termed Taraies), which provide an important short-term water supply to the local community. These monsoon rainfall events also provide recharge to the shallow and perched aquifers throughout the Thar Desert region.
Three main aquifers and two aquitards have been identified in the Thar region. These units comprise from the surface downwards an upper shallow aquifer, which is located in the base of the dune sands, a fine grained siltstone aquitard, a middle alluvial sand aquifer of sub-recent age, a claystone and lignite aquitard in the top part of the Bara Formation and a deep aquifer of marine sands belonging the bottom part of the Bara Formation.
The Shallow or Top aquifer (dune sand) is unconfined and is sustained by recharge from the surface during the monsoon rains. The mean hydraulic conductivity (K) of this aquifer is 2.6E-02 m/d (Singh et al, 2010). The saturated thickness is typically 5m, but because of the undulating nature of the erosive contact with the Sub-Recent siltstones, the incidence and thickness of this aquifer is quite patchy. The water quality is also highly variable (TDS = 1,500mg/l – 15,000mg/l) depending on the inter-connectivity of the aquifer and the frequency with which it is flushed by fresh recharge water. Despite these limitations, the dune aquifer is a very important source of water to the community for livestock and potable use.
The Middle aquifer is confined beneath the Sub-Recent siltstone. It comprises alluvial sands originally deposited in a deltaic and fluvial setting and appears to be heterogeneous and variable in thickness across the region. It is typically 5m to 10m thick, but locally may be as little as 2m. Previous studies indicate that the K of this aquifer ranges between 1.0E-03 m/d and 5 m/d (Singh et al, 2010). The water quality is brackish with a typical TDS of 5,000mg/l.
The Deep aquifer sits at the very bottom of the sedimentary sequence above the granite basement and confined below the Bara claystone and lignite horizons. It is the largest aquifer in the region in terms of thickness, lateral extent and yield, with the K ranging between 5m/d and 23m/d (Singh et al, 2010). The water quality is generally brackish to mildly saline with a TDS concentration ranging between 5,000mg/l and 10,000mg/l.
RPS Aquaterra undertook a field investigation in Thar Block VI between October 2010 and February 2011 in order to obtain site specific information on the properties of the three main aquifers.
The field programme included:
● Installation of four test and observation wells in each of the aquifers ● Test pumping of the installed test wells ● Collection of groundwater samples from each of the test wells ● Groundwater level monitoring A summary of the detailed water quality results is given in Table 78, further results are presented in SRK 2011 (SRK report Annex 1, Appendix F).
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Table 78: Summary of aquifer water quality results in Block VI Parameter Units Aquifer Deep Middle Middle Shallow SCE34_DTW SCE34_MTW SCE31_MTW SCE34_ST 1 2 W Non-metals and other species Temperature oC 37.9 33.7 33.7 33.2 Dissolved Oxygen (DO) mg/l 3.74 3.96 3.59 4.91 Odour TON 1.5 2.0 3.0 5.0 Taste - ND ND ND ND Colour PtCO 5.0 10.0 6.0 10.0 pH 7.14 6.96 6.49 6.68 Biochemical Oxygen Demand (BOD) mg/l 6.4 16.4 6.8 5.6 Chemical Oxygen Demand (COD) mg/l 14.0 42.0 17.5 12.0 Cyanide (CN) mg/l <0.001 <0.001 <0.001 <0.001 Phosphorous (P) total mg/l 0.86 0.72 0.39 2.48 Ammonia (NH 3) mg/l <0.001 <0.001 1.06 1.24 Hardness Total as CaCO3 mg/l 796 1910 1602 998 Solids Suspended Solids (total) mg/l 23.72 46.84 24.27 19.26 Total Dissolved Solids (TDS) mg/l 4,390 6,352 6,010 3,720 Electrical Conductance (EC) ms/cm 7.70 12.28 11.22 7.36 Microbiology Escherichia coli (E-coli) Cfu/ml 25 45 28 65 Major Anions Chloride (Cl-) mg/l 2,304 3,544 3,246 1,949 Sulphate (SO42-) mg/l 248 280 270 126 Carbonate (CaCO 32 -) mg/l <1.0 <1.0 <1.0 <1.0 Bicarbonate (HCO 3-) mg/l 213.8 246.0 305.0 311.0 Nitrate (NO 3-) mg/l 0.28 0.01 0.3 <0.01 Phosphate (PO 4-) mg/l 0.39 0.28 0.14 1.83 Fluoride (F-) mg/l 2.86 <0.02 0.29 1.87 Major Cations Sodium (Na+) mg/l 1347 1639 1610 976 Potassium (K+) mg/l 16.48 32.46 24.85 17.92 Calcium (Ca 2+) mg/l 152.5 348.0 336.8 198.3 Magnesium (Mg 2+) mg/l 99.6 252.0 185.2 122.7 Metals Cobalt (Co) total mg/l 0.0685 <0.01 0.0392 <0.01 Nickel (Ni) total mg/l <0.01 <0.01 <0.01 <0.01 Copper (Cu) total mg/l 0.0482 <0.01 <0.01 0.0286 Cadmium (Cd) total mg/l <0.01 <0.01 <0.01 <0.01 Lead (Pb) total mg/l <0.001 <0.001 <0.001 <0.001 Arsenic (As) total mg/l 0.003090 0.001826 0.003057 0.004716 Chromium (Cr) total mg/l 0.00998 0.01390 0.006 <0.001 Chromium ((Cr) VI mg/l 0.00475 0.01250 0.00274 <0.001 Chromium (Cr) III mg/l 0.00523 0.0014 0.00326 - Zinc (Zn) total mg/l 0.0082 0.5372 0.1793 0.0853
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Parameter Units Aquifer Deep Middle Middle Shallow SCE34_DTW SCE34_MTW SCE31_MTW SCE34_ST 1 2 W Mercury (Hg) total mg/l <0.00001 <0.00001 <0.00001 <0.00001 Boron (B) mg/l 4.6 3.85 2.8 1.26 Iron (Fe) total mg/l 6.208 1.708 0.9854 0.7099 Vanadium (V) total mg/l <0.01 <0.01 <0.01 <0.01 Selenium (Se) total mg/l <0.00001 <0.00001 <0.00001 <0.00001 Organics Polyaromatic Hydrocarbon (PAH) µg/l <0.001 <0.001 <0.001 <0.001 Cyclohexane (C 6H10 O) µg/l <0.001 <0.001 <0.001 <0.001 Hydrocarbon Extractable µg/l 0.002084 <0.001 <0.001 <0.001 Total Petroleum Hydrocarbons µg/l 0.007226 0.003182 0.009116 <0.001 Purgable Organics µg/l 0.000948 0.000417 0.001853 <0.001 Source: SRK, 2011 (RPS Aquaterra)
TDS for the Shallow Aquifer was 3,270mg/l and village wells sampled at the same time gave values ranging from 1,620 to 3,720mg/l. the aquifer is brackish and slightly less saline than the regional values reported by Singh (Singh et al, 2010).
TDS for the two Middle Aquifer boreholes were 6,010mg/l and 6,352mg/l, indicating that this aquifer is slightly saline.
TDS for the Deep aquifer was 4,390mg/l indicating that this aquifer is brackish.
11.4.1.4 Flood risk Whilst the Project site has an arid climate and no perennial watercourses, the area can receive significant storm rainfall during the summer monsoon season. The flood runoff collects in inter- dune areas and is soon lost to evaporation and infiltration.
In 2011 Sindh, and particularly the Thar Desert, experienced an extreme monsoon as shown in Table 79, the season total of 1,348mm at Mithi and 552mm at Chhor set new records 32 . The table demonstrates that July was much drier than normal but the rest of the season was unusually wet.
Table 79: Monsoon rainfall in Thar Desert (mm) in 2011 Parameter Badin Chhor Mithi 1931-2011 1931-2011 2004-2011 July ● Actual 31.4 8.0 9.0 ● Normal 67.6 79.3 78.2 ● Highest 302.9 (2003) 354.3 (2003) 303.8 (2009) August ● Actual 331.2 276.0 562.8* ● Normal 92.5 69.3 150.7 ● Highest 459.0 (1979) 356.1 (1990) 346.3 (2006)
32 Arif Mahmood, Nadeem Faisal and Akhlaq Jameel (Jan, 2012), Special Report on Pakistan ‟s Monsoon 2011 Rainfall, Pakistan Meteorological Department, Ministry of Defence, Government of Pakistan.
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Parameter Badin Chhor Mithi 1931-2011 1931-2011 2004-2011 September ● Actual 284.0 268.0 776.1* ● Normal 27.1 37.3 58.6 ● Highest 347.7 (1970) 381.6 (1998) 220.0 (2006) July-September ● Actual 646.6 552.0* 1347.9* ● Normal 187.2 185.9 287.5 ● % Departure 245% 366% 369% ● Highest 806.3 (1994) 521.0 (2003) 669.8 (2006) * New record, Normal=1961-1990 or averaged over the available record.
Source: Arif Mahmood et al., 2012
Figure 22 shows the pattern of daily rainfall over the 2011 monsoon season at Mithi. Three days recorded totals close to or above 300mm.
Figure 22: Maximum rainfall in any 24 hour period Mithi meteorological station – July, August and September 2011
Source: Hagler Bailly Pakistan, 2013
There is no monitoring of local storm runoff in the Project area to inform the design of flood protection measures for the Project.
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11.4.1.5 Water use Village settlements abstract (pump/draw) water from hand dug wells, tapping the Top (Dune Sand) aquifer, across the Thar Desert region. The volume of water abstracted is generally relatively small and is used to meet drinking water requirements as well as all other daily domestic water needs.
SRK report anecdotal evidence from the local villagers in the Block VI area which suggests that village wells within Khario Jani, Ranjhan Noon and Singhario abstract approximately 4,000- 7,500 litres per day from each active hand dug well. It is reported that approximately 100 to 150 bucket loads (each bucket has a 40-50 litre capacity) are removed from each well per day, but that the well goes dry after taking approximately 50 to 60 bucket loads continuously and needs to be rested for two to three hours to allow water levels to recover prior to resuming pumping. SRK report describes that local villagers suggest that water quality in the village wells improves following significant rainfall events reflecting rapid recharge.
The SCA has a number of active and proposed wells abstracting water from the Deep Aquifer across the region. The water abstracted is treated by the RO plant and used to meet municipal drinking water supply requirements. There is one such deep well and RO plant currently in operation in Islamkot.
11.4.2 Future baseline Committed development As discussed in chapter 2, the Project is to be constructed adjacent to a large new coal mine within Block VI. This mining operation will have a number of impacts on local water resources and flood risk as described and assessed in the mining project ESIA (Hagler Bailly, 2013, Wardell Armstrong, 2016). Key impacts of relevance to the Project are:
● Localised disruption of surface drainage pattern changing spatial characteristics of storm runoff ● The impact of dewatering on groundwater flow and levels in the zone of influence of the mining operation creating a cone of depression centred on the pit affecting groundwater levels up to 1km away ● Impact of disposal of dewatering volumes on Shallow aquifer water levels and quality at the discharge location – a location sufficiently distant and hydraulically down gradient from the dewatering operations not to create cycling of water ● Resettlement of villages, loss of historic agricultural lands and destruction/abandonment of wells leading to new patterns of water usage by the local community based on supply from the mine ● Creation of a new lined landfill for hazardous waste. The proposed Block VI coal mine will form part of the baseline for the operation of the Project. The potential cumulative effects arising from the adjacent mine workings in relation to water resources and flood risk have been considered as part of this assessment of the construction and operation of the Project.
Climate change Current projections to the 2080s indicate that climate change may affect the future baseline against which the impacts of the Project on surface water and groundwater resources have been assessed. There may be changes in the flow and water quality characteristics of surface water and groundwater bodies as a result of changes in climate.
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Current projections indicate that there will be more variability in the monsoon season affecting the start date, the overall duration, the daily and monthly distribution and thus greater inter- annual variation. The probability and severity of surface water flooding could therefore increase leading to more recharge to shallow groundwater and an improvement in water quality (lower salinity). Conversely the frequency and severity of failures of the monsoon could increase leading to reduced recharge and poorer water quality. Given the current high variability of rainfall, these changes are not considered to result in significant changes to the reported effects from the Project.
11.4.2.1 Hydrogeology – future situation To extract coal safely the open pit must be kept dry (dewatered). The dewatering volume will increase over time as the open pit grows in size and is predicted to result eventually in a cone of depression in groundwater levels extending up to 1km from the pit.
One of the challenges facing the mining project is what to do with the large volumes of groundwater that will be produced by the dewatering operation. The water must be disposed of in such a way that it cannot re-enter the dewatering area, represented by the area of the cone of depression around the pit. As this ‘mine floodwater’ is a composite of captured flows from the three aquifers it will also have poor water quality compared to the Shallow Wquifer receptor for these discharges if they were to be disposed to ground by infiltration. The Sindh standards specifically forbid the blending of effluent to improve its quality.
Investigations undertaken to date identify that between 2,000-3,000 litres per second of water may be produced from dewatering of the mine, although this may be affected by dewatering activities at adjacent blocks. Whilst some water will be required for the Project and mine, there will be a significant surplus. A feasibility study undertaken by RPS Aquaterra identified four options, which are presented in Table 80 along with the conclusions of the feasibility study.
Table 80: Surplus water disposal options Water disposal option Feasibility study conclusions Construction of a soakaway and / or evaporation pond There is insufficient space available on Block VI for the construction of soakaways and / or evaporation ponds. Reinjection of the surplus water into the third aquifer some Reinjection would require a large area of land away from the distance from Block VI. Block and its feasibility is unknown. The cost of reinjection would be considerable more than the cost of the original dewatering/depressurisation pumping. The long-term efficiency of a reinjection wellfield would not be guaranteed Disposal of the water to a remote reservoir (yet to be This option would require a separate environmental and social constructed and the responsibility of the Government of Sindh), impact assessment to be completed. south of the block blocks adjacent to the Rann of Kutch. Utilisation of some water for agriculture either with or without There is some scope for this option. An area of 84km 2 could be treatment. irrigated based on the estimated dewatering rates. It was identified that irrigation would generated some return water which would require management. Source: RPS Aquaterra, 2017
All mine floodwater for disposal to ground and thus to the Shallow aquifer will be pre-treated by RO to reduce its salinity sufficiently to meet the NEQS.
The Project will use mine flood water as its main source of supply, but there is also a proposal to bring surface water from the Indus River system by way of the Nara Canal, Chotiari Reservoir, a new canal and pipeline, and a new reservoir (Vajihayr Reservoir). This long distance transfer is small (0.85 m 3/s) but any disposal to ground by the Project of waste water
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from this fresher water source will have an impact on the existing Shallow aquifer conditions particularly in the non-monsoon period.
11.4.2.2 Water use – future situation The coal mine project will resettle the inhabitants of the villages directly affected by the mine workings. The resettlement will include provision of new, better quality water supply for domestic use and for some agricultural uses (livestock watering). For the future baseline, it is therefore assumed that there will be no communities depending on Shallow groundwater for domestic use within the study area for the Project.
11.5 Impact identification and assessment
11.5.1 Construction impacts
11.5.1.1 Overview This section presents the identification and assessment of the following potential impacts of the Project during the construction phase based on the description of the proposed construction activities given in section 2.4. Construction impacts will include:
● Abstraction of water for construction camp and for use in construction (concrete batching plant, vehicle washing, dust suppression, etc) ● Disruption of local drainage network by earthworks ● Mobilisation of sediment from earthworks and stockpiles to ephemeral surface water features impacting water quality ● Contamination arising from inadequate treatment and disposal of waste and wastewater from work compounds and yards ● Spillage of oils and chemicals, including cement, in relation to groundwater and surface water Temporary facilities for water supply and waste water treatment will be provided for the power plant (see section 2.4) while the permanent works are being constructed and commissioned.
11.5.1.2 Water use by the Project during construction Water will be obtained from the adjacent mine development – initially from a purpose drilled borehole in the Deep aquifer and, from the end of year 1 or 2 of the mine development, from dewatering wells and sumps. It is understood that the mine dewatering system will consist of boreholes drilled to capture water from the Shallow, Middle and Deep aquifers – the proportions coming from each aquifer will vary over time as the pit deepens. Except where it will be used for dust suppression all groundwater will need to be treated before use because of poor water quality (high salinity). Depending on the sequencing of construction activities at the mine and for the Project it may be necessary to provide bottled water for the construction workforce for a period before groundwater treatment is commissioned on site.
The mine will resettle local villages in Block VI providing them with an alternative water supply to their existing use of the Shallow aquifer and ephemeral surface water bodies.
During the construction phase, the Project water requirement is expected to be smaller than the dewatering volume necessary to allow development of the coal mine over the same period so the mine will have to dispose of the excess. The Developer intends to install an early dewatering well which would provide raw water for the mine and power plant and an RO plant to provide
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potable water for the mine accommodation. During the construction phase of the Project, there will be some lowering of existing water levels in the Shallow aquifer close to the pit due to the mine dewatering.
The Shallow aquifer is categorised as medium sensitivity, the magnitude of the impact attributable to the Project during construction is negligible resulting in a negligible impact, which is not significant.
The Middle aquifer is the most saline of the three and is categorised as low sensitivity, with a negligible magnitude resulting in a negligible impact, which is not significant.
The Deep aquifer is a very large waterbody of relatively poor water quality as such it is categorised as low sensitivity. During construction, abstraction from this resource is assessed to be negligible magnitude resulting in a negligible impact, which is not significant.
Based on the findings of the mine ESIA (Hagler Bailly, 2013, Wardell Armstrong, 2016) the mine activities within Block VI development are also deemed not to have a significant impact on water resources during the period of construction for the Project.
11.5.1.3 Storm drainage and flood risk Construction of the Project infrastructure will require earthworks that will change the micro- topography and local drainage patterns which are generally aligned draining from northeast to southwest. The temporary freshwater ponded areas have been classified into two types depending on whether they have been modified by traditional water capture systems or are natural. The former are treated as of higher sensitivity/value in the current baseline but are considered medium when their role in community water supply is reduced by the mine resettlement programme, the natural areas are categorised as low. The magnitude of construction impacts on both types is considered to be minor. The resulting impact of construction is a minor adverse impact for the natural areas and moderate adverse for traditional water capture systems (and is therefore significant).
11.5.1.4 Contamination of shallow aquifer During construction of the Project infrastructure, there is the potential for incidents leading to contamination of the underlying Shallow aquifer. The main risks to water quality arising from construction activities relate to direct discharges or potential spillage of fuels, lubricants, concrete spills and chemicals from the construction site and the inadequate treatment and disposal of waste and wastewater from work compounds.
The Shallow aquifer has been classified as a medium sensitivity/value receptor. The magnitude of construction impacts is considered to be minor adverse, resulting in an minor adverse impact and therefore is no significant.
11.5.2 Operational impacts The operation of the Project will include a number of activities that have the potential to impact on the water environment. These include:
● Impact on water resources of supplying industrial and domestic water needs ● Discharge arrangements for storm water runoff ● Disposal of brines from RO plant, and disposal of waste water from industrial processes where not recycled within the Project ● Acid leachate from fly ash dump
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● Disposal of sewage and domestic waste water (kitchens, laundry, etc) ● Fire fighting system and disposal of contaminated fire water after use
11.5.2.1 Operational water usage The Project, as described in chapter 2, will have two sources of raw water:
● Groundwater abstracted from the Deep aquifer or delivered from the mine dewatering system (and therefore coming from a combination of Top, Middle and Deep aquifers) ● Transfer from the Indus River via the Nara Canal, Chotiari Reservoir, and Vejhiar Reservoir The main source will be groundwater based on a supply from the adjacent mine dewatering system supported by direct abstractions. The water is saline and requires pre-treatment. The proposed pre-treatment in the raw water treatment plant is RO. Water for domestic use is to be further treated by activated carbon filtration and disinfection to meet drinking water standards.
During normal operation, the total consumption for the plant and associated domestic requirements has been estimated as 1,861 m 3/hr of which some 105m 3/hr will be internally recycled within the Project site leaving an operating water demand of 1,756m 3/hr (0.49m 3/s). A consumption of 1,756m 3/hr equates to 15 million m 3 per annum. The raw water treatment plant will have a capacity to treat 1,756m 3/hr.
Table 81: Water balance for the Project in operation No Item Water Reclaimed Water requirement water (m 3/hr) consumption (m 3/hr) (m 3/hr) 1 Cooling tower evaporation loss 1,160 0 1,160 2 Cooling tower drift loss 38 0 38 3 Blowdown losses of cooling water system 349 63 286 4 Boiler make-up water treatment system 45 8 37 5 Water for oil area 2 1 1 6 HVAC system make-up 15 0 15 7 Vehicle wash water 3 2 1 8 Turbine house wash water 3 2 1 9 Boiler house wash water 3 2 1 10 Cooling water for hydrogen generator station 20 20 0 11 Moistening water for dry ash 20 0 20 12 Bottom ash system make-up water 10 0 10 13 Coal dust suppression 31 0 31 14 Spray water for ash disposal area 10 0 10 15 Raw water treatment plant 85 0 85 16 Industry waste water treatment system 1 0 1 17 Oily waste treatment system 1 0 1 18 Potable water system 10 7 3 19 Sanitary sewage treatment system 1 0 1 20 Greening water for plant area 6 0 6 21 Unforeseen consumption 48 0 48 TOTAL 1,861 105 1,756 Source: China Power, 2014
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The main use of water is for cooling. The design incorporates a natural draft cooling and circulating system. The system is capable of circulating some 25m 3/s. Evaporation losses from the cooling towers are estimated to be 1,160m 3/hr with an additional drift loss of 38 m 3/hr. It is estimated that a further 286m 3/hr is lost to blowdown procedures, this is not lost to evaporation but is separated such that 63m 3/hr is recycled and the rest passed to the central monitoring basin and waste outfall.
Process water will be recycled and a proportion diverted to the coal storage yard and ash disposal area for dust suppression.
During the operation phase, cooling losses will account for 68% of the Project’s total consumption or around 10 million m 3/annum. This evaporation is a loss of water resources from the three aquifers, however without detailed modelling of the mine dewatering as the pit develops it is impossible to quantify the proportion of the Project raw water supply coming from each of the aquifers at any particular time over the operational lifetime of the Project. During monsoon rains the proportion coming from the Shallow aquifer will increase, with some contribution from rainfall collected by the pit drainage system. In years when the monsoon fails the Shallow aquifer will make a limited contribution.
The dewatering volume will increase over time as the open pit grows in size and is predicted to result eventually in a cone of depression in groundwater levels extending up to 1km from the pit. During the operation phase of the Project, water levels in the Shallow aquifer close to the pit will be maintained at the minimum due to the mine dewatering. Arrangements for final disposal of the mine and Project waste waters is yet to be determined by the Government of Sindh but if to the Shallow aquifer, this would be over 1km away from and hydraulically down gradient of, the pit.
The net change in aquifer volume would therefore still be relatively small compared to the overall resource of the Shallow aquifer in the Thar Desert.
The Shallow aquifer is categorised as medium sensitivity, the magnitude of the impact attributable to the Project during operation is minor and therefore the impact is assessed as of minor significance and therefore is not significant.
The Middle aquifer is categorised as low sensitivity due to high salinity, with a negligible magnitude on the regional aquifer the operation phase impact attributable to the Project is assessed negligible and therefore is not significant.
The Deep aquifer is a very large waterbody of relatively poor water quality as such it is categorised as low sensitivity. During operation, abstraction from this resource is assessed to be negligible magnitude and the impact is assessed as negligible and therefore not significant.
Based on the findings of the mine ESIA (Hagler Bailly, 2013, Wardell Armstrong, 2016), the Block VI development is also deemed to have an impact on water resources of minor significance during the period of operation for the Project.
11.5.2.2 Disposal of waste waters The main sources of waste water are:
● Brine from the RO plant processing the raw water supply from the mine ● Sewage effluent ● Drainage from the coal storage yard ● Wash water from various operations within the plant frequently contaminated by oils and grease
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● Drainage from roads and hard standing including refuelling area If these waste streams were allowed to discharge directly to ground and then into the Shallow aquifer untreated there would a slight beneficial impact in terms of the net abstraction but an adverse impact in terms of water quality. The Shallow aquifer is categorised as medium sensitivity, the magnitude of the impact attributable to the Project during operation is moderate adverse, resulting in a moderate adverse impact, and is therefore considered as significant. Natural ephemeral surface waterbodies are categorised as having low sensitivity, the magnitude is assessed as minor adverse resulting in a negligible impact, which is not significant.
As part of a strategic approach to the Thar Coalfield, the Government of Sindh and the Sindh Engro Coal Mining Company are developing an effluent pipeline (capacity 50 Cusecs) is under construction from Block II to a location some 32km to the south of Islamkot at Gorano where a reservoir is being constructed to receive the waste water. There is no outfall planned for this Reservoir. To date, it is understood that approvals are outstanding for the works but it is expected that all blocks within the Coalfield will utilise this provision from the Government of Sindh. The Government of Sindh, as developer of this infrastructure would be responsible for understanding an assessment separate to this ESIA and obtaining the necessary approvals.
11.5.2.3 Potential pollution A number of chemical processes are required in order to bring the raw water to the necessary standard for different uses within the plant and for the treatment of waste water streams from these different uses to prepare for recycling within the Project or for discharge. Some of these chemicals are hazardous (eg hydrochloric acid, sodium hydroxide, hydrazine) and their storage and handling presents a risk of a pollution incident that would affect the shallow aquifer beneath the site.
The plant will generate large quantities of fly ash. Exposure to rainfall or to water applied for dust suppression will lead to acid leaching of saline percolates and metals from the fly ash deposits, this seepage could affect the quality of the underlying Shallow aquifer.
The plant has been designed with a comprehensive monitoring and fire response system. In the event of a fire there is a pollution risk to the Shallow aquifer from the use of fire retardant/suppression chemicals infiltrating the ground during and after fire incident.
The Shallow aquifer is categorised as medium sensitivity, the magnitude of the impact attributable to the Project during operation is minor and therefore the impact is assessed as of minor significance and not significant. Natural ephemeral surface waterbodies are categorised as low sensitivity, the magnitude is assessed as minor adverse resulting in a negligible impact and thus, not significant.
11.5.3 Decommissioning phase On closure of the Project and closure of the mine, abstractions from the three aquifers would cease and this would lead to a recovery in water levels in the previously dewatered area around the pit.
Other potential impacts are similar to those in the construction phase and relate to possible contamination during decommissioning and demolition works.
There is a potential for impacts to natural ephemeral surface water bodies and the Shallow aquifer if the mine landfill or the fly ash deposit deteriorate once active management ceases such that contaminated seepage can reach these receptors.
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11.5.4 Cumulative impacts Other blocks have been identified for coal mining in the Thar Coalfield. The development of these other blocks are individually likely to have impacts on the surface water and aquifer systems similar to those of the mine and power station proposed for Block VI. How similar will depend on the mining approach and power generation and cooling technologies chosen for each block.
The three aquifers (Top, Middle and Deep) are regional in extent underlying the Thar Desert so cumulative impacts are inevitable if all the blocks are developed. Much depends on the timing of each block’s development and the period over which all six might be operating simultaneously.
The strategic studies for the That Coalfields have identified the need for a regional water resources study with detailed groundwater modelling to allow cumulative impacts on water resources to be assessed under different coal block development scenarios. The Government of Sindh is preparing a water management plan for the Thar Coalfield. Their studies will establish the baseline for all water resource across the whole area and then will model all new developments to assess the cumulative changes in water use and potential impacts on water resources both quantity and quality. The water management plan will contain all the measures to be taken to minimise potential impacts area-wide.
11.6 Mitigation and enhancement measures
11.6.1 Avoidance measures incorporated in project design The design of the Project has taken into account issues of sustainable water management and minimising flood risk in particular:
● Use of mine flood water (dewatering) as main source of supply ● The selection of closed-cycle cooling system with natural draft cooling towers over alternatives (refer to chapter 3) to minimise water requirements ● Treatment of mine floodwater by reverse osmosis prior to use as process water and domestic supply ● Dust from the two coal storage yards will be controlled by a permanently mounted water sprinkler system using recycled process water ● Water drainage system including treatment will be provided in the coal yards and the ash disposal facility ● Provision of Project sewage treatment plant and oily waste water treatment ● Provision of storm drainage ditches and infiltration areas to divert storm runoff away from the Project site and maximise recharge to the Shallow aquifer away from the cone of depression created by ongoing mine dewatering Facilities incorporated in the Project design will ensure that all waste water to be discharged to the natural environment meets the NEQS requirements. The Project drainage system will also prevent the discharge of any contaminated runoff, whether from storm rainfall or from a fire incident, to the environment without passing through the Project waste water treatment facilities.
The Government of Sindh has responsibility for the final discharge of waste waters from all development blocks in the Thar Coalfield. Arrangements for disposal are not yet agreed for Block VI. The Government of Sindh is proposing a 50 cusec capacity channel to take waste water from the adjacent Block II towards the south, so potentially some or all of the Block VI waste water could be disposed of via this channel.
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11.6.2 Generic mitigation measures Best practice hazardous materials storage, handling and use will be employed in both the construction and operation of the Project. This will include the following:
● Bunding of storage areas to contain any spills and provision of spill kits for clean up ● Vehicle and equipment fuelling to only be undertaken in designated areas on impermeable surfaces with adequate spill protection in place ● Training of workforce on correct handling of hazardous materials and response in case of an incident Further details are given in the accompanying ESMP (Volume IV).
11.6.3 Proposed monitoring Monitoring is designed to:
● Provide the basis for ongoing impact management during the construction, operation and decommissioning phases ● Involve assessment of compliance and adherence to environmental standards and guidelines ● Establish the effectiveness of the prescribed mitigation measures and the occurrence and magnitude of impacts ● Provide an `early warning ‘system for harmful trends In particular, the monitoring is a requirement of the NEQ Self-Monitoring and Reporting by Industry Rules (see section 11.2.1).
The Project includes a laboratory for chemical testing during the operation phase.
In the operation phase all discharges to the environment will be regularly sampled at the outlet of the relevant waste treatment facility to confirm compliance with the NEQS. Where appropriate the monitoring should be continuous, for example for pH and conductivity. For parameters requiring laboratory analysis the sampling interval may range from daily to weekly.
11.7 Residual impacts Table 82 and Table 83 summarise the assessment with and without mitigation in the construction and the operation phases.
Without mitigation, most of the Project’s impacts are considered to be not significant (minor and negligible) because of the poor quality of the aquifer resources.
The most significant impact is that on the local villages whose fields and wells will be occupied by the Project and the adjacent mine, however, as they will be resettled with a replacement water supply which will be more reliable and better quality, the impact on their water use after mitigation is assessed as being negligible and therefore not significant.
11.7.1.1 Construction phase During construction water requirements for the Project will be low and met from several sources in small quantities (bottled water, Deep aquifer borehole, dewatering from the Shallow and Middle aquifers), and resettlement with replacement water supplies by the mine, will minimise the overall impact. All potential construction impacts will be prevented and mitigated by the
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effective implementation of industry standard practices for safe environmental management and pollution control on construction sites.
Consequently, the impact on water resources and flood risk attributable to the Project during the construction phase is deemed to have a negligible significance. The impact from the Block VI development is deemed to be not significant.
11.7.1.2 Operation phase The Project has adopted water minimisation technologies and recycling for generation processes and cooling leading to reduced raw water requirement. Supply is 1,756m 3/hr of which 1,198 m 3/hr will be lost by evaporation and drift from the cooling tower. Waste water treatment is comprehensive and no discharges will be made to the ground or Shallow aquifer without prior treatment to achieve NEQS standards. Hazardous waste such as brine from the RO plant will be disposed of in the lined hazardous waste landfill to be built by the mine.
Consequently, the impact on water resources and flood risk attributable to the Project during the operation phase will have a minor adverse impact on the Shallow aquifer and therefore is not significant .
11.7.1.3 Decommissioning phase All potential decommissioning impacts will be prevented and mitigated by the effective implementation of industry standard practices for safe environmental management and pollution control on construction sites.
Consequently, the impact on water resources and flood risk attributable to the Project during the decommissioning phase is deemed to be not significant.
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Table 82: Summary of Project impacts on water resources and flood risk before and after mitigation Receptor Potential impacts Sensitivity Impact Impact Mitigation Residual magnitude evaluation impact evaluation and significance Construction Shallow aquifer The mine flood water supplied as raw Medium Negligible Negligible None Negligible, not water to the Project will contain some significant water from the Shallow aquifer
Disposal of waste water into aquifer Medium Minor Minor Treatment to meet NEQS prior to disposal Negligible, not significant Contamination caused by Medium Minor Minor GIIP for incident response and clean up Negligible, not spills/leaks/fire incidents significant Middle aquifer The mine flood water supplied as raw Low Negligible Negligible None required Negligible, not water to the Project will contain some significant water from the Middle aquifer Deep aquifer Water supplied from the mine as raw Low Negligible Negligible None Negligible, not water to the Project is largely drawn significant from the Deep aquifer Disposal of waste water into aquifer Low Negligible Negligible Treatment to meet NEQS prior to disposal Negligible, not significant Natural ephemeral Loss of sites – built over or cut off from Low Moderate Minor Construct new drainage channels and Negligible, not waterbodies in inter-dune storm runoff by new diversion infiltration areas to divert storm runoff significant areas channels around the Project site and to maintain recharge to Shallow aquifer and continue provision of pools for wildlife and livestock watering. Disposal of waste water Low Minor Negligible On site drainage designed for complete Negligible, not separation of clean storm water and waste significant water. Treatment of waste water to meet NEQS prior to disposal. Contamination caused by Low Minor Negligible GIIP for incident response and clean up Negligible, not spills/leaks/fire incidents significant Traditional water Loss of sites – built over or cut off from Medium Moderate Moderate Village resettlement and provision of Negligible, not capture/storage systems storm runoff by new diversion compensatory replacement water supply significant in inter-dune areas that channels by the mine mean loss of any such extend seasonal water systems on the Project site is either fully use addressed by the mine mitigation or will be compensated by the Project. Source: Present study
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Table 83: Summary of Project impacts on water resources and flood risk before and after mitigation Receptor Potential impacts Sensitivity Impact Impact Mitigation Residual magnitude evaluation impact and significance Operation Shallow aquifer The mine flood water supplied as Medium Minor Minor None Minor, not raw water to the Project will significant contain some water from the
Shallow aquifer Disposal of waste water into Medium Moderate Moderate Treatment to meet NEQS prior to disposal Negligible, not aquifer significant Contamination caused by Medium Minor Minor GIIP for incident response and clean up Negligible, not spills/leaks/fire incidents significant Middle aquifer The mine flood water supplied as Low Negligible Negligible None required Negligible, not raw water to the Project will significant contain some water from the Middle aquifer Deep aquifer Water supplied from the mine as Low Minor Negligible None Negligible, not raw water to the Project is largely significant drawn from the Deep aquifer Disposal of waste water into Low Minor Negligible Treatment to meet NEQS prior to disposal Negligible, not aquifer significant Natural ephemeral Loss of sites – built over or cut off Low Moderate Minor Construct new drainage channels and infiltration Negligible, not waterbodies in inter- from storm runoff by new diversion areas to divert storm runoff around the Project significant dune areas channels site and to maintain recharge to Shallow aquifer and continue provision of pools for wildlife and livestock watering. Disposal of waste water Low Minor Negligible On site drainage designed for complete Negligible, not separation of clean storm water and waste significant water. Treatment of waste water to meet NEQS prior to disposal. Contamination caused by Low Minor Negligible GIIP for incident response and clean up Negligible, not spills/leaks/fire incidents significant Traditional water Loss of sites – built over or cut off Medium Moderate Moderate Village resettlement and provision of Negligible, not capture/storage systems from storm runoff by new diversion compensatory replacement water supply by the significant in inter-dune areas that channels mine mean loss of any such systems on the extend seasonal water Project site is either fully addressed by the mine use mitigation or will be compensated by the Project. Source: Present study
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12 Landscape and visual
12.1 Overview This chapter considers the potential landscape and visual impacts associated with the construction and operation of the Project. The purpose of the landscape and visual assessment is to recognise, understand and interpret the character and value of the landscape setting of the Project. The assessment identifies the predicted impacts of the proposed project design on the landscape resource and views and assesses their significance.
12.2 Assessment methodology Landscape and visual impacts associated with the Project which could potentially result in effects on sensitive receptors, have been assigned significance based on the overarching framework presented in chapter 5. Specific magnitude and sensitivity criteria for landscape and visual impacts are presented in Table 84 to Table 86.
The methodology for the landscape and visual impact assessment (LVIA) was developed using the IUCN guidance document “Environmental Impact Assessment Guidance for Coal Fired Power Plants in Pakistan” (EIAG) published in 2014 and ‘Guidelines for Landscape and Visual Assessment’ (GLVIA) produced by the Landscape Institute (LI) and Institute of Environmental Management and Assessment (IEMA) in 2013 (Third Edition) which is recognised as good practice.
This assessment is based on the review of existing mapping, field surveys, baseline site photography and aerial imagery.
12.2.1 Landscape The baseline study identified the existing character of the landscape, its constituent elements, features and its geographical and historical context. It assesses the condition of the landscape, the way it is experienced, the value attached to it and its susceptibility to change.
The evaluation of the sensitivity of the landscape resource is based on factors and attributes which affect the value of the landscape and its susceptibility to the type of change arising from the proposed development. These criteria are set out in Table 84.
Table 84: Landscape sensitivity criteria Sensitivity Criteria Examples High National designation or importance Protected landscape recognised by international and national designation, reflecting aesthetic, cultural or religious significance. A landscape with high wilderness quality and limited human activity. A high susceptibility to change due to the type of development proposed. Medium Regional – locally important Areas of open landscape with some human activity evident. landscapes or features Regionally or locally important, may be designated reflecting aesthetic, cultural or religious significance. A moderate susceptibility to change due to the type of development proposed. Low Common or degraded landscapes Areas of urban influences or uncontrolled development in the landscape. A low susceptibility to change due to the type of development proposed. Source: Mott MacDonald 2016
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12.2.2 Visual amenity In accordance with the outline methodology in GLVIA, the baseline study identifies the people who might be affected by the Project within the study area. The sensitivity of different visual receptors varies according to the interest they take in their visual environment, their distance from the site, viewing opportunity and the duration of the view. Visual receptors are categorised into groups reflecting their proximity to the site and viewers’ expectations, as set out in below Table 85.
Table 85: Criteria for assessing visual sensitivity Visual receptors Sensitivity Residents of local settlements with direct views towards the Project area. Visitors to High internationally and nationally recognised landscapes, cultural and religious sites Local people working in predominantly outdoor occupations (such as farmers or herders). Medium Residents of local settlements with partially screened views towards the Project area. Travellers through the area Low Source: Mott MacDonald 2016
12.2.3 Identification of potential impacts Impacts on the landscape resource may arise from changes to overall landscape character or to individual elements or features. Factors that may affect the magnitude of change to the landscape resource and visual amenity include:
● The extent of the loss of existing landscape elements and change to the view due to the loss/addition of features ● The degree to which aesthetic or perceptual aspects of the landscape are altered by the introduction of new landscape components ● The scale and appearance of the proposed power plant and the degree of contrast/integration with the existing view ● The scale of the geographical area affected by the Project ● The distance of the visual receptor from the development and the angle/position of view ● The duration and reversibility of the impact The impact magnitude criteria are identified in Table 86.
Table 86: Landscape and visual magnitude criteria Magnitude Criteria High Total loss or fundamental alteration to key landscape elements and key views and/or addition of new features that substantially alter the character of the landscape, visual amenity and views. Medium Partial loss or alteration to key landscape elements and key views and/or addition of new features that form prominent new elements that are largely characteristic of their setting, but alter the character of the landscape, visual amenity and views. Low Minor loss or alteration to landscape elements and key views and/or addition of new features that form largely inconspicuous elements in the landscape, resulting in a detectable change in the character of the landscape, visual amenity and views. Negligible No change to, or very minor loss of landscape elements and key views and/or additions of new features that do not alter the character of the landscape, visual amenity and views. Source: Mott MacDonald 2016
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12.2.4 Significance of impacts In accordance with the outline methodology in GLVIA, effects are evaluated by combining the assessment of both magnitude and sensitivity and by using the impact evaluation matrix presented in Table 87. This impact evaluation matrix has been adapted for the LVIA and is based on the matrix included in chapter 5. Those effects that are moderate or major are significant effects. Impacts are beneficial, adverse or neutral.
Table 87: Impact evaluation matrix adapted for the LVIA
Magnitude
Adverse Beneficial
High Medium Low Negligible Low Medium High Major/ Moderate/ Minor/ Moderate/ Major/ High Major Major Moderate Minor Negligible Minor Moderate Major/ Major/
Sensitivity Sensitivity Medium Moderate Minor Negligible Minor Moderate Moderate Moderate
Moderate/ Moderate/ Minor/ Minor/ Moderate/ Moderate/ Low Negligible Minor Minor Negligible Negligible Minor Minor Minor/ Minor/ Negligible Minor Negligible Negligible Negligible Minor Negligible Negligible Source: Mott MacDonald 2016
12.2.5 Assumptions and limitations
12.2.5.1 Assumptions concerning the baseline environment Where appropriate, visual receptors were grouped rather than identified individually for the purposes of the assessment.
It has been assumed that the Kharo Jani settlement will have been resettled prior to the commencement of construction activities for the Project.
12.2.5.2 Assumptions concerning the prediction of impacts In quantifying impacts, the assessment process aims to be as objective as possible. However, whilst in some instances changes to a view can be factually defined, or direct loss of features quantified, the evaluation of landscape character and visual impact frequently requires qualitative judgements to be made. This is generally considered acceptable if based on 'professional expertise', supported by clear evidence, reasoned argument and informed opinion. The conclusions of this assessment combine objective measurement with informed professional interpretation.
12.2.6 Area of influence The modeled zone of theoretical visibility (ZTV) was used to establish the spatial scope of the study area and as a tool for assessing the visual impact following both EIAG and GLVIA guidelines. The ZTV is defined as the approximate area from which the Project will be theoretically visible from the eye level of a person standing on the ground. The ZTV was generated using a viewshed analysis generated by modelling the potential visibility of the Project elements within a 30km radius from the Project. This approach is based on best practice
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guidance for assessing the visual impact of tall elements in the landscape from Scottish Natural Heritage 33 . As the viewshed analysis was based on the ‘Bare Earth Model’ it is recognised that the initial ZTV will define a more extensive area of theoretical visibility than would be experienced in the field as built elements and existing tree cover will screen some views.
The south west – north east alignment of the prominent sand dunes contains the theoretical visibility of the Project as indicated in the ZTV illustrated in Figure 35. The ZTV was modelled using ESRI’s ArcGIS for Desktop ArcMap 10.4 Application. A viewshed analysis was undertaken using the visibility tool in ArcMap. Each cell or pixel within the raster digital terrain Model (DTM) is assessed for visibility to each point feature of a structure and is given a value representing the number of points it can see. The result is a colour map of areas where structures are predicted to be visible or not. The data used for the analysis is the SRTM Global 1 Arc-Second dataset. The analysis carries assumptions as follows:
● Bare Earth Model was used - topography of the underlying terrain without trees, buildings, or other features ● 30km Visible Range - the distance at which visibility modelling has been considered sufficient and stopped ● Observer Height at 1.5 metres -the assumed average eye-level height of an observer. ● Refractivity Coefficient 0.13 -The coefficient describing the light refracting properties of the atmosphere ● Curved Earth - the model accounts for the curvature of the earth Point Features - the structure outlines are represented by points along their footprint with 5m spacing. Structures are assumed to have flat tops
12.2.7 Temporal scope The temporal scope of the assessment assesses site preparation and construction of the Project (both assessed under the ‘construction’ phase which is expected to be approximately 40 months in total) and operation which will be for a minimum of 30 years. The base case year is assumed to be 2017.
12.3 Baseline description
12.3.1 Overview This section presents the baseline characterisation of the landscape and visual amenity of the Project area to enable comparison of the current situation with changes anticipated to the landscape character and visual amenity of the area as a result of the Project. Key sources of baseline information include a number of secondary resources, including studies undertaken for the Block VI mine and the plant in Block II. In addition, aerial photography has also been used to inform the assessment. A field survey was undertaken by a Mott MacDonald specialist to supplement and support the secondary data. No landscape character assessment data is available at national, regional or local level.
There are a number of small villages and settlements throughout the Project study area located both inside and outside Block VI. Located within Block VI are the small villages of Salar Ji Dhani, Gangoo Ji Dhani, Yousuf Ji Dhani, Yaqoob Ji Dhani, Kharo Jani and Ranjho Noon. There are two larger villages in Block Vl – Kharo Jani with a population of 1,200 lies just northwest and Ranjho Noon, with 1,400 people is in the southwest corner of Block VI. However,
33 Visual Representation of Windfarms Good Practice Guidance, 29 March 2006 – note currently under review.
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Kharo Jani is expected to be resettled as a result of the mine activities within Block VI. Just outside Block VI are the villages of Jadhe Dhani, Bhitro Bhill, Singharo, Sanalba, Kanhea Ji Dhani, Mangu Bheel, Mehun Linju and Munhan Tar. The Project location and settlements are illustrated in Figure 23.
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Figure 23: Project location and settlements in Block VI
Source: Mott MacDonald Pakistan Ltd
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12.3.2 Landscape and visual baseline The Project site is located in the southeast corner of the Sindh Province of Pakistan at the Thar Desert area in Block VI adjacent to Block II coalfield and covers an area of approximately 66km 2. Block VI is situated approximately 380km northeast of Karachi, 20km northeast of Islamkot and 77km east of Mithi. There are a number of local roads that enter the desert from the city of Mithi and the town of Islamkot leading to the Project site, the most significant is the S71004 road from Islamkot.
Block VI is situated within the District of Tharpakar which is a sub-district of Mithi. Two main villages Ranjho Nun and Kharo Jani are located within Block VI, with other small villages located in and around Block VI.
The study area is in a desert location with sand dunes that extend up to 3km in length and 200m in height above sea level. The dunes are set in a wider partially cultivated plain and the relative height varies between 20m and 55m above the plain. The younger dunes are a dynamic system, in continual motion and take on changing shapes and sizes. Older dunes however are in a semi-stabilised condition. Playas (saline lake beds), locally known as dhands, are scattered throughout the southern region of the district. Tree/scrub cover is sparse but typically present along the dunes and the plain is largely cultivated. The nucleated settlements consist largely of mud and thatch dwellings located between the dunes.
Sindh Province has approximately 1,310,000 hectares of protected areas which, includes the Kirthar National Park, located in Karachi and Jamshoro District. Given the distance of this national park from the Project site, it is not considered further in this assessment. The Sindh Wildlife Department is planning to establish Karoonjhar Hills National Park that will include whole of the Tharparkar District and some parts of Badin and Thatta districts.
The Rann of Kutch was declared a RAMSAR site under the Convention on Wetlands of International Importance and is particularly noted for its waterfowl habitat. Within the district, this extends from Nagaparker in the southeast to the western boundary and northwards as far as Diplo, including the southern section of the wider coalfields.
A parallel area to the north of this, which includes Mithi and Islamkot, has also been declared a Wildlife Sanctuary by the Government of Sindh under Clause 14 of the Sindh Wildlife Ordinance 1972. This includes the four most southerly designated coalfield blocks. The designated sites are indicated in Figure 24 below.
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Figure 24: Natural Habitats in Sindh Province
Source: MM Pakistan (Pvt) Ltd (September 2012) Fauna Report - Thar Coal, Section II Biological Baseline: Fauna Survey
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Figure 25: Key settlements in Block VI
Source: Mott MacDonald
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12.3.3 Landscape character Tharparkar and its surroundings have a rich past, with indigenous culture, customs and traditions mostly dating back to the Buddhist and Jain period. The district contains a large number of sites of archaeological, cultural, historical and religious significance. Some of the prominent sites are:
● Thario Halepoto (6km from Block VI boundary) – the site is located at Islamkot near the proposed Thar coalfield. The ruins date back to the Buddhist period (unprotected) ● Ruins of Paari Nagar (65km from Block VI boundary) – the ruins at Paari Nagar comprise Jain temples and settlements near Nagar Parkar town (unprotected) ● Gori Temple – a Jain temple in Nagar Parkar taluka of Thar Parkar (unprotected) These sites fall outside the modelled ZTV and are not considered further in this assessment. The Project area is characterised by mostly desert and consist of sand dunes covered with thorny bushes. The undulating dunes are separated by sandy plains and low barren hills, which rise abruptly from the surrounding plains. The ridges are irregular and roughly paralleled often enclosing sheltered valleys, above which they rise to a height of up to 55m. These valleys are moist enough to allow cultivation and when not cultivated they yield crops of rank grass.
The only mountains in the district are in Nagarparkar on the northern edge of the Rann of Kutch. Karoonjhar Mountains form the 19km long principal range and rise to a height of 305m. Smaller hills rise in the east, which are covered with sparse tree cover and grassland. There are no rivers or streams in Tharparkar district, except, two perennial springs named Achleshwar and Sardharo, and two non-perennial streams known as Bhetiani and Gordhro River. The Rann of Kutch is a large flat land in the south of Tharparkar district. It is almost at sea level with a number of salt lakes (thick layers of salt are formed in these lakes).
Thar is one of the most densely populated deserts of the world with over 91,000 inhabitants. Approximately ninety five percent (95.65%) of the population in Tharparkar district is classified as rural and 4.35% as urban. The urban population is located in three main towns ie Mithi, Islamkot and Diplo.
The wider landscape surrounding the Project site has a largely homogenous character consisting of sand dunes with sparse tree cover, cultivated plains and scattered settlements. A single character area has been defined:
● Settled desert landscape character area (LCA) – This LCA is characterised by an open landscape with areas of small scale agricultural cultivation and sparsely vegetated dunes. Settlements are in harmony with the landscape, located between the large dune formations with locally sourced building materials - typically mud and thatch. The overall condition of the landscape is good, with little evidence of detracting elements. The LCA is not a protected landscape. The LCA has a medium sensitivity to change. The photographs in Figure 26 to Figure 31 illustrate the typical landscape of the LCA.
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Figure 26: Settled desert LCA Figure 27: Settled desert LCA
Source: Mott MacDonald 2016 Source: Mott MacDonald 2016
Figure 28: Jusuf Ji Dhani village Figure 29: Security hut near Jusuf Ji Dhani village illustrating typical building materials
Source: Mott MacDonald 2016 Source: Mott MacDonald 2016
Figure 30: Kharo Jani village Figure 31: Jusuf Ji Dhani village
Source: Mott MacDonald 2016 Source: Mott MacDonald 2016
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12.3.4 Visual amenity The visual baseline study identified a limited number of potential visual receptors (people with a view of the Project). The topography within the study area is characterised by the presence of the stabilised dunes which contain and screen views from the plain areas immediately adjacent. Long views within the study area are possible across the top of the dunes, from the areas where dunes are lower and from the areas where there is little screening vegetation.
Residents living within the study area, people using the local roads and local people working and walking in the landscape are potential visual receptors. These are listed with an assessment of their sensitivity in Table 101. The location of the villages is presented in Figure 26.
Figure 32: View from Jadhe Dhani looking south west towards the Project site
Source: Mott MacDonald 2016
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Table 88: Visual receptors Receptor View Approximate Sensitivity distance from site Residents of The village is located on at the western end of sand-dune 3km High Jadhe Dhani valley with open cultivated land to the north and west. The (see Figure land is relatively flat and sparsely vegetated. Open direct 33) views to the Proposed site. Residents of This village is located within a wide, relatively flat area of 5km Medium Bhitro Bhill scrub. Open cultivated land to the north and south of the (see Figure village and the scrub extends to the east and west. Views 34) north-west (towards the Project site) are largely screened by the undulating sand-dune in the foreground. Residents of Village to be resettled therefore not included in the baseline 2.5km N/A Kharo Jani or assessment. Residents of Two large dunes sit between the village and the Project site. 6km Low Singharo The Project would be screened and the receptor is not considered further Residents of Ranjho Noon is a larger village located on the S71004 road 5.5km Low Ranjho Noon to the west of the proposed site. The village sites within an area of flat cultivated land with sand-dunes to the east. The vegetation around the village is more sparse than that found within the sand-dune valleys closer to the proposed site. The Project would be screened and the receptor is not considered further Residents of Two large dunes sit between the village and the Project site. 6km Low Mangu Bheel The Project would be screened and the receptor is not considered further Residents of This village sits at the foot of a relatively gently sloping dune 2km High Yaqoob Ji with open cultivated land to the north. Views to the east Dhani (towards the Project site) are largely screened but from the higher part of the village, direct views are possible. Residents of The village sits on the western end of a dune. Views to the 1.5km High Yusuf Ji south (towards the Project site) are largely screened by the Dhani (see dune. Figure 35) Residents of This village sits at the entrance to a low sand-dune valley 1.5km High Gangoo Ji with farmland cultivated land to the north and west. Abundant Dhani tree and shrub vegetation is present within the valley and the undulating sand-dune topography partly screen some views from this receptor to the Project. Residents of This village sits at the foot of a low sand-dune valley with 2km Low Salar Ji farmland to the north and west. Tree and shrub vegetation Dhani within the valley and the undulating sand-dune topography screen views to the Project site. Abundant tree and shrub present within the valley and views from this receptor to the proposed site are largely screened by undulating sand-dune topography. Residents of This village is located on the northern edge of a wide area of 3.5km Medium Munhan Tar cultivated land, with undulating sand-dunes to the north. Views south to the proposed Project site are across the open farmland in the foreground but framed by sand-dunes further the south. Residents of Ranijo Noon is a larger village located on the S71004 road to 6km Low Ranjho Noon the west of the proposed site. The village sites within an area of flat farmland with sand-dunes to the east. The planting around the village is more sparsely planted than that found within the sand-dune valleys closer to the proposed site. Views from this receptor towards the proposed site are obscured by topography and existing vegetation within the dune valleys. Source: Mott MacDonald 2016
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Figure 33: View from the dune immediately to the west of Bhitro Bhill village looking west towards the Project site – the village is on lower ground behind the dune
Source: Mott MacDonald 2016
Figure 34: View from the dune immediately south of Yusuf Ji Dhani looking south east towards the Project site
Source: Mott MacDonald 2016
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12.4 Likely impacts and assessment of significance
12.4.1 Overview This section identifies and assesses the potential beneficial and adverse landscape and visual impacts of the Project during construction and operation. The IUCN guidance document “Environmental Impact Assessment Guidance for Coal Fired Power Plants in Pakistan ” published in 2014 outlines the following elements as potential impacts. These have been considered within the following assessment: ● Impacts on visual resources and landscapes; ● Impacts on visibility ● Increases in light contamination. Landscape and visual impacts will arise during construction from:
● The removal of vegetation within the footprint of the power plant and the construction site ● The presence of temporary construction compounds and plants ● Construction activities associated with the Project and associated infrastructure ● Vehicle movements including large machinery such as cranes ● Presence of artificial lighting ● Demolition of residential properties, other buildings and bridges ● The movement of excavated earth and changes in the landform on site ● Loss of tranquillity in the surrounding landscape Landscape and visual impacts will arise during operation from:
● The presence of the power plant and 2 x 330MW generation units and 210m exhaust stack ● The presence of the coal yard ● Access roads within Block VI ● The presence of on-site accommodation, office facilities, fire station, workshop and open materials storage area ● Emissions generated from combustion and from the water vapour plume caused by the cooling towers ● Presence of artificial lighting ● The permanent loss of vegetation within the footprint of the development Measures to mitigate the likely adverse impacts and provide enhancements for landscape and visual amenity are discussed in section 12.5. This assessment is based on the findings of the site visit undertaken in 2016. However, the Project would be realised with the context of the zoning of the whole area for industrial development associated with the Thar coalfields developments. The mitigation measures discussed are focussed and proportionate to the likely significant effects associated with the Project in this industrial context.
12.4.2 Construction impacts
12.4.2.1 Landscape character Construction activity, including construction traffic on local roads, will decrease levels of tranquillity. The presence of large scale earthworks, construction plant including cranes, generators and other equipment, storage areas and artificial lighting will introduce incongruous urbanising elements into a rural landscape setting. The presence of construction activities,
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although temporary in nature, will result in a partial alteration to key landscape elements of the settled desert landscape LCA and introduce structures which will form prominent new elements within the landscape. The magnitude of change is considered to be medium. Given the medium sensitivity of the landscape and medium magnitude of change, the predicted effects of the construction works will be moderate adverse on landscape character and therefore significant.
12.4.2.2 Visual amenity The activities associated with the construction of the Project will be visible to the settlements extending from the villages of Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Jadhe Dhani on the north west and northern border of Block VI and Munhan Tar to the west. Cranes and construction associated with the taller Project elements will be noticeable from the closer settlements given the undeveloped landscape setting. The plant and machinery including tall cranes, compounds, storage areas, new roads and construction traffic will be visible from nearest settlements, as discussed in Table 89
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Table 89 and from the ridges of the nearby dunes.
Potential intrusive light sources from night time working during the construction period would represent a substantial change from the existing domestic scale lighting in the settlements but may be influenced by future developments in the Thar Coalfield blocks.
Although temporary in nature, the construction works will introduce prominent new elements into local views resulting in major adverse impacts or receptors in Jadhe Dhani, which is a significant impact.
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Table 89: Summary of significance assessment of potential impacts on visual receptors – construction phase Potential Receptor Magnitude Sensitivity Impact Evaluation Impact Impact significance (prior to mitigation) Construction Residents of High High Construction activities would be prominent in Major adverse lighting Jadhe Dhani the view. Additionally, ‘sky glow’ and – significant Cranes and potentially glare from artificial lighting when construction used will represent new features that form activities prominent new elements effecting visual amenity and views Construction Residents of Low Medium The sand dune formation would largely screen Minor adverse – lighting Bhitro Bhill the construction activities. However, tall plant not significant Cranes and such as cranes and potentially ‘sky glow’ from construction artificial lighting when used will be visible. activities There will be a detectable change in visual amenity and views Construction Residents of Low High The sand-dune formation will largely obscure Minor adverse – lighting Yaqoob Ji Dhani views of construction activity. However, tall not significant Cranes and plant such as cranes and potentially ‘sky glow’ construction from artificial lighting when used will be visible. activities Direct views from some outlying dwellings towards the Project may be possible. There will be a detectable change in visual amenity and views. Construction Residents of Low High The sand dune formation would largely screen Minor adverse – lighting Yusuf Ji Dhani the construction activities. However, tall plant not significant Cranes and such as cranes and potentially ‘sky glow’ from construction artificial lighting when used will be visible. activities There will be a detectable change in visual amenity and views. Construction Residents of Low High The sand dune formation would largely screen Minor adverse – lighting Gangoo Ji Dhani the construction activities. However, tall plant not significant Cranes and such as cranes and potentially ‘sky glow’ from construction artificial lighting when used will be visible. activities There will be a detectable change in visual amenity and views. Construction Residents of Low Low The sand dune formation would largely screen Minor adverse – lighting Salar Ji Dhani the construction activities. However, tall plant not significant Cranes and such as cranes and potentially ‘sky glow’ from construction artificial lighting when used will be visible. activities There will be a detectable change in visual amenity and views. Construction Residents of Medium Low The distant sand dune formation would largely Minor adverse – lighting Munhan Tar screen the construction activities. However, not significant Cranes and tall plant such as cranes and potentially ‘sky construction glow’ from artificial lighting when used will be activities visible. There will be a detectable change in visual amenity and views. Construction Residents of Low Low The distant sand dune formation would partly Minor adverse – lighting Ranjho Noon screen the construction activities. However, not significant Cranes and tall plant such as cranes and potentially ‘sky construction glow’ from artificial lighting when used will be activities visible. There will be a detectable change in visual amenity and views. Source: Mott MacDonald 2016
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12.4.3 Operational impacts
12.4.3.1 Landscape character The Project built elements comprises two cooling towers up to 130m in height, a crusher house 35m tall, boiler house 70m tall and turbine hall 35m in height, extensive areas for ancillary facilities including coal storage areas and a 210m stack. The key components of the Project at the site include:
● Coal yard ● 2 x 330MWe generation units ● One 210m exhaust stack ● Cooling water system ● Ash yard (temporary storage) ● Ash disposal area (within Block VI) ● Access roads within Block VI ● On-site accommodation, office facilities, fire station, workshop and open materials storage area. During the operational phase, the plume from the stack and steam from cooling towers will be also evident in the wider landscape. The Project and especially the stack will constitute a focal point within the open landscape of the desert.
The presence of the Project introduces large scale, urbanising elements that will be incongruous in a rural landscape resulting in a change in landscape character of the area. Existing built elements are inconspicuous in the wider landscape where the scrub covered dunes are the dominant features. Due to the large scale of the new structures, the Project elements will be prominent elements in the landscape. The landscape is considered to have some capacity to accommodate change due to the presence of the strong dune formations and the absence of recognised landscape designations. The Thar Coalfield area has been zoned for industrial use and the Project would be realised in the context of associated developments.
The magnitude of change is considered to be medium resulting from the addition of new features that will be prominent new elements in the landscape that alter its character. Overall, given the medium sensitivity of the local landscape and medium magnitude of change, impacts are considered to be moderate adverse and therefore significant.
12.4.3.2 Visual amenity The ZTV shown in Figure 35, which has modelled on the operational footprint of the Project illustrates the ZTV indicating theoretical visibility of the power station buildings, cooling towers and stack. The strong dune landform, rising out of the relatively level plain formation, will limit the visibility of the low level Project elements. Taller Project elements including – cooling towers, and stack will be noticeable elements from the closer settlements, given the undeveloped landscape setting and over a wider area up to 10km from the site and extending potentially to 20km to the north and east. It should be noted that the ZTV uses a ‘bare earth model’ such that the extent of theoretical visibility will over estimate what will be experienced in the field through the presence of screening elements. provides a summary of the impacts on visual amenity during the operational phase.
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Figure 35: ZTV indicating theoretical visibility of the buildings and cooling towers
Source: Mott MacDonald 2017
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Table 90: Summary of significance assessment of potential impacts on visual receptors – operational phase Potential Receptor Magnitude Sensitivity Impact Evaluation Significance Impact (prior to mitigation) New large Residents High High Addition of new features that form Major adverse – buildings and of Jadhe prominent new elements effecting visual significant stack Dhani amenity and views. Additionally, ‘sky Plume from glow’ and potentially glare from artificial stack and lighting when used will represent new cooling towers features that form prominent new elements effecting visual amenity and views New large Residents Medium Medi The majority of the power plant Moderate buildings and of Bhitro um structures will be screened by the dune adverse – stack Bhill in the foreground. Tall elements such as significant Plume from the cooling towers, stack and associated stack and plumes will form new features that form cooling towers prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views New large Residents Medium High The majority of the power plant Major adverse – buildings and of Yaqoob structures will be screened by the dune significant stack Ji Dhani in the foreground. Tall elements such as Plume from the cooling towers, stack and associated stack and plumes will form new features that form cooling towers prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views New large Residents Medium High The majority of the power plant Major adverse – buildings and of Yusuf Ji structures will be screened by the dune significant stack Dhani in the foreground. Tall elements such as Plume from the cooling towers, stack and associated stack and plumes will form new features that form cooling towers prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views New large Residents High High The proximity to the site and scale of Major adverse – buildings and of Gangoo development will result in the addition significant stack Ji Dhani new features that substantially alter the Plume from visual amenity and views. Additionally, stack and ‘sky glow’ and glare from artificial lighting cooling towers may affect views New large Residents Low Low The sand dune formation in the Minor adverse – buildings and of Salar Ji foreground would largely screen the not significant stack Dhani power station buildings. However, tall Plume from elements including the stack and plume stack and may be visible together with potential cooling towers ‘sky glow’ from artificial lighting when used. New large Residents Medium Low The distant sand dune formation would Moderate buildings and of Munhan partially screen the lower elements. adverse – stack Tar However, tall plant including the cooling significant Plume from towers and the stack and plume will be stack and visible. Potentially ‘sky glow’ from cooling towers artificial lighting when used will be visible. New large Residents Low Low The dune formations will largely screen Minor adverse – buildings and of Ranjho the Project and only the stack, not significant stack Noon associated plume and potentially ‘sky Plume from glow’ from artificial lighting will be stack and detectable in the view. cooling towers
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12.4.3.3 Summary of impacts A summary of the potential impacts during construction and operation on landscape character is shown in Table 91.
A summary of the potential impacts during construction on visual receptors is shown in Table 89. The residents of one of the closest settlements to the Project, Jadhe Dhani will have relatively open views towards the construction activity which together with potential intrusive light emmissions from artificail sources will form promient new elements in the view. Other settlements would be partially screened by the presence of interveining dune formations. However cranes and construction activities associated with the taller structures would be visible above the dunes.
A summary of the potential impacts on visual receptors during the operational phase is given in Table 90. Residents in the closest settlements of Jadhe Dhani, Yaqoob Ji Dhani, Yusuf Ji Dhani and Gangoo Ji Dhani have relatively open views towards the Project. Jadhe Dhani residents would have the most unimpeded views towards the Project. The addition of new features would form prominent new elements effecting visual amenity and views. ‘Sky glow’ and potentially glare from artificial lighting, when used, could be potentially intrusive.
Table 91: Summary of significance assessment of potential impacts on landscape character Potential Receptor Magnitude Sensitivity Impact Evaluation Significance Impact Construction phase Construction Settled Medium Medium New and uncharacteristic elements Moderate lighting, cranes, desert in the landscape that will alter the adverse – buildings and landscape landscape character significant activities Operational phase New large Settled Medium Medium New and uncharacteristic elements Moderate buildings desert in the landscape that will alter the adverse – including the landscape landscape character significant stack and cooling towers
12.5 Mitigation and enhancement measures Table 92 provides a summary of mitigation and enhancement measures for impacts identified in this assessment. The buildings and structures of the Project will be large scale. It is therefore, not possible to screen these due to their size and the relative openness of the surrounding landscape. However, Table 92 identifies areas where mitigation measures are proposed to alleviate, to some extent, the potentially significant impacts.
12.6 Residual impacts Residual impacts are those significant impacts that remain after the application of mitigation and/or enhancement measures. A summary of impacts considered significant after application of all mitigation and/or enhancement measures included in Table 92 is presented in Table 93.
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Table 92: Mitigation and enhancement measures for impacts on landscape character and visual amenity Type of Measure Impacts mitigated or Detail enhanced Construction Land take Impacts on landscape character Minimise the amount of land take required. and visual amenity Traffic management Impacts on landscape character Maintaining strict requirements for vehicles to remain on roads at all and visual amenity times. Management through a traffic management plan. Lighting Impacts on landscape character Site lighting should be restricted outside normal working hours, to and visual amenity levels acceptable for safe working conditions. Where temporary lighting is required outside of normal working hours, this should be task focussed, down lit and shielded to reduce light spill and background sky glow. Programming and Impacts on landscape character Tracks or temporary site roads should be constructed at the management and visual amenity beginning of the construction period to minimise disturbance of other ground. Movement of vehicles should be confined to these routes to avoid soil compaction. Reinstatement Impacts on landscape character Reinstate vegetation where construction areas and access tracks are and visual amenity no longer required. Design considerations Impacts on landscape character In line with guidance in the EIAG: and visual amenity ● Locate facilities to take advantage of both topography and vegetation as screening devices. ● Design and locate structures and roads to minimise and balance cut and fill. ● Low-profile structures should be chosen whenever possible to reduce their visibility. ● Design facilities, structures, roads and other Project elements to match and repeat the form, line, colour and texture of the existing landscape. ● Design natural looking earthwork berms and vegetative or architectural screening where screening topography and vegetation are absent. ● Paint grouped structures the same colour to reduce visual complexity and colour contrast. ● Plant vegetative screens to block views of facilities. Operation Lighting Impacts on landscape character In line with guidance in the EIAG, illumination of the Project and its and visual amenity immediate vicinity should be minimised by including use of motion detectors or other controls to have lights turned off unless needed for security or safety. If lighting is required, this should be task focussed, down lit and shielded to reduce lighting overspill and background sky glow. Design development Ensure that the design development of the facility aims to reduce the overall bulk and scale of the built elements for example accommodating facilities into smaller buildings rather than a single large unit and incorporating a more articulated building profile The lower parts of the Project buildings and ancillary structures should be painted in neutral colours representative of the surrounding landscape – ie shades of sandy browns and greys. Surfaces should be a matt finish to reduce the reflection of sunlight. Source: Mott MacDonald 2016
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Table 93: Residual impacts Likely impact Receptor Magnitude Sensitivity Impact evaluation Residual Statement of impact significance evaluation Landscape New large buildings, Settled desert Medium Medium The Project will introduce large scale, new elements in the landscape that will Moderate Significant stack and plumes landscape alter the landscape character. Mitigation measures through sensitive design will adverse reduce the impacts of the development but for operational considerations, the scale is likely to be relatively unchanged. Visual amenity New large buildings Residents of Medium High Due to operational considerations, the scale of the cooling towers and stack are Moderate Significant and stack in views Jadhe Dhani likely to remain unchanged. Controlling light pollution will have a positive effect. adverse Plume in views Screening is unlikely to be effective given the scale of the Project elements, however, screening planting close to the village could offer some screening and filtering of views with potential benefits of a managed fuel source if suitable conditions are present. New large buildings Residents of Low Medium Controlling light pollution will have a positive effect. Screening is unlikely to be Minor adverse Not significant and stack in views Bhitro Bhill effective given the scale of the Project elements, however, enhancing existing Plume in views scrub along the dune formation close to the village could offer some screening and filtering of views. New large buildings Residents of Medium High Controlling light pollution will have a positive effect. Orientation of built elements Moderate Significant and stack in views Yaqoob Ji and design of the structures could reduce the apparent bulk of the development. adverse Plume in views Dhani Screening is unlikely to be effective given the scale of the Project elements. New large buildings Residents of Medium High Controlling light pollution will have a positive effect. Orientation of built elements Moderate Significant and stack in views Yusuf Ji Dhani and design of the structures could reduce the apparent bulk of the development. adverse Plume in views Screening is unlikely to be effective given the scale of the Project elements. New large buildings Residents of Medium High Controlling light pollution will have a positive effect. Orientation of built elements Moderate Significant and stack in views Gangoo Ji and design of the structures could reduce the apparent bulk of the development. adverse Plume in views Dhani Screening is unlikely to be effective given the scale of the Project elements. New large buildings Residents of Low Low Controlling light pollution will have a positive effect. Enhancing existing scrub Negligible Not significant and stack in views Salar Ji Dhani along the dune formation close to the village could offer additional screening Plume in views New large buildings Residents of Medium Low Controlling light pollution will have a positive effect. Screening is unlikely to be Moderate Significant and stack in views Munhan Tar effective given the scale of the Project elements. adverse Plume in views New large buildings Residents of Low Low Controlling light pollution will have a positive effect. Enhancing existing scrub Negligible Not significant and stack in views Ranjho Noon along the dune formation close to the village could offer additional screening Plume in views
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13 Ground conditions
13.1 Introduction This chapter considers the potential impacts on ground conditions associated with construction, operation and decommissioning of the Project. Specific objectives of this assessment are to assess:
● Potential impacts of the Project on geology and soils, from the construction phase, subsequent operation and the decommissioning phase. ● Potential impacts on geology, soils and groundwater from existing contaminated land if present in the Project area and future contamination which may result from Project activities. Appropriate mitigation measures to avoid or reduce any identified significant impacts are also presented.
Each phase of the Project –construction, operation and decommissioning– has the potential to impact on soils, with subsequent potential implications on soil quality and land use. In addition, there is potential to affect groundwater quality if mobilisation of contamination occurs. The geology and soils of an area can also impose constraints on the construction, particularly if contaminated or unstable lands are present. Such constraints will be considered in both the Project design as well as in construction and operational procedures. Sensitive receptors associated with ground conditions comprise key features, such as designated (regionally, nationally or internationally) important geological sites or agriculturally or ecologically valuable soils. There is also potential for secondary impacts from existing or future contaminated ground to sensitive receptors that may be nearby, such as human health (farmers, contractors and site/maintenance workers), wildlife and livestock.
Based on the perceived connectivity between the above receptors and the ground conditions, the effects on these receptors with respect to impacts from contaminated ground are discussed in this chapter.
13.2 Methodology criteria The methodology for assessment of ground conditions is broadly consistent with the general ESIA methodology for the Project outlined in chapter 5. Specific criteria for determining sensitivity of ground conditions and the magnitude of the impacts are presented below.
Table 94 presents the criteria for determining the sensitivity of geological and soil receptors. This has predominantly been reviewed with regard to the agricultural value of the soil, which is considered the most likely sensitive potential use for soils in the area and sites of local and/ or international geological importance.
The potential for secondary impacts to human health receptors, as a result of contamination of soil, are also assessed in this chapter. Human health receptors are considered to be of high value.
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Table 94: Sensitivity criteria Importance/ Definition value of feature High Agricultural land (soil of excellent quality with no limitations, can support a very wide range of agricultural crops); or nationally or internationally important for its geology. Medium Agricultural land (soil of good quality with minor limitations, can support a wide range of agricultural crops); or regionally important for its geology. Low Agricultural land (soil of good to moderate quality with moderate to moderately severe limitations, can sometimes support a wide range of agricultural crop, or cereals, pasture and scrubland); or locally important for its geology. Negligible Agricultural land (soil of poor quality with severe limitations, supports mainly scrubland); or not important for its geology.
Table 95 presents the criteria for determining the magnitude of impacts on geology and soils. Areas of land affected have been reviewed qualitatively rather than with absolute figures with regards to the relative availability of similar soil types in the region.
Table 95: Magnitude criteria Magnitude of impact Major Results in loss of feature. The Project (either on its own or with other projects) may result in physical removal or degradation (including loss of structure and contamination) of a large area of soil relative to the availability of similar such soil type in the area. Moderate Results in impact on integrity of feature or loss of part of feature. Physical removal or degradation (including loss of structure and contamination) of a moderate area of soil relative to the availability of similar such soil type in the area. Minor Results in minor impact on feature. The impacts result in the physical removal or degradation (including loss of structure and contamination) of a minor area of soil relative to the availability of similar such soil type in the area. Negligible Results in an impact on feature but of insufficient magnitude to affect the use or integrity. The impact would lead to no observable change in the features.
The significance criteria used for the assessment is in line with the significance matrix provided in chapter 5.
13.2.1 Baseline conditions methodology The evaluation of baseline conditions uses a variety of sources, including information on geology, soils, hydrogeology and the existing contamination status of the soils and groundwater in proposed construction areas of the Project. Baseline conditions for the site have been assessed based on the following information:
● The SESA completed by Mott MacDonald on behalf of the Coal and Energy Development Department of the Government of Sindh (November 2014) ● Revised Implementation Plan, Thar Coalfield Block VI completed by SRK (August 2015) ● ESIA for the Block VI Lignite Mining Project completed by Wardell Armstrong and Hagler Bailly (April 2013) ● Thar Coal Block II Power Project ESIA undertaken by Hagler Bailly (January 2014)
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13.2.2 Scope of assessment
13.2.2.1 Temporal scope The temporal scope of the assessment assesses site preparation and construction of the Project (both assessed under the ‘construction’ phase which is expected to be 40 months in total) and operation which will be for a minimum of 30 years.
Impacts relating to contamination will be assessed based on information on potential historical, current and future sources of contamination. For historical sources this is based on soil testing data and, in the absence of this, information available regarding historical and current land use.
13.2.2.2 Spatial scope For this assessment, the study area includes the land within the boundary of the Project area, which comprise the power plant, access road and the surrounding area within a maximum distance of 500m from the boundary of the Project areas. Provided suitable mitigation is incorporated, operations associated with Project activities are unlikely to significantly affect overall, geology and soils outside of the Project area and no contamination impacts are envisaged at distances greater than 500m from the site boundary.
13.2.3 Assumption and limitations To the extent that some of the assessment is based on information obtained in ground investigations of other studies, persons using or relying on this report should recognise that any such investigation can examine only a fraction of the subsurface conditions. As such, unexpected ground conditions may be present that have not been identified at this stage of the Project. Furthermore, suitable mitigation measures will be in place, detailed in the construction environmental management plan, to manage unexpected contamination if identified during the construction works.
13.3 Baseline description
13.3.1 Landscape and topography The geomorphology of Block VI is typical of much of the Thar Desert in having an undulatory relief with areas of higher ground consisting of elongated (20 to 50m high) sand dunes, parallel to the prevailing north-easterly winds interspersed, with areas of very flat plain being approximately 75 to 85m above mean sea level (amsl).
There are no river courses close to the Project area, although there are small ephemeral (transient) channels that capture run–off during and after large rainfall events. Significant temporary water bodies exist along the southern margins of the Thar Desert, particularly in the Great Rann of Kutch, 60km to the south of Block VI. Refer to chapter 11 and chapter 14 for further detail.
13.3.2 Geology The Block VI concession area is located in the eastern part of the Thar Coalfield, where the overburden and waste rock cover is less than 200m thick. Geological studies extensively carried out for the Thar coalfields have indicated four major divisions of stratigraphic sequences. In descending stratigraphic order, these are: recent dune sands, a sub–recent formation and the tertiary bara formation.
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● The bara formation contains the main lignite horizons which are interbedded with carbonaceous clays and underlain with two thick sand layers of 4m and 40m separated by a thin lignite horizon and carbonaceous clay ● The sub–recent age sediments overlie the bara formation and consist of red–orange silts, clays and sands. The base of this formation is marked by a loose 5–10m sand layer with varying silt content ● The recent dune sand occurs above this and is generally a 60m thickness of fine to moderately grained and unconsolidated sands. In Block VI, the main lignite seam occurs at 130 to 160m below surface and varies in thickness from 10 to 23m. The main seam is split by a major parting to the east and thins to the north and western parts of the basin. A series of thinner lignite horizons, varying in thickness from 0.5 to 4m, occur in the 20m above this main horizon and also occur in below the main seam sporadically below the main lignite seam for 7 to 20m.
The main lignite seam as referred to in Block VI comprises of multiple layers. The thinner seams vary in continuity and thickness across the license (0.3 to 4.7m). The total coal thickness within Block VI decreases to the north of the licensed area and dips towards the south and west, forming the depocentre of the coal basin.
No large scale faulting or folding has been identified within the sediments and small scale faulting cannot be characterised. The lignite seams occur at depth and have not been subject to surface weathering or alteration.
There are three aquifers of significance in the Project area:
● The top aquifer is at the base of the recent sand dune deposits and comprises mainly fine grained sands ● The middle aquifer is confined from above by the sub–recent siltstones and below by the claystones and shales of the bara formation ● The bottom aquifer is confined from above by the bara formation claystones and lignites.
13.3.3 Soils In Tharparkar there is lack of thick top soil with appreciable organic components available. According to World Reference Base (WRB) for Soil Resources classification system, the soil of Thar is predominantly classified as arenosols. Regosols, leptosols and solonchaks are the soil types present in association and / or inclusion with the arenosols. All soil types present in Tharparkar show that the soil is of poor quality. Similarly, according to the soil classification of Thar by the Agricultural Research Council (Islamabad), all the categories come under poor quality soil. The soil of the district primarily comprises unconsolidated mineral material, loamy sand to coarser textured with low water holding capacity and high permeability to water. It is susceptible to soil erosion, shifting sand dunes and long periods of drought.
The Project area is mostly covered with desert consisting of sand dunes and fine sand materials. The soils are generally infertile and because of severe wind erosion, are overblown. The area is covered not only by sheets of sand but also rocky projections of low elevations which constitute the older rocks. The soil remains dry for much of the year and is prone to wind erosion. High velocity winds blow soil from the desert causing shifting sand dunes.
When there is rainfall, the soils are moist enough to allow cultivation and when not cultivated they yield crops of grass. The salinity of the subsoil causes consequent shortage of portable
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water and generates salt lakes. Due to the short span of the monsoon and inconsistent rains, agricultural activities are at subsistence level.
As part of the mine ESIA, surface soils samples were collected and were assessed. The following observations can be made:
● Selected heavy metals (calcium, cobalt, nickel, copper, lead, total chromium, zinc, iron, vanadium) were detected at concentrations above the laboratory limit of reporting (LOR) in the samples analysed. ● Other analytes including cyanide, total petroleum hydrocarbons and purgeable organics results were below the laboratory LOR.
13.3.4 Seismicity Pakistan lies along the contact between the Indian and Eurasian Plates. It is situated in the north–western corner of the Indian Plate. To its south–east is the Indian Plate and to the north the Asian/Karakoram Continental Plate. The Thar Desert lies in the south–eastern part of Pakistan on the stable western margin of the Indian Plate.
Prior to 2007 the area of Block VI was categorised in Zone 2, corresponding to peak horizontal ground acceleration of 0.08 to 0.16g. In 2007, the seismic risk for the entire country was reassessed in light of two major earthquakes in the region. Block VI now falls in the Seismic Zone 2B which corresponds to a peak horizontal ground acceleration of 0.16 to 0.24g. The location of Thar coalfield in relation to seismic zones is shown in Figure 36.
Figure 36: Seismic zones in study area
Source: Hagler Bailly Pakistan
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13.3.5 Landslides There is no available data regarding the landslides within the Project site and there are no records of collapse, debris flow or other adverse geological events around the proposed Project site. There is a close correlation between landslides, seismic activity and intense rainfall. Landslides are primarily caused by slope saturation and earthquake prone areas also increase the likelihood of landslides.
13.3.6 Historical and future contamination sources
13.3.6.1 Potential for historical contamination The Project site has not been occupied by any industries previously that would lead to contamination in the area. A recent study investigated the presence of arsenic (As) in groundwater, which is one of the main sources of drinking water in Tharparkar. The study showed high levels of As 34 in groundwater samples that might be transported by the Indus River from the Himalayas and mobilised in aquifers by the reductive dissolution of various As-bearing oxides 35 . Considering the dry climate of Tharparkar region, evaporation also contributes to the high levels of As.
The ESIA of Block II also concluded that based on the water quality samples obtained from 40 wells, that the groundwater is generally unfit for human consumption.
As discussed in section 13.3.3, surface soils samples were collected and were assessed as part of the mine ESIA and the heavy metals were detected at concentrations above the laboratory LOR. Based on the absence of any significant historical sources it is considered unlikely that soils have been impacted by any anthropogenic sourced contaminants.
Due to the limited information available on the routes of the associated infrastructure at this stage, the specific ground conditions associated with these Project components have not been assessed. Given the remote and rural setting of the Thar Coalfield, it is not considered likely that parts of the associated facilities will pass through currently or historically industrialised areas which have the potential to have been subject to contaminating activities. Assessment of the ground conditions along the route will be undertaken by the Government of Sindh as part of separate assessments.
13.3.6.2 Potential contamination due to construction and operation works The main potential contamination impacts from the construction and operation of the power plant and associated infrastructure will be associated with the transport, storage and use of hazardous materials. The main potential future sources of contaminants are considered to be:
● Coal dust from the storage and use of lignite coal (particularly associated with crushing activities) ● Bottom and fly ash storage, and transport of ash to the emergency ash storage area on site (potential associated heavy metal and polycyclic aromatic hydrocarbons (PAH) contamination), and subsequent transport of ash to the off-site ash disposal area ● Fuel oil used for boiler start up ● Surface run-off as a pathway for contamination (storm drainage) ● Waste water (operational and sewage) including oily water run-off, chemical waste and coal and ash yard storm water
34 Based on the World Health Organisation’s (WHO) maximum permissible limits for drinking water 35 Brahman et al., 2016, Smedley and Kinniburgh, 2002 and Singh, 2006
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● Storage and use of chemicals at the construction laydown area and Project site during construction ● Storage and use of chemicals, such as those for water treatment. Chemicals used are likely to include hydrochloric acid and caustic soda. For all aspects of the construction and operation works, there is potential for secondary health- related impacts to construction and site workers from the handling of hazardous or contaminative materials. Where relevant, these impacts are also discussed in the sections below. If appropriate personal protective equipment (PPE) is worn, with suitable health and safety risk assessments undertaken and standard good construction methods adhered to, the possibility of construction workers being impacted by contaminated land is likely to be low.
13.3.7 Value of geology and soils The geology in the Project area is assessed as having a negligible geological value, as there are considered to be no national or internationally recognised sensitive geological features in this part of the Project area.
At the time of this study there were no data available on soil fertility in the Project area. Available data on the classification of land by use indicates that the Project area is partially agricultural field; therefore the soils are considered to have a low value/sensitivity based on the criteria for determining sensitivity of features (refer to section 13.2).
13.4 Impact identification and assessment
13.4.1 Overview The main Project components which may impact soil quality are considered to be:
● Site preparation including levelling ground preparation within the Project site ● Construction and operation of the new 2x330MW coal-fired power plant and associated infrastructure, including: – Coal yard at power plant site – A substation that will connect to an existing 500kV transmission line – One 210m stack – Cooling water system – Ash yard (temporary storage) – Ash disposal area (within Block VI) – Access roads within Block VI – On-site accommodation, office facilities, fire station, workshop and open materials storage area. Potential impacts relating to the above components are discussed separately in the following sections. Based on an initial assessment, the principal potential impacts to soil and groundwater during all phases of the Project include:
● Degradation of soil and groundwater quality as a result of leaks and spills of hazardous materials (including waste) during their transport, storage, handling and disposal ● Disturbance of potentially contaminated soil as a result of ground works (excavation/ levelling) which could encourage leaching of contaminants into groundwater ● Vegetation and soil loss associated with construction ● Storage of ash generated from the combustion process and the generation of soil infiltration of ash contaminated water with the potential to impact groundwater quality.
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Soil and groundwater are potentially at risk of contamination from the construction, commissioning and operational activities of the Project facilities, including the management of wastewater and other fluids generated by the Project and the storage and handling of other hazardous materials. There is also the potential for secondary impacts to groundwater and human health as a result of soil contamination. The potential for impacts to soil and groundwater from contamination resulting from construction and operation of the Project are discussed below. The following impact assessment is based on our understanding that no significantly polluting activities have previously been undertaken in the Project area. Given the relatively similar nature of both the construction phase and future decommissioning phase, it is anticipated that the impacts described below can be attributed to both.
For all aspects of the construction, operation and decommissioning works, there is the potential for secondary impacts, from contaminated soils affected by the works, to construction and site workers via the handling of hazardous materials or soils. Where relevant, these impacts are also discussed in the following sections. The Project will enforce the use of appropriate PPE as adherence to standard construction methods. As such, the possibility of construction workers being impacted by contaminated soil or other hazardous material is considered to be low.
13.4.2 Construction impacts Construction of the Project and associated infrastructure will be undertaken on previously undeveloped land. This will lead to the loss of approximately 40 hectares of land for the development. Whilst the magnitude of this impact is considered to be major adverse, the soils at the Project area are considered to have a low value due to their limited agricultural value.
13.4.2.1 Site preparation Prior to construction, the Project site will require preparation including site levelling (due to 20m to 50m tall rectangular dunes) and for the construction of piled foundations. Site levelling will require significant movement and reworking of soils which could lead to degradation, erosion and/or loss of soil cover. Compaction of soils can cause secondary impacts on soil drainage.
The soils in the Project area are considered to have a low value and sensitivity. The area affected is considered to be of a reasonable size, whilst other similar areas will remain and the impact will be permanent, therefore the magnitude is considered to be moderate adverse. Impacts to the soil are assessed as minor adverse and therefore are not significant. The site levelling will have an impact on the soil drainage properties which will in turn affect the drainage of potential precipitation run-off and infiltration. The significance of these impacts are discussed further in chapter 11.
13.4.2.2 Construction activities Disturbance of soils during construction, particularly due to movement of vehicles, may lead to erosion of the upper soil layers. A subsequent secondary impact of erosion includes creation of dust. Based on our knowledge of the site history, it is considered unlikely that the soil quality at the Project site has previously been impacted by anthropogenic contamination. Creation of dust may have implications for human health and ecological receptors near to areas where construction activities are to be carried out. Potential impacts from the creation of dust are discussed in more detail in the chapter 7.
Construction of the buildings and hard surfacing and re-vegetation (if possible) of undeveloped areas will act to reduce erosion. Construction activities will ensure the stability of foundations.
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13.4.2.3 Contamination of soil Existing contamination There is potential for impacts from existing soil contamination during construction when soils will be disturbed and exposed. It is understood that the Project site has not previously been developed. As discussed in section 13.3.6, previous soil testing on the Thar Coalfields showed the presence of As; therefore the potential presence of soil contamination on the proposed development site cannot be discounted. Contamination could be spread via excavation and movement of soils, through windblown pathways via dust creation, sediment in runoff and through leaching into groundwater. The magnitude of contamination impacts to soils and human health is conservatively considered moderate adverse for all of the Project elements. With regard to human health (of construction workers and neighbouring site users) is considered to have a high sensitivity and without suitable mitigation, the impact is assessed as major adverse and is significant.
Future contamination During construction, a range of potentially hazardous substances would be used, such as oils, lubricants, fuels and cement. These materials will also require transport to the site. Accidental spills or leakages of hazardous substances may result in local contamination of soils, with potential implications for groundwater. With current best practice construction site management, the likelihood of this occurring will be minimised to a negligible risk.
The magnitude of contamination impacts to soils would be minor to moderate adverse. Based on the low value/sensitivity of soils in the Project area, the impacts to soils are assessed as negligible to minor adverse and therefore is not significant.
13.4.2.4 Wastewater A range of potentially contaminated waste liquids will be produced during construction activities including: concrete wash water; sewage effluent; surface runoff and waters for hydro testing, washing and cleaning (particularly during facility start up). All wastewater and liquid waste streams for the Project will ultimately be treated prior to discharge in accordance with the SEQS effluent discharge limits.
During construction, particularly prior to construction of the site drainage system, it is anticipated that some run-off may not be captured by the sites drainage system. If uncontrolled or untreated, discharge of waste waters could have a minor magnitude of impact on soils and subsequently on groundwater due to the composition of the water and potential presence of pollutants. Based on the low value of soils in the Project area, the impact to soils are assessed as negligible and is therefore not significant.
Secondary impacts to groundwater are discussed in more detail in chapter 11.
13.4.3 Operational impacts
13.4.3.1 Contamination Similar to the construction phase, the main potential contamination impacts for the Project are associated with the use, transport and storage of hazardous materials, and liquid waste disposal. Pollutants associated with the Project activities include fuel oil used for boiler start up, coal dust, bottom and fly ash and other chemicals related to the site processes, such as those for water treatment (including hydrochloric acid). Impacts may result from leaks and spills from
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the storage and use of hazardous materials stored at the plant. Due to the incorporated design and environmental mitigation measures that will be in place this is very unlikely.
A three-part conveyor system will be utilised for unloading delivered coal, transferring crushed or pulverised coal from a stockpile to the storage bunkers; and delivery of the pulverised coal to the CFB boilers. Soil contamination can result from the loss of coal or coal dust into the ground. Two coal storage yards will be located at the site which could be the source of particulate pollution if washed out of the stockpile. Leachate from the stockpile may contain contaminants associated with coal such as heavy metals and can present a risk to surrounding soil and groundwater if freely draining. The quality of the leachate will depend on the coal composition.
Bottom and fly ash will be stored separately in silos at the site. The Developer will be responsible for the transportation and disposal of ash, which is expected to be at the Block VI mine site. Discussions with the Developer and relevant stakeholders will be undertaken to ascertain whether there is a potential for commercial use for the fly ash (eg blocks and cement manufacturing) and bottom ash (eg road construction) within Pakistan.
Hydrocarbons such as fuel oil, lubricating oil and degreasing solvents are highly mobile and can potentially contaminate a wide area. On encountering groundwater, the liquids may migrate laterally over a wide area, presenting risks to groundwater resources further afield. Some liquids may also migrate vertically in groundwater presenting a contaminant risk to identified aquifers (refer to section 13.3). Water treatment chemicals could present a risk to the environment if present in discharge waters, runoff, or if introduced to the environment via leaks and spills. All hazardous materials will be stored in bunded containers or on lined surfaces with surface drainage to a foul water treatment system.
The coal stocking areas will have sealed concrete surfaces and will have incorporated drainage. The exact design and required thickness will be determined during Project detailed design phase, with the minimum requirement that there shall be no possibility of infiltration in the groundwater. Dust will be managed (using a sprinkler system) [and the coal stocking area will be surrounded by an earthen bunded wall to reduce the potential effects of windblown dust from the coal storage area.
Many of the chemicals used at the site are highly mobile and can potentially contaminate a large area. Without suitable mitigation, chemicals entering groundwater may migrate laterally, presenting risks to groundwater resources further down gradient. Some liquids may also migrate vertically in groundwater presenting a risk to deeper aquifers. The risks to groundwater from contamination are discussed in chapter 11.
13.4.3.2 Seismic impacts As discussed in section 13.3.4, Block VI falls in the seismic Zone 2B which corresponds to moderate/intermediate seismic risk. Earthquakes not only present a risk to building structures and human health, but also have the potential to damage drainage structures and containers for storage of hazardous materials. Impacts may be as a result of leaks and spills of hazardous materials, site drainage from potentially contaminated areas and process waste. Measures to mitigate the impacts of potential earthquakes are included in the design of the Project.
13.4.3.3 Surface water runoff The plant design will include two buried treatment facilities for domestic wastewater. Oily waste water from the fuel oil storage and unloading area, boiler room and transformer yard area will be collected in a sump before being treated in an oil separator. Treated oily wastewater will flow to a central monitoring basin. The coal storage yard will be located on a sealed concrete surface
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with a surface drainage collection system which will discharge to a final settling lagoon will then be discharged into the mine stormwater drainage system.
There is potential for impacts to soil and groundwater from failure of the treatment process or ineffective drainage due, for example, to blockages or insufficient capacity. There is potential for contamination impacts if collection ponds are not appropriately lined or maintained.
For all of the above, the potential impacts to soils are assessed as negligible due to their low value/sensitivity and a minor adverse magnitude of impact, which is not significant. The risks to groundwater from contamination are discussed in chapter 11.
13.4.3.4 Impacts on soil quality Contamination has the potential to affect soil quality locally at the Project site. Depending on the extent of contamination (small or large spill/leak) the magnitude would be minor to moderate. Soil is considered to be a low sensitivity receptor. Based on its low value, the resulting impact to soils would be negligible to minor adverse and therefore not significant.
Storage and handling of hazardous materials onsite will be undertaken in accordance with the site environmental health and safety plan to minimise the risk of leaks and spills and therefore the potential for impacts to the environment and human health.
If not suitably controlled, soil contamination has the potential to impact groundwater, human health and ecology. The most likely receptors include site operatives and visitors who may come into contact with contaminated dusts, most likely via inhalation and ingestion. Human health receptors have a high value. Based on the most likely exposure route (inhalation and ingestion of dust) and the likely contamination related to the processes (organics mainly comprising hydrocarbons, and heavy metals), health impacts could be short-term or chronic and therefore the magnitude would be moderate adverse. Taking into account the potential impact on human health, the significance of this impact is assessed as major adverse and significant prior to mitigation being applied. Incorporating spill protection measures in plant design and monitoring during the operational phase will reduce the impact significance.
13.5 Mitigation and enhancement measures
13.5.1 Overview The main impacts on soils for all aspects and phases of the Project are considered to be erosion, landslides during monsoon season and contamination. This is particularly significant during the early construction phase when ground disturbance, leaks and spills are more likely.
During construction, contamination impacts from leaks and spills will be mitigated through use of best practice construction methodology in line with local regulations. Impacts from waste can be suitably mitigated by following a Project specific waste management plan. For all aspects of the Project a comprehensive HSE plan will be implemented, aimed at preventing accidents, injuries and work-related diseases through identification of the causes of physical, chemical and biological hazards and by prioritising hazard elimination, hazard control and hazard minimisation.
Mitigation measures are incorporated in Table 96 and Table 97 and residual impacts after mitigation are identified in Table 98.
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13.5.2 Mitigation of risks to human health Impacts to human health during all stages of the development can be prevented by following good site practice and use of appropriate PPE. Suitable PPE includes: eye protection; body/leg protection; foot protection; hand protection; hearing protection; lung protection and head protection.
Physical exposure to soil and dust can result in a risk to site workers. PPE should be maintained and replaced when worn out. Occupational monitoring of workers will be undertaken in order to confirm the effectiveness of use of PPE and if required the PPE requirements will be revisited.
Other measures for protection of human health include: communication of potential hazards to workers; safe storage of hazardous materials; provision of suitable welfare facilities including clean water for washing and drinking; provision of suitable ventilation systems in workers accommodation; environmental monitoring (e.g. gas and vapour monitoring) and emergency preparedness and response plans.
An emergency preparedness and response plan (EPRP) will be prepared, detailing procedures, response personnel, medical support, equipment, evacuation procedures and measures for limiting or stopping potential events. A framework EPRP has been provided in the ESMP (Volume IV).
13.5.3 Construction impacts A CESMP will be developed for the site prior to construction. This document will outline the practices and procedures during the construction phase and will be further developed for the operational phase, to ensure minimal associated environmental impacts.
Mitigation measures required for construction of the Project are summarised in Table 96.
There is potential for impacts to the health of contractors and site workers during construction activities when handling hazardous waste materials. A comprehensive occupational health and safety (OHS) plan aimed at preventing accidents, injuries and work-related diseases through identification of the causes of physical, chemical, biological and radiological hazards and by prioritising hazard elimination, hazard control and hazard minimisation would be implemented.
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Table 96: Mitigation measures required during the construction phase Process/activity Impact Mitigation Site preparation ● Vegetation loss and ● Where possible vehicles to use defined access roads/tracks. (levelling) and vehicle compaction, resulting in erosion ● Where travelling off road, keep vehicle movements to a movement of desert soils leading to: soil minimum. and further vegetation loss, ● Earthworks to be undertaken during suitable weather change in drainage structure, conditions i.e. low wind strength to minimise the level of clogging of drainage features wind-blown dust. Damping down of soils may also be used to by wind-blown dusts and prevent creation of dust. sediments in rainwater run off Earthworks/ intrusive ● Mobilisation of dust and ● Use best practice construction methodology in line with local construction works secondary impacts on human regulations. health ● Undertake earthworks during suitable weather conditions i.e. low wind strength to minimise the level of windblown dust. Damping down of soils may also be used to prevent creation of dust. Contractors to wear suitable PPE to protect against inhalation of dust. A risk assessment will be carried out to identify the level of PPE required in line with site specific risk factors. Leaks and spills of ● Soil quality with secondary ● Use best practice construction methodology in line with local hazardous materials impacts on groundwater quality regulations to minimise the potential for leaks or spills to and human health. occur. ● Hazardous materials will be suitably stored to prevent leaks and spills. Drip trays will be used to intercept leaks and spills from equipment and during refuelling. Adequate bunding will be provided for all fuel and chemical storage. ● Develop and implement an EPRP and a separate spill prevention and response plan for clean-up of contaminated material in case of fuel leaks. Waste water from ● Soil quality with secondary ● Use best practice construction methodology in line with local construction, integrity impacts on groundwater quality regulations. testing and cleaning and human health. ● All waste water requiring treatment will be processed in the dedicated wastewater treatment facility.
13.5.4 Operational impacts Mitigation measures required for operation of the Project are summarised in Table 97.
As with the construction phase there is a potential for impacts to the health of site workers when handling hazardous materials. These will be addressed through the implementation of OHS management systems.
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Table 97: Mitigation measures required during the operational phase Process/activity Impact Mitigation Leaks and spills of ● Soil quality with secondary ● Drip trays will be used to intercept leaks and spills from hazardous materials impacts on groundwater equipment and during refuelling. quality and human health. ● Develop and implement an EPRP and a separate spill prevention and response plan in accordance with local regulations. Clean-up contaminated material in case of fuel leaks. ● Hazardous materials will be suitably stored to prevent leaks and spills. Bunding at least 110% of largest container will be provided for all fuel and chemical storage. Double or triple skinned bunding will be used where necessary. Site drainage (including ● Soil and groundwater ● All drainage and process water (including surface water ash and coal storage quality run-off and water from the coal stockyard) will be collected, yards) treated at the water treatment plan prior to discharge off- site and/ or re-use on site. Treatment will include separation of oil from the water, pH adjustment and biological treatment. ● All storage ponds will be suitably lined and will be monitored for leakages. ● In accordance with the site ESMP, on-going monitoring and maintenance of the drainage system will be undertaken. ● Wastewater emissions will comply with local water quality and discharge regulations and will not exceed maximum allowable concentrations for discharge of wastewater to land and water. ● In the stack area, fly ash will be stored in elevated silos in an area with a concrete base and wall around it. ● Soil and groundwater quality will be protected in the coal stockyard area by placement of a concrete base which will mitigate the migration of pollution. Storage of wastewater ● Soil and groundwater ● Ponds will be fully lined to prevent leaks and spills. in ponds quality ● The ponds will be designed with extra capacity for monsoon deluge. ● All aspects of the plant will be designed to withstand the assessed intensity of earthquake. Transport, handling, ● Soil, groundwater and ● By implementing the mitigation detailed above, for leaks storage, drainage and surface water quality and spills and drainage, potential impacts to soil and use of potentially groundwater quality can be minimised. contaminating materials ● Routine quarterly monitoring of groundwater quality and level at up-gradient and down-gradient locations in the vicinity of the power plant. ● Assessment of any changes in groundwater conditions, to ensure groundwater quality is not degraded by Project activities and to provide early warning should impacts occur.
13.6 Residual impacts Following the implementation of mitigation as set out in sections 13.5.3 and 13.5.4, residual impacts are set out in Table 98. There are not expected to be any significant residual impacts.
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Table 98: Summary of ground contamination impacts and mitigation Activity Potential impacts Sensitivity Magnitude Impact Mitigation or enhancement Residual descriptor impacts and significance Construction Site preparation ● Erosion Low Moderate Minor adverse ● Best practice construction techniques Negligible - not (levelling) and vehicle ● Landslide adverse ● Where possible vehicles to use defined access significant movement ● Damage to soils roads/tracks. ● Where travelling off road, keep vehicle movements to a minimum. ● Earthworks to be undertaken during suitable weather conditions i.e. low wind strength to minimise levels of wind-blown dust. Damping down of soils may also be used to prevent creation of dust. Earthworks – ● Potential impacts to High Moderate Moderate adverse ● A CESMP will be developed for the site. Minor adverse - not disturbance of soil with human health adverse ● Best practice construction techniques significant potentially existing ● Compliance with local and international contamination guidance ● Develop and implement an EPRP and a separate spill prevention and response plan. Leaks and spills of ● Potential impacts to Low Minor to Negligible – minor ● A CESMP will be developed for the site. Minor adverse - not materials from human health moderate adverse ● Best practice construction techniques significant construction activities ● Compliance with local and international guidance ● Develop and implement an EPRP and a separate spill prevention and response plan. Collection and ● Soil contamination Low Minor Negligible ● A CESMP will be developed for the site. Negligible - not treatment of ● Best practice construction techniques significant wastewaters ● Compliance with local and international guidance ● In accordance with the site ESMP, on-going monitoring and maintenance of the drainage system will be undertaken. Operation Leaks and spills of ● Potential secondary Low Minor to Negligible – minor ● Develop and implement an EPRP and a Minor adverse - not materials (and site impacts to human moderate adverse separate spill prevention and response plan. significant drainage/ waste waters health adverse ● Implement site inspection protocol and if damage occurs) undertake monitoring as necessary.
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Activity Potential impacts Sensitivity Magnitude Impact Mitigation or enhancement Residual descriptor impacts and significance Site drainage from ash ● Potential secondary Low Moderate Moderate to major ● All drainage and process water will be collected, Minor adverse - not and coal storage yards impacts to human adverse adverse treated at the WWTP prior to discharge off-site significant health and/ or re-use on site. ● All storage ponds will be suitably lined. ● Ash will be stored in impermeable sealed bags. ● All buildings, infrastructure and electrical equipment will be designed to withstand an earthquake intensity of 8. ● In accordance with the site ESMP, on-going monitoring and maintenance of the drainage system will be undertaken. Operational activities ● Potential secondary Low Minor to Negligible – minor ● A OESMP will be developed for the site. Minor adverse - not leading to spills and impacts to human moderate adverse ● Compliance with local and international significant leaks health adverse guidance ● Soil contamination ● Develop and implement an EPRP and a separate spill prevention and response plan. ● Implement site inspection protocol and undertake monitoring as necessary.
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14 Ecology & biodiversity
14.1 Introduction This chapter presents the baseline conditions and the assessment of Project impacts on biodiversity associated with the construction and operation of the Project. It identifies the relevant framework of the legislation and other requirements, and identifies and assesses potential significant impacts, before defining appropriate mitigation measures that will be implemented as part of the Project. The baseline includes protected areas, habitats and species, with information being used from primary and secondary sources.
14.2 Applicable legislation
14.2.1 National requirements The national legislation relevant to biodiversity is summarised in Table 99 below.
Table 99: Biodiversity-specific legislation Legislation / Brief description Guideline (Year of issuance) Forest Act (1927) and The Act deals with the matters related to the protection and conservation of natural vegetation and Forest (Amendment) habitats. It empowers the competent agency to declare protected and reserved forest areas and to Act (2010) maintain these. Although it recognises the rights of people to access natural resources for their domestic use, it prohibits unlawful cutting of trees and other vegetation. Therefore, consent is required from the forest department of the concerned province prior to cutting any trees for construction purposes or otherwise. Sindh Environmental To provide for the protection, conservation, rehabilitation and improvement of the environment, for Protection Act, 2014 the prevention and control of pollution, and promotion of sustainable development. The Sindh Wildlife & An Act to provide for protection, preservation, conservation, sustainable use and Protected Areas Act, management of biodiversity, especially wildlife, and establishment and management of 2010 protected areas in the Province of Sindh. Sindh Wildlife Details the rules, regulations and permits for hunting, trapping and capturing of game animals; Ordinance 1972 and conservation of National Parks, Game Reserves; and the laws and guidelines of working in Amendments 2001 protected area and sanctuaries.
14.2.1.1 National Biodiversity Action Plan Pakistan completed a national biodiversity action plan (BAP) in 2000, which acts as Pakistan’s biodiversity policy for meeting the planning requirements of the United Nations (UN) Convention on Biological Diversity (CBD). The process leading up to the preparation of the national BAP involved broad participation from governments, academia and civil society through national and regional-level consultative workshops to develop and review the draft document (CBD Secretariat, 2016).
The national BAP sets out a strategy for action under 13 main components which correspond to the Articles of the CBD: planning and policies, legislation, identification and monitoring, in-situ conservation, ex-situ conservation, sustainable use, incentive measures, research and training, public education and awareness, EIA, access issues, exchange of information and financial resources. For each component, the issues relevant to Pakistan are identified and a list of objectives and corresponding actions are recommended to deal with the identified issues.
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Slowing the rate of biodiversity loss in Pakistan is a key objective in the national BAP. This will require policy and institutional reform to better understand biodiversity and the most effective means for ensuring its conservation and sustainable use. The active participation and support of local communities will be essential for in-situ conservation. The national BAP also calls for greater collaboration between government agencies, local communities and NGOs to work together as partners in biodiversity conservation.
14.2.2 International requirements
14.2.2.1 International conventions Pakistan is a party to a number of conventions in relation to biodiversity, including the Convention on the Conservation of Migratory Species of Wild Animals (CMS), the Convention on International Trade of Endangered Species of Wild Fauna and Flora (CITES), the Convention on Wetlands of International Importance (Ramsar Convention) and the UNCBD.
The CBD defines biodiversity as “the variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part; this includes diversity within species, between species, and of ecosystems”. As a signatory country, Pakistan has a responsibility to:
● Safeguard its biodiversity ● Introduce procedures requiring EIA for Projects likely to have significant impacts on biological diversity; refer to Section 4.5 on EIA related legislation in Pakistan ● Introduce legislative provisions that ensure environmental policies and procedures are duly taken into account
14.2.2.2 IFC PS6 (2012) This chapter has been prepared in line with Pakistani national standards and requirements. However, where possible, the assessment followed IFC PS6 (IFC, 2012a) and IFC Guidance Note 6 (IFC, 2012b).
The IFC PS6 objectives are:
● To protect and conserve biodiversity ● To maintain the benefits from ecosystem services ● To promote the sustainable management of living natural resources through the adoption of practices that integrates conservation needs and development priorities IFC PS6 requires that a conservation value is allocated to the ecological features (protected areas, habitats and species) which are likely to be directly or indirectly impacted in the Project AoI. Under the IFC guidance, the requirements of PS6 apply to Projects in all habitats, whether or not those habitats have been previously disturbed and whether or not they are legally protected. Specifically, a Project is required to:
● Assess the significance of Project impacts on all levels of biodiversity as an integral part of the social and environmental assessment process ● Take into account differing values attached to biodiversity by specific stakeholders ● Assess major threats to biodiversity, especially habitat destruction and invasive alien species In accordance with IFC PS6, habitats are divided into modified, natural and critical habitats. Critical habitats can be either modified or natural habitats supporting high biodiversity value, including:
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● Habitat of significant importance to critically endangered and/or endangered species (International Union for Conservation of Nature and Natural Resources (IUCN) Red List) ● Habitat of significant importance to endemic and/or restricted-range species ● Habitat supporting globally significant concentrations of migratory species and/or congregatory species ● Highly threatened and/or unique ecosystems ● Areas associated with key evolutionary processes Since habitat destruction is recognised as a major threat to the maintenance of biodiversity and to assess likely significance of impacts, IFC PS6 requires the following depending on habitat status:
● Modified Habitat: exercise care to minimise any conversion or degradation of such habitat, depending on scale of Project, identify opportunities to enhance habitat and protect and conserve biodiversity as part of operations. ● Natural Habitat: developer will not significantly convert or degrade such habitat unless no financial/technical feasible alternatives exist, or overall benefits outweigh cost (including those to biodiversity), and conversion or degradation is suitably mitigated. Mitigation must achieve no net loss of biodiversity where feasible; offset losses through creation of ecologically comparable area that is managed for biodiversity, compensation of direct users of biodiversity. ● Critical Habitat: in areas of critical habitat the developer will not implement Project activities unless there are no measurable adverse impacts on the ability of the critical habitat to support established populations of species described or on the functions of the critical habitat; no reduction in population of a recognised critically endangered or endangered species and lesser impacts mitigated as per natural habitats.
14.3 Methodology and assessment criteria
14.3.1 Ecological area of influence For the ecological impact assessment, the Area of Influence (AoI) varies with the ecological receptor and consists of the following areas:
● Project affected area (PAA), i.e. footprints of all Project components and related facilities power plant site: – Coal yard – 2 x 330MWe generation units – A substation that will connect to an existing 500kV transmission line – One 210m exhaust stack – Cooling water system – Ash yard (temporary storage) – Ash disposal area (within Block VI) – Access roads within Block VI – On-site accommodation, office facilities, fire station, workshop and open materials storage area ● Buffer zone of 500m from PAA in relation to habitats, flora, birds (excluding vultures), mammals and reptiles
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● Buffer zone of 15km from PAA in relation to protected areas (national and international levels), vultures, and for cumulative impact assessment This AoI was selected to include the areas directly affected by the land take for the Project, areas which will be temporarily affected during construction, areas likely to be impacted by disruption and areas where there is a risk of pollution and noise disturbance during construction and/or operation.
The ecological baseline within the AoI was formulated from information obtained from various primary and secondary sources. Details on the methodologies used are provided in the following sections.
14.3.2 Desktop review A desk-based review of available information from national and international sources was undertaken. This included:
● UN CBD website ( http://www.cbd.int/ ) ● UNESCO database on World Heritage Sites ( http://whc.unesco.org/en/interactive-map/ ) ● Ramsar Secretariat ( www.ramsar.org ) ● IUCN Red List of Threatened Species version 2015-4 ( http://www.iucnredlist.org ) (IUCN, 2015) ● Status and Red list of Pakistan Mammals (Sheikh and Molur, 2004) ● BirdLife International Data Zone ( http://www.birdlife.org/datazone/home ) ● Protected Planet ( http://www.protectedplanet.net/country/PK ) ● The Reptile Database ( http://reptile-database.reptarium.cz/ ) ● Flora of Pakistan ( http://www.tropicos.org/Project/Pakistan ) ● Catalogue of Life ( http://www.catalogueoflife.org/ ) Previous reports undertaken as part of the Thar Coalfield Project and other projects in the region have been reviewed and included:
● Thar Coal Block II Power Project ESIA (Hagler Bailly, 2014) ● Block VI Lignite Mining Project ESIA (Hagler Bailly, 2013) ● Environmental and Social Study for Thar Coalfield (Mott MacDonald, 2015) Information on the following nature conservation areas and other protected areas (existing or proposed) within the AoI and up to 15km has also been collected and reviewed:
● Ramsar sites ● Key Biodiversity Areas (KBA) ● Important Bird Areas (IBA) ● World Heritage Sites (WHS) ● Biosphere Reserves ● National conservation areas in Pakistan: – National Parks – Wildlife sanctuaries – Game reserves – Protected and reserved forests
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14.3.3 Biodiversity surveys
14.3.3.1 Overview Biodiversity surveys were undertaken in July and October 2011 by Hagler Bailly Pakistan to inform the ESIA for Block VI Thar coalfield (Hagler Bailly, 2013). Block VI was awarded 66.1km 2 by Sindh Coal Authority (SCA) and the study area extended a further 10km from the boundary. Biodiversity surveys were also undertaken in December 2009, March/ April 2010 and July/ August 2010 by Hagler Bailly Pakistan to inform the ESIA for Block II Thar coalfield (Hagler Bailly, 2014). Block II was awarded 95.5km 2 by SCA and the study area extended a further 5km from the boundary. During the surveys, 28 sampling locations were surveyed in Block VI and 53 sampling locations were surveyed in Block II.
The following habitats and species were studied as part of these surveys:
● Habitats and flora ● Mammals ● Birds ● Herpetofauna (Reptiles and Amphibians) ● Invertebrates (Block VI only) Ecological surveys were undertaken in 2012 to inform the environmental and social study for Thar Coalfields (Mott MacDonald, 2015). The study area included the Thar Coalfields blocks and the whole of the Tharparkar district. The methods are summarised in the sections below and full descriptions are included in the Mott MacDonald (2015) report (refer to Volume III).
Additional ecological surveys in Block VI were undertaken in June 2016 to update the previous surveys. These surveys were undertaken by a team of local specialists under the coordination of Mott MacDonald. The report from June 2016 is included in Volume III. The June 2016 surveys covered habitats/flora, mammals, birds and reptiles. A combination of methods were used, including direct visual observations during the day, spotlighting at night, recording field signs of animals (faecal pellets, dens, tunnels, tracks, footprints and calls), interviews with local people and consultation with the Wildlife Department and conservation NGOs.
14.3.3.2 Habitat and flora survey The field studies for habitats and the abundance and diversity of the flora in Block II and Block VI were conducted in 2009, 2010 and 2011 and covered all seasons (Hagler Bailly, 2013, 2014). Habitats were classified based primarily on geomorphology and soil texture, with consideration of variations within habitat types. Wildlife habitats were described using three basic components: cover, food, and water (based on Morrison et al 2006) with vegetation as the core descriptive component. During each survey, between 3 and 10 quadrats of 10x10m were taken at random points along a transect within the survey area. For all surveys, plants within and directly adjacent to each quadrat were noted. Percentages for cover, density, frequency and Importance Value Index (IVI) for each species from the study were recorded or calculated.
A botanical survey of the Tharparkar district was undertaken in April 2012 (Mott MacDonald, 2015). During the survey 50 quadrats of 50x50m were taken using stratified random methodology in each of the following microhabitats: dune crest, slopes/swales/flanks, sandy plains, saline lands, lake/wetland and hilly tract.
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14.3.3.3 Fauna surveys Mammal surveys For all surveys in 2009, 2010 and 2011, line transect (500m by 20m) were completed at each of the sampling sites for mammals. All animals sighted, or their signs (footprints, droppings, dens etc.), GPS coordinates and habitat type were recorded. As well as these diurnal surveys, surveys were conducted for nocturnal mammals using spotlights whilst travelling in a vehicle along roads/ vehicle tracks. Incidental sighting were also recorded during other surveys.
Live trapping and releasing of mammals was carried out within Block VI and Block II. Sherman traps were used and set at specific areas. Fresh bait was used to attract mammals on every trapping day; the traps were then checked the following morning. The trapped mammals were identified and their weight and sex was recorded. Other relevant data such as the date, habitat, location, elevation, and weather conditions, were also recorded.
In April 2012, sampling for small mammals was conducted in 27 quadrats of 500x500m in representative areas of Tharparkar district. In some areas (Mithi and Nagarparkar), rodents were also recorded at night through spotlighting. Medium-sized and large mammals were recorded through direct observations, field signs such as foot prints, scats and dens, and from information from locals, hunters and game watchers of the Department of Wildlife, Sindh (Mott MacDonald, 2015).
Bird surveys Birds were recorded along transect lines (500m by 50m) at each sampling location for all surveys in 2009, 2010 and 2011. Transects started early morning and late afternoon and covered all habitat hypes on site. The start time and coordinates of the starting point were recorded. The bird surveys in April 2012 covered the whole of the Tharparkar district and involved walkovers and using a car.
In 2012, officials of Sindh Wildlife Department and local residents were interviewed in order to assess the existing threats to the birds as well as any possible negative impacts of the Thar Coal Project to the resident and migratory avian fauna of the area (Mott MacDonald, 2015).
Reptile and amphibian surveys Line transects (500m by 20m) were completed at each sampling site for reptiles and amphibians in Block VI and Block II. Sightings of individuals and signs (impression of body, tail or footprints, faecal pellets, tracks, dens or egg laying excavations etc) were recorded along with their GPS coordinates, elevation, habitat type and photographs where possible.
Active searches were conducted for animals and their signs for diurnal and nocturnal species along the transect lines, at the relevant time of day. One set of pitfall trap (5-10) were also placed at a sampling site for a single day and night with drift fences alongside them. Samples were collected and preserved where the species could not be identified in the field.
The 2012 surveys involved stone turning, checking under vegetation, searching for basking skinks on sand dunes and walking along microhabitats. Amphibians were observed along water bodies as well as in ruderal habitats. The specimens that could not be identified in the field were preserved for detailed study in the laboratory (Mott MacDonald, 2015).
Invertebrate surveys The invertebrate surveys were carried out in a number of sampling location for diurnal species and also for nocturnal species to record the abundance and diversity of invertebrates in Block VI and Block II.
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Sweep net transects and butterfly transects were used during diurnal surveys. A sweep net of 30cm diameter rim, 2.25ft long bag and one metre long handle was used to collect invertebrates along a transect line. The observer walked at constant speed for thirty minutes repeatedly sweeping the net from side to side. Samples were collected from the sweep nets every 50m to be preserved and were identified later. Butterflies were counted along the same transect line within 2.5m of the observer in all directions whilst walking the transect at a constant speed. The temperature, wind and cloud cover were recorded for each sampling point.
Nocturnal surveys were undertaken using a portable car battery operated ultra violet light trap. The trap was operated for thirty minutes at each sampling location.
14.3.4 Determining significance of impacts and effects The magnitude of the potential impacts upon each ecological feature (Table 100) is assessed for the construction and operation of the Project. The conservation value (sensitivity) or weighting attributed to each ecological feature which occurs within the Project AoI is defined in Table 101.
In order to categorise the sensitivity on the basis of biodiversity-specific criteria typically adopted for the assessment of ecological impacts, the sensitivity ranking presented in Table 101 differs slightly from the evaluation matrix presented in chapter 5 by including the conservation value category “Very High.” However, a “High” or “Very High” sensitivity (conservation value) is equivalent to the general category “High” for receptor sensitivity in the impact evaluation matrix.
Significance has been determined by the interaction between the magnitude of impacts and the sensitivity of receptors affected, as depicted in the impact evaluation matrix shown in chapter 5.
Table 100: Criteria for determining impact magnitude Category Definition Major Fundamental change to the specific environmental conditions assessed resulting in long term or permanent change, typically widespread in nature (regional, national and international), would require significant intervention to return to baseline; exceeds national standards and limits. Moderate Detectable change to the specific environmental conditions assessed resulting in non- fundamental temporary or permanent change. Minor Detectable but minor change to the specific environmental conditions assessed. Negligible No perceptible change to the specific environmental conditions assessed. Source: Mott MacDonald
14.3.5 Assumptions and limitations The ecological surveys only focused on the typical habitats and areas of ecological interest. Due to the large scale of the Project, it was neither possible nor practical to survey the entire AoI as part of this ESIA. This impact assessment has made use of the survey data collected in the previous years as part of Thar Coalfields environmental and social studies (see Section 14.3.2).
This assessment has considered the potential unexpected ecological features and precautionary mitigation measures along with additional monitoring are included in Section 14.6 and 14.7.
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Table 101: Criteria for determining receptor sensitivity (conservation value) Conservation value Detail Species criteria Habitat or site criteria (Sensitivity) Very high Very high importance IUCN critically endangered and Internationally designated sites (or and rarity. International endangered species. equal status). Critical habitats of scale with limited significant international ecological potential for substitution. importance. High High importance and IUCN vulnerable species. Nationally designated sites (or equal rarity, national scale, or Nationally protected species of status). Areas of critical habitats of regional scale with limited significant population size and national ecological importance, and potential for substitution, importance. natural habitats of significant species of international ecological importance and/or high status but not within biodiversity with limited potential for designated areas. substitution. Medium High or medium IUCN near threatened species. Regionally important natural importance and rarity, Nationally protected species or habitats. Modified habitats with high local or regional scale, and rare species, but not a significant biodiversity or under significant limited potential for population size and not of national threat of loss within the region. substitution, species of importance. national status but not within designated areas. Low Very low or low IUCN least concern. Species of Undesignated sites and natural importance and rarity, and local importance. habitats of local biodiversity and local scale. cultural heritage interest. Modified habitats with limited ecological value. Other sites with little or no local biodiversity and cultural interest. Modified habitats with limited biodiversity value. Negligible Very limited ecological IUCN least concern species. Highly modified habitats of no importance. Species of no national or local biodiversity value. importance. Source: Mott MacDonald
14.4 Baseline context
14.4.1 National and regional context Pakistan is located within the Palearctic and Indomalayan ecozones. The ecosystems of Pakistan range from coastline in the south to the mountain ranges of the Himalayas and Hindu Kush in the north along with deserts and plains (CBD, 2014). The vegetation is dry and sub- humid land comprised of xerophytic shrubs and small trees, grasslands and steppe. The variation in relief and climate means Pakistan has a rich biodiversity and many ecosystems, habitats and species of global significance. In Pakistan, 195 mammal species (six endemic) have been recorded, as well as 668 bird species (25 endangered), 177 reptile species (13 endemic), 22 amphibians (nine endemic), 198 freshwater fish (29 endemic) and 5,000 species of invertebrates, as well as 5,700 species of flowering plants (over 400 endemic) (CBD Secretariat, 2016).
Main threats to the terrestrial biodiversity in Pakistan are overgrazing, deforestation, illegal hunting, and habitat disintegration due to population growth and infrastructure development. The main threats to biodiversity of inland waters are pollution from industrial and municipal waste. The coastal and marine ecosystems are also threatened from pollution (CBD, 2014).
The Project site is located within the Thar desert and Tharparkar district, in the south-east province of Sindh. The Thar desert, also known as the Great Indian Desert, occupies 77,000 square miles of rolling sand dunes in eastern Pakistan and the north-western Indian state of Rajasthan. The annual rainfall in the region is particularly low ranging from 4 to 0 inches and
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most of that falls during the monsoons in summer. Block VI (where the Project is located) is situated in the north of Thar coalfield and it occupies a land area of about 66.1km 2.
Protected areas Pakistan has 14 national parks, 72 wildlife sanctuaries, 66 game reserves, nine marine and littoral protected areas, 19 protected wetlands, and a number of other protected areas of grassland, shrubland, woodland and natural monuments.
There are no protected areas within 15km of the PAA. The closest protected area is Rann of Kutch, an internationally designated Ramsar site, Important Bird Area (IBA) and nationally designated Wildlife Sanctuary. The IBA and the Wildlife Sanctuary share the same northern boundary which is 22.5km from the PAA. The northern boundary of the Ramsar site is 43km south of the PAA.
14.4.2 Habitats The Project AoI lies in the Thar Desert, which has a semi-arid tropical climate with four distinct seasons.
Surveys undertaken in Block VI and Block II identified four main habitat types that include agricultural fields, sand dunes, plains and human settlements (Hagler Bailly, 2013; Hagler Bailly 2014) (Table 102). Sand dunes were the dominant habitat observed within the Block VI in 2011 (constituting 58% of the habitat), whereas agricultural fields were the dominant habitat observed in Block II in 2009/2010 (constituting 56% of the habitat).
Table 102: Habitat types within Block VI and Block II AoI Habitat type Habitats (%) within Project AoI Block VI, 2011 Block II, 2009/2010 Agricultural fields 36% 56% Sand dunes 58% 35% Plains 3% 7% Human settlement areas 2% 2% Source: Hagler Bailly (2013; 2014)
The vegetation in the Thar Desert consists of xerophilious grasslands composed of Eragrostis sp. Aristida adscensionis, Cenchrus biflorus, Cympogon sp., Cyperus sp., Eleusine sp., Panicum turjidum, Lasiurus scindicus, Aeluropus lagopoides, and Sporobolus sp. Scrub vegetation consists of low trees such as Acacia nilotica, Prosopis cineraria, Prosopis juliflora, Tamarix aphylla, Zizyphus mauritiana, Capparis decidua, and shrubs such as Calligonum polygonoides, Calotropis sp., Aerva sp., Crotalaria sp.. Haloxylon salicornicum and Haloxylon recurvum are also present (Hagler Bailly, 2013; Hagler Bailly, 2014).
In July 2011, the dominant species recorded in Block VI included Crotalaria burhia (rattlepod), Prosopis cineraria (kandi), and Aerva tomentosa (desert cotton) within the agricultural fields. The dominant species recorded in Block VI in October 2011 in agricultural fields included Prosopis cineraria (kandi), Aristida sp (threeawn), and Ziziphus nummularia (ber). In Block II in 2009/2010, the plant communities dominating mostly the edge of agricultural lands were Salvadora oleoides (tooth brush tree), Aerva tomentosa (desert cotton), Leptadenia pyrotechnica (broom bush), Calotropis procera, Ziziphus nummularia (ber) and Crotalaria burhia (rattlepod).
In July 2011, the dominant species recorded in Block VI within the sand dunes were Acacia senegal (gum acacia), Aerva tomentosa (desert cotton) and Leptadenia pyrotechnica (broom
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bush). Dominant species in sand dunes in October 2011 include Indigofera cordifolia (heart-leaf indigo), Acacia senegal (gum acacia) and Aerva tomentosa (desert cotton). The common and dominant plants of sand dunes in Block II include Aerva javanica, Acacia senegal, Crotalaria burhia (rattlepod), Calligonum pollygonoides, Leptadenia pyrotechnica (broom bush), and Salvadora oleoides (tooth brush tree).
The plains in Block VI included Salvadora oleoides (tooth brush tree), Leptadenia pyrotechnica (broom bush) and Aerva tomentosa (desert cotton) as the main species in July 2011, and Indigofera cordifolia (heart-leaf indigo), Salvadora oleoides (tooth brush tree) and Leptadenia pyrotechnica (broom bush) as the dominant species in October 2011. Due to grazing pressure, the vegetation of grasses, scrubs and bushes in Block II in 2009/2010 was considered uniformly degraded (Hagler Bailly, 2013; 2014).
The 2012 surveys described the vegetation within six microhabitats in the Tharparkar district but only dune crest, dune slope and sandy plains are relevant to the Project AoI. The species composition of these microhabitats is presented in the Mott MacDonald (2015) report.
14.4.3 Flora Floristically, the Project is located at the southern limit of the Sindh Province of the Sudano- Zambezian Region (Tropicos, 2016).
The botanical surveys recorded the following species:
● 123 species recorded during the 2011 field surveys in Block II (Hagler Bailly, 2013) ● 137 plant species recorded in 2009/2010 in Block VI (Hagler Bailly, 2014) ● 162 species recorded in the Tharparkar district in April 2012 (Mott MacDonald, 2015) ● 53 species recorded in the PAA in 2016 (refer to Volume III) ● Of the 162 species recorded in 2012, grasses (Poaceae) were dominant (33 species- 20.37%), followed by Fabaceae (12 species - 7.41%) and Amaranthaceae, Boraginaceae, Euphorbiaceae (7 species - 4.32% each). Most of the species are annual (51%) followed by perennial (36%) and biennial (13%) (Mott MacDonald, 2015). The June 2016 surveys recorded 75 mature trees of four species in the designated PAA: Prosopis cineraria (kandi), Salvadora persica (jhar), Senegalia modesta (syn. Acacia modesta syn. Prosopis modesta) (kumbat), and Faidherbia albida (syn. Acacia albida) (roheero).
None of the plant species found during the surveys is threatened globally or nationally. The 2012 survey recorded five endemic species to Pakistan in the Tharparkar district, but they were not present in the Project AoI (Mott MacDonald, 2015).
Euphorbia caducifolia (leafless milk hedge, thohar) is spread widely throughout the Project AoI in Block VI, especially in the sand dunes. This species is protected under Appendix II of CITES. It is widespread in India and Pakistan, in coastal plains and hills; at elevations of up to 800m above sea level. (Ali and Qaiser, 2001).
Two invasive species were found as part of the ecological surveys for Block VI in 2011 (Hagler Bailly, 2013): Prosopis juliflora (vilayati babul) and Prosopis glandulosa (honey mesquite). They were found 18km south of the PAA. Prosopis juliflora is an invasive shrub species native to South and Central America. It is fast-growing, salt-tolerant and drought-tolerant (Weber, 2013). This species is a noxious weed in Pakistan and was found in agricultural fields, sand dune and plains during the surveys for Block VI and Block II (Hagler Bailly, 2013; 2014). This species was recorded in 40% of the quadrats surveyed in April 2012 in the Tharparkar district, including Block VI where the Project is located (Mott MacDonald, 2015).
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Prosopis glandulosa (honey mesquite) was recorded in the PAA during the June 2016 surveys in Block VI. This species is native to the southern United States and northern Mexico, and is naturalized in Punjab and Sindh.
14.4.4 Mammals Surveys undertaken in Block VI in 2011 observed or reported signs of 15 mammal species (Hagler Bailly, 2013) and surveys undertaken in Block II in 2009/2010 observed or reported 20 mammal species (Hagler Bailly, 2014). Twenty seven mammalian species belonging to fifteen families are reported to occur in the Block II AoI (Hagler Bailly, 2014). No mammal species recorded in Block VI or Block II are globally/nationally threatened species, endemic species or protected species in Pakistan.
The 2012 surveys recorded 34 mammal species in the Tharparkar district (Mott MacDonald, 2015). The following species are threatened globally and/or nationally but none of these were recorded within the Project AoI or Thar Coalfields:
● Indian pangolin (Manis crassicaudata) – IUCN Endangered, Pakistan Vulnerable ● Honey badger (Melivora capensis) – IUCN Least Concern, Pakistan Critically Endangered ● Striped hyaena (Hyaena hyaena) – IUCN Near Threatened, Pakistan Critically Endangered ● Caracal (Caracal caracal) – IUCN Least Concern, Pakistan Critically Endangered ● Asiatic wild ass (Equus hemionus) – IUCN Near Threatened, Pakistan Critically Endangered ● Indian gazelle (Gazella bennettii) – IUCN Least Concern, Pakistan Vulnerable The June 2016 surveys in the PAA recorded eight mammal species through field signs or direct observations, including golden jackal (Canis aureus), Indian hare (Lepus nigricollis), Javan mongoose (Herpestes javanicus) and Indian hedgehog (Paraechinus micropus) (see Volume III). None of these species are threatened globally or in Pakistan.
The Indian grey wolf (Canis lupus pallipes) is known from the Thar desert but it is very rare; it was not observed in the Block VI or Block II AoI during the field surveys (Hagler Bailly, 2013; 2014). This species is listed as Endangered on the Pakistani National Red List 2004 and as Least Concern on the IUCN Red List. The major threats to the species are decline in habitat and prey species. They are found in subtropical scrubland, tropical dry scrubland, hot desert, open areas and tropical thorn forest (Sheikh and Molur, 2004).
The common red fox (Vulpes vulpes) and the Bengal fox (Vulpes bengalensis) were identified during the surveys in 2009/2010 and 2011 (Hagler Bailly, 2013; 2014). Common red fox was also recorded in the Thar Coalfields in April 2012 (Mott MacDonald, 2015). In addition, an unidentified fox species Vulpes sp, was observed in Block VI in 2011, in Block II in 2009/2010 and in the PAA in June 2016. There is a possibility that it could be Rueppell’s fox or sand fox (Vulpes rueppelli) which is listed as Vulnerable on the Pakistani National Red List 2004. However, the distribution of this species does not cover the Project AoI (IUCN, 2016). This species is listed as Least Concern in the IUCN Red List.
14.4.5 Birds A total of 74 bird species were observed in Block VI AoI in 2011 and 88 species were observed in Block II AoI in 2009/2010 within all habitat types. The species observed include both resident and migratory birds of which none are water birds because there are no permanent wetlands in the wider area. Six globally threatened bird species are known in the AoI of Block VI and Block II: three are listed as Critically Endangered on the IUCN Red List, one is listed as Endangered and two are listed as Vulnerable (Table 103).
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During the April 2012 survey in the Tharparkar district, 74 bird species were recorded (Mott MacDonald, 2015) of which 58 are resident, 4 winter visitors, 8 irregular year-round visitors and 4 species are summer breeders according to Grimmett et al. (2008). The following threatened species were recorded during these surveys: oriental white-backed vulture (or white-rumped vulture) (Gyps bengalensis), Egyptian vulture (Neophron percnopterus), Indian vulture (Gyps indicus) and great knot (Calidris tenuirostris) (Table 14.5).
The June 2016 surveys identified 23 bird species in the PAA (refer to Volume III). Of these, two species are globally and nationally threatened:
● Oriental white-backed vulture (or white-rumped vulture) (Gyps bengalensis) is Critically Endangered globally (IUCN, 2016) and is considered to be rare in the PAA ● Egyptian vulture (Neophron percnopterus) is globally Endangered and rare in the PAA
Table 103: Nationally/ globally threatened bird species observed in Block VI, Block II, PAA and Tharparkar district Latin name Common name Distribution IUCN status CITES Source in Pakistan appendix (IUCN Red List) Gyps Oriental White- Resident Critically II Block VI ESIA (2011) bengalensis backed Vulture or endangered Block II ESIA White-rumped (2009/2010) Vulture Tharparkar district (2012) PAA (2016) Gyps indicus Long-billed Vulture Resident, non- Critically II Block VI ESIA (2011) or Indian Vulture breeding endangered Block II ESIA (2009/2010) Tharparkar district (2012) Neophron Egyptian or Resident, Endangered II Block VI ESIA (2011) percnopterus Scavenger Vulture breeding Block II ESIA (2009/2010) Tharparkar district (2012) PAA (2016) Aquila clanga Greater Spotted Non-breeding Vulnerable II Block VI ESIA (2011) Eagle Block II ESIA (2009/2010) Aquila heliaca Imperial Eagle Resident Vulnerable I Block VI ESIA (2011) Calidris Great Knot Winter visitor Endangered - Tharparkar district tenuirostris (2012) Source: Data compiled by Mott MacDonald
The oriental white-backed vulture or white-rumped vulture (Gyps bengalensis) was recorded during all field surveys in 2009/2010 and 2011 (Hagley Bailly, 2013; 2014). Eleven individuals were sighted over the surveys in 2011 in Block VI and they were observed in all three habitats, <2km from the PAA. Three empty nests were located on Prosopis cineraria trees in Block II in 2009/2010; these were thought to be nests of either the white-backed vulture or Egyptian vulture (Neophron percnopterus). In April 2012, oriental white-backed vulture was recorded in the Nangarparkar tehsil but not in the Thar Coalfields (Mott MacDonald, 2015). Oriental white- backed vulture was recorded during the June 2016 surveys in the PAA but is considered to be rare. Gyps bengalensis is close to extinction in Pakistan and is listed as Critically Endangered
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on the IUCN Red List and listed on Appendix II of CITES. They occur mostly on plains and feed on carrion.
Indian or long-billed vulture (Gyps indicus) was sighted in the 2009/2010 and 2011 field surveys (Hagley Bailly, 2013; 2014) and is listed as Critically Endangered on the IUCN Red List and listed on Appendix II of CITES. It is also a qualifying feature of Rann of Kutch IBA, located 22.5km south from the PAA. A total of four individuals were observed in Block VI in locations approximately 15km from the PAA. This vulture has a small resident population breeding on cliffs in the extreme south-west Tharparkar district (Hagler Bailley, 2013). In April 2012, Indian vulture was recorded in Block VI and in the Nangarparkar tehsil (Mott MacDonald, 2015). The Indian vulture is known to breed in south-east Pakistan and can be found in cities, towns and villages near cultivated areas, and in open and wooded areas (BirdLife, 2015b). No Indian vultures were observed to be nesting in Block VI or Block II during the surveys.
Egyptian or scavenger vulture (Neophron percnopterus) is listed as Endangered on the IUCN Red List and listed on Appendix II of CITES. They typically nest on ledges or in caves on cliffs, crags and rocky outcrops. They forage in lowland and montane regions over open, often arid, country and also scavenge at human settlements feeding on carrion, tortoises, organic waste, insects, young vertebrates, eggs and even faeces. The Egyptian vulture was observed within Block VI in the survey conducted in 2011 and the location of the record was approximately 1km from the PAA. A total of two occupied Egyptian vulture nests were identified in the Block VI AoI in 2011 and two occupied Egyptian vulture nest were identified in the Block II study area in 2009/2010. Additional vulture nests were identified during all surveys but these were empty (Hagler Bailly, 2013; 2014). The nests were located outside the actual boundary of Block VI, approximately >8km from the PAA. As part of the surveys in April 2012, Egyptian vulture was recorded in Blocks II and IV, but it was concluded that they roost, nest and breed in the Nagarparkar tehsil, which is at least 100km from the Project AoI (Mott MacDonald, 2015). As part of the surveys in June 2016, this species was also reported by local people in the PAA (see Volume III).
Threats to vultures are mainly due to anti-inflammatory drugs used to treat domestic livestock which are poisonous to the birds. Other threats include changes in human consumption and processing of dead livestock (BirdLife, 2015a).
Greater spotted eagle (Aquila clanga) is listed as Vulnerable on the IUCN Red List and listed on Appendix II of CITES. The species occupies a fragmented range including small numbers in Pakistan and north-west India. It occurs in lowland forests near wetlands, nesting in tall trees. It feeds on retrieved quarry, small mammals, waterbirds, frogs and snakes and hunts over swamps and wet meadows (BirdLife, 2013a). These habitats are found mainly in the Rann of Kutch Ramsar site, IBA and Wildlife Sanctuary south of the Project AoI. One individual was observed in agricultural fields in Block VI in 2011, approximately 8km west of the PAA.
Imperial eagle (Aquila heliaca) was recorded over 2km from the PAA within Block VI during the October 2011 surveys. It is listed as Vulnerable on the IUCN Red List and listed on Appendix I of CITES. It is a scarce winter visitor to Sindh, it prefers open plains and deserts and avoids high mountainous regions (BirdLife, 2013b).
Red-headed vulture or king vulture (Sarcogyps calvus) has not been confirmed in the Project Aol. It is listed as Critically Endangered on the IUCN Red List and listed on Appendix II of CITES. It was not recorded during the 2009/2010 surveys in Block II (Hagley Bailly, 2014), the 2011 surveys in Block VI (Hagler Bailly, 2013), 2012 surveys in the Tharparkar district (Mott MacDonald, 2015) or 2016 surveys in the PAA. However, the Project AoI falls within the distribution of this species (BirdLife, 2015c). They are a rare occurrence in the Tharparkar area,
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they are usually found in open country away from human habitation, well-wooded hills and dry deciduous forest with rivers (BirdLife, 2015c). Nests have been recorded in tall trees (BirdLife, 2015c), however no tall trees were recorded within Block VI or Block II during the field surveys (Hagler Bailly, 2013).
Great knot (Calidris tenuirostris), globally Endangered, was recorded in 2012 in the Nangarparkar tehsil outside the Thar Coalfields and Project AoI (Mott MacDonald, 2015). This is species is very unlikely to occur in the Project AoI because there are no suitable wetlands for them to winter.
Pakistan lies within the Asian Migratory Flyway, which is used by large numbers of migrating birds from Europe, Central Asian States and India every year. No significant presence of migratory birds has been reported from the Block VI or Block II AoI.
14.4.6 Herpetofauna (reptiles and amphibians) During the 2009/2010, 29 reptile species and two amphibian species were identified as being present or likely to be present within Block II AoI (Hagler Bailly, 2014). During the 2011 surveys, 19 reptile species and one amphibian species were identified within Block VI AoI (Hagler Bailly, 2013). Surveys in the Tharparkar district in 2012 recorded 20 reptile species and two amphibian species (Mott MacDonald, 2015). The June 2016 surveys recorded 10 reptile species in the PAA, including Indian spiny-tailed lizard (Saara hardwickii), saw-scaled viper (Echis carinatus sochureki), Indian desert monitor (Varanus griseus koniecznyi) and black cobra (Naja naja) (see Volume III).
No globally/nationally threatened species were recorded in the AoI of Block VI and Block II, in Tharparkar district in 2012, or in the 2016 surveys in the PAA. Two Pakistani endemic reptile species (striped sand gecko Crossobamon maynardi and Kachh spotted ground gecko Cyrtopodion kachhense) were identified during the 2012 surveys but they were in the Nankarparkar tehsil, away from the Thar Coalfields and Project AoI (Mott MacDonald, 2015).
The Indian desert monitor (Varanus griseus koniecznyi) was observed in all surveys, is listed under CITES (Appendix I). The Indian spiny-tailed lizard (Saara hardwickii), common sand boa (Eryx johnii), chain sand boa (Eryx conicus) and black cobra (Naja naja) were all observed within Block VI and Block II AoI and are listed under CITES (Appendix II). None of these species have been assessed on the IUCN Red List.
One endemic reptile species to Pakistan, the Cholistan desert lacerta (Eremias cholistanica) was found in both Block II AoI in 2009/2010 and Block VI AoI in 2011. Eleven individuals where observed in Block II, mainly in agricultural fields, approximately 7km south-west of the PAA. Two individuals were found in Block VI surveys in plains and agricultural fields, with the closest observation also approximately 7km south-west of the PAA.
14.4.7 Invertebrates The diurnal surveys undertaken in July 2011 in Block VI observed invertebrate specimens (excluding butterflies) belonging to 19 taxa and butterfly specimens belonging to 4 taxa. During the diurnal surveys undertaken in Block VI in October 2011 (post-monsoon), invertebrate specimens belonging to 65 taxa, and butterfly specimens belonging to 14 taxa were found.
The highest abundance of invertebrates observed in July 2011 (diurnal and nocturnal surveys) was within agricultural fields whereas the highest abundance of invertebrates observed in October 2011 was in sand dune habitat. Sand dunes also contained the highest abundance of butterflies in both diurnal surveys.
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No globally/nationally threatened species were recorded in the Project AoI in any of the previous surveys; however, there is little research on invertebrates in Pakistan.
14.4.8 Consideration of critical habitat As part of the ESIA for Block VI Thar coalfield, a critical habitat assessment was undertaken (Hagler Bailly, 2013) using the IFC PS6 (IFC, 2012a) and associated Guidance Note 6 (IFC, 2012b). It was concluded that critical habitat was not present in the AoI of that Project for Block VI. The conclusion is also valid for the Project subject to this EIA.
14.5 Impact identification and assessment
14.5.1 Construction impacts
14.5.1.1 Overview This section presents the identification and assessment of the following potential biodiversity impacts of the Project during the construction phase.
Construction impacts:
● Terrestrial habitat and flora loss and degradation (permanent and temporary) ● Disturbance to terrestrial animal species (eg dust, noise, artificial light) ● Injury or death of terrestrial animals ● Habitat fragmentation ● Accidental introduction and dispersal of invasive species from construction activities, which could have a long-term and irreversible impact on the local biodiversity ● Increase in road kills and injuries of wildlife.
14.5.1.2 Protected areas Rann of Kutch Rasmar site, IBA and Wildlife Sanctuary is located over 22.5km south of the PAA. Due to the distance from the Project site, the identified protected areas are unlikely to be affected by the construction works. The conservation value of the protected area is considered to be very high (international importance), but impact magnitude is negligible. The resulting ecological effects are therefore negligible and not significant.
14.5.1.3 Habitats and flora The Project AoI comprises mainly agricultural fields, sand dunes and sandy plains. The development will result in the permanent loss of small areas of these habitats. The habitat loss will include 15.75ha within the footprint of the Project and 2.25ha on a separate site for the accommodation camp. These habitats are considered to be widespread and of low conservation value, and the impacts of the works will be moderate in magnitude. Therefore, the construction impacts on habitats will be permanent and of minor significance in the absence of mitigation.
The botanical surveys in 2009/2010, 2011, 2012 and 2016 in the Project AoI and wider area indicate mainly common species of flora are present, with no globally or nationally threatened species recorded. These species are generally considered to be of low conservation value. The plant species on site will be directly affected by the development. Indirect impacts on species within the AoI may include increased dust and disturbance through increased traffic. Impacts on flora species are considered to be moderate in magnitude and the impacts will be permanent and of minor adverse significance and not significant.
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Accidental introduction and dispersal of invasive species such as vilayati babul (Prosopis juliflora) and honey mesquite (Prosopis glandulosa) from construction activities could increase the magnitude of the impacts in the absence of mitigation measures as they will compete with native flora. However, the impact would still be of minor adverse and not significant .
14.5.1.4 Fauna Mammals
Land disturbance caused by Project activities will lead to a localised reduction in food, shelter and range for mammals. Surface stripping will result in the removal of vegetation cover and may cause accidental death of small mammals. Artificial lighting and noise during construction will cause disturbance to mammals in the Project AoI. Mammals may also be subject to hunting and poaching by construction staff in the absence of mitigation. However, mammals are mobile and are likely to move away from the area when the works commence.
No mammals of international or national conservation value were confirmed in the Project AoI during the surveys conducted in 2011 (Hagler Bailly, 2013), 2009/2010 (Hagler Bailly, 2014), 2012 (Mott MacDonald, 2015) or 2016 (Volume III). There are records for nationally and globally threatened mammals in the wider area of Thar District (e.g. Indian grey wolf, honey badger) but these species are unlikely to be affected by the Project.
The mammal species recorded in the AoI of the Project are of low conservation value and the construction impacts are considered to be of moderate magnitude. The resulting impact of construction on mammals is temporary and minor adverse and therefore not significant.
Birds Birds are likely to be affected during the construction of the Project because of loss and degradation of habitat, noise, artificial lighting, habitat loss, presence of people, and hunting.
The habitats in the Thar Desert are important for the survival of several globally threatened raptor species. The following species are confirmed in the Project AoI: oriental white-backed vulture or white-rumped vulture (Gyps bengalensis), Egyptian vulture (Neophron percnopterus), long-billed vulture or Indian vulture (Gyps indicus). Both oriental white-backed vulture and Egyptian vulture nest in the Tharparkar district but the known nests are not in the Project AoI. These species are of very high conservation value. Impacts on globally or nationally threatened bird species are considered to be moderate and therefore the resulting impact of construction will be temporary, resulting in a major adverse impact and therefore will be significant in the absence of mitigation.
There are many common species of birds recorded in the Project AoI (Section 14.4.5) and these are of low conservation value. Impact magnitude is likely to be moderate and the resulting impact will be temporary and minor adverse and not significant.
Herpetofauna
Impacts on globally/nationally threatened or endemic reptiles and amphibians are considered to be negligible, given that none were recorded in the Project Aol. The resulting impact is considered to be negligible and therefore not significant.
The common species of reptiles and amphibians in the Project AoI are likely to be affected during the construction of the Project because of habitat loss and degradation, animal deaths and injuries, noise and vibration, artificial lighting and dust. These species are of low conservation value and the construction impact magnitude is likely to be moderate. The resulting impact is temporary and minor adverse and not significant.
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Invertebrates
Habitat loss/degradation, artificial light and dust are likely to have a negative impact on terrestrial invertebrates during construction. The magnitude of these impacts is considered to be moderate. Given the low conservation value of the invertebrates in the Project AoI, the resulting impact of construction is minor adverse and temporary and therefore not significant.
14.5.2 Operational impacts
14.5.2.1 Overview This section presents the identification and assessment of the following potential biodiversity impacts of the Project during operation:
● Increased noise and disturbance to fauna due to increased road traffic for the delivery of coal and exportation of ash and loading of materials ● Disturbance affecting birds and mammals from light and human presence from operation activities ● Increase in road kills and injuries of wildlife ● There is a low pollution risk from the storage of the coal ● Degradation of air quality because of the power plant emissions and ash disposal The following sections assess these impacts in relation to the biodiversity receptors and these sections are therefore organised according to receptor types.
14.5.2.2 Protected areas The Rann of Kutch Ramsar site, IBA and Wildlife Sanctuary is located over 22.5km south of the PAA. Due to the distance from the Project site, the identified protected areas are unlikely to be affected by the operational activities. The conservation value of the protected area is considered to be very high (international importance), but impact magnitude is negligible. The resulting ecological impacts are negligible and therefore not significant.
14.5.2.3 Habitats and flora There are no sensitive habitats on the Project site and Aol that will be affected during operation. The habitats close to the Project may be affected by indirect degradation due to dust deposition or pollution (in the absence of mitigation). The habitats in the Project AoI are of low conservation value and impact magnitude during operation is considered to be minor; the operational impact on habitats and flora is therefore negligible and not significant.
14.5.2.4 Fauna Mammals
Mammals in the Project AoI may be affected by noise, artificial lighting, degradation of air quality, and increase in road kills during the operation of the Project. Mammals may also be subject to hunting and poaching by operational staff in the absence of mitigation. These impacts are considered to be of minor magnitude. The mammal species recorded in the Project AoI are common and of low conservation value. The resulting impact of operation on mammals is therefore negligible and not significant.
The impact magnitude on threatened mammal species of high conservation value is considered to be negligible during operation as these species have not been recorded in the Project AoI.
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The overall operational impact on threatened mammals is therefore negligible and not significant.
Birds
Birds in the Project AoI may be affected by noise, artificial lighting, presence of people, hunting by operational staff, and degradation of air quality during operation of the Project.
The following globally threatened species are known from the Project AoI but there are no confirmed nests there: oriental white-backed vulture or white-rumped vulture (Gyps bengalensis), Egyptian vulture Neophron percnopterus, long-billed vulture or Indian vulture (Gyps indicus). These species are of very high conservation value but impact magnitude during construction is considered to be minor. The resulting impact is therefore permanent and moderate adverse and therefore significant.
The other bird species recorded in the Project AoI are common and of low conservation value. Impact magnitude on these species is likely to be minor and therefore the operational impacts are negligible and not significant.
Herpetofauna
No globally or nationally threatened reptiles and amphibians were recorded in the Project Aol and operational impacts on these species are negligible. The resulting impact is considered negligible and not significant.
The common herpetofauna occurring within the AoI are of low conservation value. During the operation of the Project, these species may be affected by noise, artificial lighting, degradation of air quality, and increase in road kills. Impact magnitude on these species is likely to be minor and therefore the impacts are negligible and not significant.
Invertebrates
The common species of terrestrial invertebrates present within Project AoI are of low conservation value. They may be affected by degradation of air quality and artificial light pollution during the operation of the Project. The magnitude of the impacts is considered to be minor and the overall impact is negligible and not significant.
14.6 Mitigation and enhancement measures
14.6.1 Overview Mitigation measures have been developed for key biodiversity features to ensure the systematic implementation of the mitigation hierarchy i.e. avoid, reduce (minimise), remedy (restore) and offset. This will allow for the careful management of risk, and the best possible outcomes for the Project without compromising the health, function and integrity of the ecological systems.
14.6.2 Avoidance measures incorporated in Project design The design of the Project has taken into consideration the environmental and ecological sensitivities, with the aim to avoid significant impacts on the areas of high nature conservation value, in particular:
● The Project location has been chosen in an area where existing infrastructure can be maximised for the delivery of coal and the transport of waste ash.
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● The Project will comply with safety standards to avoid spillages and leakages from chemicals, liquids and other substances stored onsite. Set procedures will be followed where spillages and leakages do occur.
14.6.3 Generic mitigation measures The following generic mitigation measures will be applied on the Project:
● All construction and operational working areas will be kept to the minimum to reduce habitat loss and degradation. ● Access routes for construction and operational activities outside the existing cleared area (if required) will be kept to a minimum. Plans will be implemented to minimise all construction traffic activities outside the Project area. These actions will significantly reduce potential impacts on habitats and disturbance to species. ● Artificial lighting used on construction sites and camps will be minimised, shaded and directed downwards to avoid light spillage and disturbance to birds, mammals and other wildlife. ● Noise disturbance and vibration will be kept to a minimum through measures such as ensuring proper maintenance of construction machinery and equipment and complying with national standards; ● Measures such as wind breaks and water sprays will be implemented to reduce dust during the working period. ● Spill prevention and response measures will be implemented with regard to refuelling and use of toxic substances to minimise accidental contamination of habitats. ● Enforcement of speed limits along access and haul roads to minimise the risk of road kills. ● Implementation of waste management practices to prevent food waste being left accessible to scavengers. ● Construction and operation staff will be made aware of the importance of biodiversity in the Project area (through staff inductions, posters in site offices, leaflets and signs banning certain activities e.g. no hunting).
14.6.4 Habitats and flora There are no internationally or nationally protected habitats likely to be affected by the Project.
The Project will result in 15.75ha of permanent habitat loss within the main Project site and 2.25ha of temporary loss for the accommodation camp. There will be additional temporary habitat clearance required for the new access road within Block VI.
Light water sprays will be implemented for reduction of dust during construction.
Any habitat clearance required will be restored on-site (if the impact is temporary) or recreated off-site through new planting using native species that do not require special irrigation measures in the long term. Seventy-five trees (mainly kandi Prosopis cineraria and jhar Salvadora persica) will need to be removed within the PAA. Given that tree survival rate in arid environments is relatively low, the 75 trees to be removed should be replaced on-site or off-site at a ratio of 6:1.
14.6.5 Non-native invasive species Non-native (alien) invasive species are the second threat to the global biodiversity after habitat destruction. The likelihood of invasions by non-native species is higher in habitats that are
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altered and disturbed, for example during construction. Invasive species have the following traits:
● Fast growth ● Rapid reproduction ● High dispersal ability ● Ability to alter growth form to suit current conditions ● Tolerance of a wide range of environmental conditions ● Ability to live off a wide range of food types ● Association with humans Any development project poses a risk of spreading invasive species. Two invasive species have been recorded in the Project AoI: vilayati babul (Prosopis juliflora) and honey mesquite (Prosopis glandulosa). Measures to prevent the spread of these species will be implemented in line with the recommendations below.
IFC PS6 (IFC, 2012a) includes the following best practice measures with regard to alien invasive species (AIS):
● Must not intentionally introduce alien species unless this is in accordance with existing national regulatory framework ● Must not deliberately introduce AIS irrespective of national regulatory framework\ ● Introduction of alien species (e.g. in planting) must be subject to a risk assessment ● Implement measures to avoid accidental introduction or spreading of alien species (detailed as follows) ● Consider the implementation of measures to eradicate AIS from natural habitats. Detailed guidelines on the prevention and management of AIS have been published by IPIECA (2010) for the oil and gas industry, but these guidelines are relevant to many other project types, including this Project. Preventative, control and monitoring measures will be implemented with regard to the following aspects of the Project:
Packaging and movement of materials
● Minimise traffic and the distance it has travelled ● Source goods/materials locally where possible ● Contain any AIS and report their presence Vehicles and plant
● ‘As-new’ wash-down is essential before entering non-infested areas and after working in infested areas ● Train and raise awareness regarding AIS ● Pressure wash vehicle tyres in a contained area ● Contain and destroy residue ● Record and report the presence of any AIS Soil and vegetation
● Minimise disturbance to, or movement of, soil and vegetation ● Prevent soil damage and erosion
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● Ensure imported soil/other materials are safe and free of AIS (source from a reputable supplier, request information on the soil’s origin and certification of AIS-free status if possible) ● Prevent AIS establishment on exposed stored soil (do not store bare soil near known sources of AIS, consider using matting to cover exposed soil) ● Ensure infested material is disposed of safely ● Retain as much natural vegetation as possible Habitat reclamation
● Use native plants for reinstatement and landscaping ● Assess any non-native species (to be used in landscaping) for AIS potential ● Consider that some AIS may be soil-based ● Avoid altering soil and waterbody properties
14.6.6 Fauna Habitat loss will be minimised, and where possible a phased vegetation clearance should be undertaken, to ensure animals are able to escape the works area during construction. Noise and disturbance will be minimised through best practice measures during construction and operation.
To minimise the potential impact to all breeding bird species, vegetation clearance will be undertaken outside of the main bird nesting period (breeding season is between April and July). Where clearance is not possible outside the breeding season, a check for breeding birds and active nests by a qualified ecologist will be undertaken within 48 hours of vegetation clearance. If breeding birds are discovered then works will be postponed in that area until the breeding cycle is complete (this may take up to three weeks). A species specific buffer zone (minimum 25 m) will be set up around the nest site.
Deep excavations will be protected (covered up) overnight or when not working to prevent animals being trapped inside. Additionally, ramps will be installed in deep excavations to allow animals to escape. If any animals are trapped in excavations, they will be released into a safe area or an ecologist will be consulted to agree the best course of action.
The following best practice noise reduction measures will be implemented to reduce impacts on birds during construction:
● Avoidance of unnecessary revving of engines and switch off equipment when not required ● Vehicles and equipment will be properly maintained to meet the manufacturers’ noise rating levels. Any silencers or bearings which become defective would be replaced as soon as possible ● Using reverse warning systems incorporating broadband noise where practicable ● Using enclosures for noisy plant such as pumps or generators ● Minimising drop height of materials ● Limiting the use of particularly noisy plant or vehicles where practicable ● Plant and vehicles will be operated with noise control hoods closed. Hunting of wild animals by construction and operation staff will not be permitted. All staff will be required to follow company rules and code of conduct. Any staff member breaching the hunting ban will be subject to disciplinary action.
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It is understood that Sindh Carbon Energy Ltd. (SCEL) intends to prepare a BAP for the management, protection and restoration of vulture species and to prevent the decline in their population due to coal mining and power generation activities in the Thar area. The proposed BAP should incorporate actions relevant to the Project in addition to the coalfields.
The Project will require an electricity transmission line connection of 160km. This is an associated facility, which will be the responsibility of the Government of Sindh. The following recommendations should be implemented:
● The powerlines, masts and towers should be designed in such a way that they do not lead to bird mortality. ● Bird deflector devices should be installed on pylons and conductors to minimise bird electrocution and collision. ● The transmission line pole and insulator design should follow the CMS Guidelines for ‘avian- safe’ lines (Prinsen et al., 2012), African-Eurasian Waterbird Agreement (AEWA) Guidelines (www.unep-aewa.org/), Birdlife International Position Statement on birds and power lines recommendations and suggested practices (Birdlife International, 2013c) and Avian Power Line Interaction Committee suggested practice (APLIC, 2006).
14.6.7 Proposed monitoring Monitoring of ecological mitigation will be conducted for the duration of the construction phase. These requirements, along with associated responsibilities and reporting requirements will be detailed in the CESMP. The Environmental Manager will ensure the measures included in this report and the CESMP are implemented during the construction of the Project. Specialist advice from a qualified ecologist will be obtained when required. The environmental (including ecological) reporting responsibilities during construction will be described in the CEMP.
The compensatory tree planting on-site or off-site will be maintained and monitored for a minimum of five years. Maintenance will involve provision of water, removal of weeds, control of pests and replacement of any dead trees.
Monthly monitoring should be carried out in the first year after construction along the transmission line routes to check for evidence of bird deaths due to electrocution and collisions. If evidence is found of bird deaths resulting from electrocution or collision then appropriate remediation measures should be put in place; this may mean replacing the type or location of bird deflector devices.
14.7 Residual impacts Without mitigation, most of the Project’s impacts are considered to be not significant (minor and negligible). The only significant impacts before mitigation are on threatened birds (major during construction and moderate during operation). All impacts will be significantly reduced through the responsible implementation of the mitigation measures, which are described in Section 14.6.
After the successful implementation of the mitigation measures, there will be no significant residual impacts.
Table 104 summarises the residual impacts of the Project on the key ecological features which occur within the AoI.
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Table 104: Summary of Project impacts before and after mitigation Receptor Potential Conservation Impact Impact Mitigation Residual Impacts importance magnitude significance impacts (sensitivity) Construction Protected areas Rann of Kutch Impacts Very high Negligibl Negligible None required Negligible, (Ramsar site, unlikely as High e not IBA and Wildlife these sites significant Sanctuary) are more than 22km from the Project site Habitats and flora Widespread Loss and Low Moderate Minor Pollution Minor, not habitats: sand degradation of prevention, significant dunes, sandy habitat reduction of dust, plains, and best practice agricultural fields measures to minimise habitat loss and degradation Common flora Direct loss Low Moderate Minor Pollution Minor, not species and prevention, significant degradation of reduction of dust, common flora and best practice within the measures to Project area. minimise habitat Introduction of loss and invasive degradation. species Measures to competing prevent/minimise with native the spread of flora invasive species. Notable fauna Common Loss, Low Moderate Minor Avoidance or Minor, not mammal species fragmentation minimisation of significant and habitat loss and degradation of degradation. habitats Phased habitat Disturbance clearance. from noise, Best practice light pollution measures to and human reduce noise. presence Pollution Increased prevention. dust and Hunting ban by pollutants construction staff. from construction Hunting by construction staff Threatened bird Habitat loss Very High Moderate Major Avoidance or Minor, not species and and High minimisation of significant degradation habitat loss and Disturbance degradation. because of Phased habitat noise, lighting clearance. and presence Best practice of people measures to reduce noise.
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Receptor Potential Conservation Impact Impact Mitigation Residual Impacts importance magnitude significance impacts (sensitivity) Hunting by Pollution construction prevention. staff Hunting ban by construction staff. Pre-construction checks for nesting birds. Common bird Habitat loss Low Moderate Minor Avoidance or Minor, not species and minimisation of significant degradation habitat loss and Disturbance degradation. because of Phased habitat noise, lighting clearance. and presence Best practice of people measures to Hunting by reduce noise. construction Pollution staff prevention. Hunting ban by construction staff. Pre-construction checks for nesting birds. Common Habitat loss Low Moderate Minor Avoidance or Minor, not herpetofauna and minimisation of significant species degradation habitat loss and Disturbance degradation. because of Phased habitat noise, lighting clearance. and presence Best practice of people measures to reduce noise. Pollution prevention. Common Habitat Low Moderate Minor Pollution Negligible, terrestrial loss/degradati prevention and not invertebrate on, artificial best practice significant species light and dust measures to minimise habitat loss and degradation. Operation Protected Areas Rann of Kutch Impacts Very high Negligible Negligible None required. Negligible, (Ramsar site, unlikely as High not IBA and Wildlife these sites significant Sanctuary) are more than 22km from the Project site Habitats and Flora Widespread Dust Low Minor Negligible Pollution Negligible, habitats: sand deposition prevention not dunes, sandy and air measures. significant plains, pollution agricultural fields Common Loss and Low Minor Negligible Pollution Negligible, species degradation of prevention. not common flora significant
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Receptor Potential Conservation Impact Impact Mitigation Residual Impacts importance magnitude significance impacts (sensitivity) due to pollution. Introduction of invasive species competing with native flora
Notable Fauna Common Disturbance Low Minor Negligible Best practice Negligible, mammal species from noise, measures for noise not light pollution and lighting. significant and human Pollution presence prevention. Increased Hunting ban. dust and Speed limits. pollutants Increase in road kills Hunting by operational staff Threatened birds Disturbance Very High Minor Moderate Best practice Minor, not from noise, measures for noise significant light pollution and lighting. and human Pollution presence prevention. Increased Hunting ban. dust and pollutants Hunting by operational staff Common bird Disturbance Low Minor Negligible Best practice Negligible, species from noise, measures for noise not light pollution and lighting. significant and human Pollution presence prevention. Increased Hunting ban. dust and pollutants Hunting by operational staff Common Disturbance Low Minor Negligible Best practice Negligible, herpetofauna from noise, measures for noise not species light pollution and lighting. significant and human Pollution presence prevention. Increased Hunting ban. dust and Speed limits. pollutants Increase in road kills Common Degradation Low Minor Negligible Best practice Negligible, terrestrial of air quality measures for noise not invertebrate and artificial and lighting. significant species lighting Pollution prevention.
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15 Social impact assessment
15.1 Introduction
15.1.1 Overview of the assessment This chapter looks at how people and communities may be affected as a result of the Project in terms of the way they live, work and interact with one another on a day-to-day basis. The broad objectives of this assessment are to ensure that key potential socio-economic and community impacts have been identified, assessed, mitigated and managed in a consultative and constructive manner.
Social and community impacts have been assessed and identified as significant in relation to employment generation and the potential influx of workers. Consideration has also been given to avoiding and mitigating any potential impacts related to occupational and community health as well as safety and security risks from construction activities resettlement and land acquisition.
Environmental impacts from construction activities could also have a cumulative impact on local community receptors such as schools and hospitals, however to avoid double counting of impacts these have been addressed within their respective chapters and are not covered again here. Specifically: air quality and dust impacts are assessed in chapter 7 and noise and vibration are covered in chapter 9.
15.1.2 General approach The process followed has been one of analysing, monitoring and managing the intended and unintended socio-economic and community consequences - both positive and negative - of the Project, and any social change processes invoked by the interventions.
The socio-economics and community assessment undertaken for this ESIA has been carried out to meet Pakistani requirements. The approach and methodology draws on guidance for social impact assessment by the International Association for Impact Assessment (IAIA) 36 . The IAIA conceptualises social impacts as changes to one or more of the following:
● People’s way of life – how they live, work, play and interact with one another on a day-to-day basis ● Their community – its cohesion, stability, character, services and facilities ● Their culture – their shared beliefs, customs, values and language use ● Their environment – the quality of the air, water, food, amenity, safety and pollution risks ● Their health and wellbeing – physical, mental, social and spiritual wellbeing and perceptions of safety ● Their personal and community property rights – access issues and economically affects Adverse impacts will be avoided and wherever possible, management and mitigation measures have been identified to reduce their effects on the community. Where impacts are beneficial, measures are designed to enhance the effects and share their benefits more widely, in particular amongst local people who may also be affected negatively by the Project.
36 International Association for Impact Assessment, Social Impact Assessment: International Principles, May 2003.
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15.2 Applicable legislation and standards
15.2.1 National requirements
15.2.1.1 EIA consultation requirements The Pakistan Review of IEE and EIA Regulations (2000) and the SEPA (Review of IEE and EIA) Regulations (2014) state that in the case of an EIA being conducted for a project, the following consultation requirements are to be met by the Federal Agency in charge:
● A public notice is to be issued in English and Urdu in a local newspaper within the project area. The notice should contain: a) the name of the project, b) its exact location, c) the name and address of the proponent and d) the places where the EIA can be accessed. ● The public notice issued should contain the date, time and place of the public consultation to be held with stakeholders, where they are able to provide comments on the project and its EIA. ● Public consultation should not be earlier than 30 days after the date of publication of the public notice. ● The EIA must be circulated to all relevant government agencies. ● All comments received by the Federal Agency from the public and/or any government agency shall be collated, tabulated and duly considered before finalising the EIA. The Guidelines for the Preparation and Review of Environmental Reports (1997) state that in order for the environmental and social assessment to be credible, fair and transparent, full public involvement should be a part of the process. This should include:
● Making all environmental reports available to the public ● Publishing lists of decisions – including the requirement for an EIA and the final outcome of environmental approval ● Public availability of any recommendations for mitigation and impact management plans According to the Guidelines for the Preparation and Review of Environmental Reports (1997), good ways to disseminate the information contained within the EIA include local language video, radio and television, presentations, newsletters and information sheets, displays (supported by members of the study team), gatherings such as local community groups, small meetings and workshops.
The Guidelines for Public Consultation (1997) deal with approaches to public consultation and techniques for designing an effective program of consultation that reaches out to all major stakeholders and ensures the incorporation of their concerns in the impact assessment. These guidelines will be applied when undertaking the consultation for this Project.
15.2.1.2 Labour, occupational health and safety and resettlement legislation Labour rights are established in the constitution of Pakistan. Labour laws are elaborated on national level through acts and ordinances that cover specific issues including limits to working hours, minimum working age and conditions of employment.
Of the 24 labour-related laws that existed in 2014 in Pakistan (Pasha, 2014), the following relate directly to the International Labour Organisation (ILO)’s Core Labour Standards which Pakistan has ratified:
● Bonded Labour System (Abolition) Act, 1992
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● Employment of Children Act (ECA), 1991 (prohibits child labour in Pakistan under the age of 14) ● Minimum Wages Ordinance, 1961 ● Industrial Relations Act, 2010 ● West Pakistan Minimum Wages for Unskilled Workers’ Ordinance, 1969 There are no laws covering equal remuneration for male and female workers undertaking work of equal value and removal of discrimination in respect of employment and occupation.
Key labour market regulatory requirements that are relevant to maintain labour rights for this Project include (World Bank, 2014; Paycheck, 2015; The Nation, 2013):
● Maximum length of a single fixed-term contract: 9 months ● Maximum working days per week: 6 ● Premium for work on weekly rest day (% of hourly pay): 100% ● Maximum length of probationary period: 3 months ● Notice period for redundancy dismissal (average for workers with 1, 5 and 10 years of tenure): 4.3 salary weeks ● Severance pay for redundancy dismissal for a worker with 1 year of tenure: 4.3 salary weeks Health, safety and welfare of workers at factories, construction sites and labour camps are addressed in the Factories Act of 1934 (as amended). These regulations will be applicable to the Project and particularly during construction. They place responsibility on the EPC contractor to provide a healthy and safe environment to workers, including workers of subcontractors. The relevant provincial labour department is responsible for taking the necessary measures to ensure compliance with the Factories Act. There is no requirement to obtain any permit or license from the Labour Department to start construction of the Project.
15.2.1.3 Land acquisition The only national legislation currently relating to land acquisition and compensation is the Land Acquisition Act (LAA) of 1894. Under the LAA, the provincial revenue departments are empowered to carry out the acquisition of private land or built-up property for public purposes, including on behalf of a federal agency or a private developer. The LAA is limited to a cash compensation policy for the acquisition of land and built-up property, and damage to other assets, such as crops, trees, and infrastructure based on market rates.
15.3 Methodology and assessment criteria
15.3.1 Scope of assessment The Project has been assessed by comparing the existing social baseline conditions with the change expected over time as a result of the Project. The temporal scope of assessment includes the following phases of the Project:
● Resettlement and site preparation: Lignite Mining Project will implement resettlement from Q4 2016 - 2019 ● Main construction phase: Expected to commence in 2020, lasting up to 2023 ● Operations: Expected to commence in 2021 ● Decommissioning: The plant is expected to have a lifetime of at least 30 years and an assessment of any works necessary to keep the plant operating will be undertaken at that time.
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The spatial scope of the social and community assessment has been defined by geographical and administrative boundaries. Pakistan is divided into four territories and four provinces including the Sindh province where the coal fields have been discovered. The Sindh province is divided into 29 districts including the Tharparkar district where the Power Plant Project is located.
The Thar Coalfield is spread across an area over 9,000 km² within the district of Tharparkar and is located approximately 380km east of the province capital, Karachi. Tharparkar is further divided into six 37 talukas 38 . The Project’s impacts have been assessed at three scales and baseline data is presented for each:
Table 105: Project area of Influence Area of influence Location Wider Area of Influence (WAI) Islamic Republic of Pakistan Local Area of Influence (LAI) The Sindh Provide District of Tharparkar Talukas (Mithi, Diplo, Islamkot, Nagarparkar, Chachro and Dahli) Immediate Area of Influence (IAI) Five villages in Block VI: Ranjho Noon, Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Salar ji.
15.3.2 Data sources Information for this assessment has been obtained from a number of secondary data sources including the ESIA of the Block VI Lignite Mining Project (2013), the SESA (2014) and the interim RAP (2013) as well as the national census (1998) and information provided by international financial institutions. In addition, in June 2016, primary data on the affected communities within the Project’s IAI was obtained through focus group undertaken by local consultants. The chapter uses this information to reflect on the socio-economic situation of the local population.
15.3.3 Significance criteria The significance of an impact has been determined by the interaction between its magnitude, and the sensitivity of receptors affected. Professional judgement has been used by appropriately qualified social scientists when assigning significance. The use of these two concepts for this assessment is outlined below.
The sensitivity of receptors has been estimated through consideration of their socio-economic vulnerability. This is measured by their capacity to cope with social impacts that affect their access to, or control over, additional or alternative social resources of a similar nature, ultimately affecting their wellbeing. Sensitive or vulnerable receptors are generally considered to have less means to absorb adverse changes, or to replicate beneficial changes to their resource base than non-sensitive or non-vulnerable receptors.
When considering sensitivity, the type of resources in question varies between receptors. For example, a community’s vulnerability has generally been measured in terms of its resilience to loss of community facilities, whereas an individual’s vulnerability has generally been considered in relation to their resilience to deprivation and loss of livelihood assets or opportunities (such as jobs, productive land or natural resources). Impacts that increase impoverishment risks
37 Mithi (district headquarters), Diplo, Islamkot, Nagarparkar, Chachro and Dahli, even though during the last census (1998) only four have been reflected 38 A taluka is an administrative area which has a town or city as its administrative centre and is usually surrounded by a number of other settlements.
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contribute to vulnerability. Impoverishment risks include landlessness, joblessness, homelessness, marginalisation, increased morbidity and mortality, food insecurity, loss of access to common property resources and social disarticulation. Table 106 presents the guideline criteria that have been used to categorise the sensitivity of receptors.
Table 106: Sensitivity criteria Sensitivity of Definition receptors High An already vulnerable social receptor with very little capacity and means to absorb proposed changes or with very little access to alternative similar sites or services. Medium An already vulnerable social receptor with limited capacity and means to absorb proposed changes or with little access to alternative similar sites or services. Low A non-vulnerable social receptor with some capacity and means to absorb proposed changes and with some access to alternative similar sites or services. Negligible A non- vulnerable social receptor with plentiful capacity and means to absorb proposed changes and with good access to alternative similar sites or services. Source: Mott MacDonald
The magnitude of an impact has been determined by consideration of the extent to which it results in social receptors gaining or losing access to, or control over, socio-economic resources resulting in a beneficial or adverse impact on their individual and collective wellbeing. Wellbeing is considered as the financial, physical and emotional conditions and quality of life of people and communities.
For beneficial impacts, the extent to which local wellbeing is likely to be enhanced has been considered. This is in accordance with the international movement in social impact assessment practice with increased focus on enhancing long-term development benefits for local communities’ sustainability, as opposed to only considering mitigation of adverse effects. As such, the magnitude criteria include consideration of the extent to which benefits are shared with and or realised by local people and communities.
The assessment of magnitude has been undertaken in two steps. Firstly, key social impacts associated with the Project and their related beneficial and adverse, direct and indirect, and cumulative effects have been identified. Secondly, the magnitude of impacts and their impacts have been categorised as either major, moderate, minor or negligible based on consideration of the parameters listed below along with professional judgement:
● Likelihood ● Duration ● Scale – number of people or groups affected ● Spatial extent Table 107 summarises the typical varying degrees of impact magnitude.
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Table 107: Magnitude criteria Magnitude (beneficial or Definition (considers likelihood, duration, number of people adverse) affected, spatial extent and local benefit sharing) Major A highly likely impact that would have implications beyond the Project life affecting the wellbeing of many people across a broad cross-section of the population and affecting various elements of the local communities’, or workers’, resilience. Moderate A likely impact that continues over a number of years throughout the Project life and affects the wellbeing of specific groups of people and affecting specific elements of the local communities’, or workers’, resilience. Minor A potential impact that occurs periodically or over the short term throughout the life of the Project affecting the wellbeing of a small number of people and with little effect on the local communities’, or workers’, resilience. Negligible A potential impact that is very short lived so that the socio-economic baseline remains largely consistent and there is no detectable effect on the wellbeing of people or the local communities’ or workers’, resilience. Source: Mott MacDonald
The relationship between sensitivity and magnitude and how this is used to determine significance of impacts is depicted in the overall significance matrix presented in Chapter 5.
15.3.4 Assumptions and limitations Key limitations are related to the absence of readily available secondary data for a range of factors and the obstacles in place to accessing official data. The latest national census was completed in 1998, which means that a large part of the data available is outdated. Where possible more recent data has been used. Surveys conducted in 2012 as well as the results from the focus groups and interviews with affected stakeholders within the LAI and IAI in 2016 have been used to verify official statistics or address information gaps. Where discrepancies in data have arisen, either the latest data has been used or the source has been named in order to verify its origin.
15.4 Baseline description
15.4.1 Overview The sections below present an analysis of the baseline socioeconomic and community profile according to the following topics:
● Demographic profile ● Local residential and community land-use ● Economy, employment, education and skills ● Education and skills ● Ecosystem services ● Access to electricity, water and sanitation, and transport ● Health ● Ethnicity, religion and caste ● Language ● Governance ● Gender relations ● Poverty, deprivation and vulnerable groups ● Cultural heritage
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15.4.2 Demographic profile In 2015, the estimate for Pakistan’s population was 199,085,847. The median ages for male and female were similar and the population was relatively young. The population pyramid for Pakistan is presented in Figure 37. The 2015 estimated growth rate was 1.46% and life expectancy was higher for females (69.4 years) than males (65.47 years). Figure 37 reflects the age distribution in Pakistan and shows a young population with approximately 30% of the national population aged 14 or younger. The working aged population (age 15-64) comprises 63% of the total population and the elderly (65 years and older) make up only 4%.
Figure 37: Pakistan’s population pyramid
Source: https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html, accessed 15 August 2016
Nearly two thirds of the Pakistani population lives in rural areas, with only 39% of the total population living in urban areas 39 . The overall rate of urbanisation is 2.8% (estimated annual rate of change from 2010-2015) 40 .
At the last census, the population of the Tharparkar district was approximately 914,291 people, with a population density of 47 persons per km 2 (1998)41 , which increased to 65 persons per km 2 by 2011 42 . The population has been predicted to increase significantly to 1,407,585 in 2012 and
39 CIA World Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html . Reviewed 15 August 2016 40 Ibid. 41 Source: District Census Report of Tharparkar, 1998, Population Census Organization, Statistics Division, Government of Pakistan 42 Pakistan Economic Survey (2011)
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3,659,404 by 2043 43 . Approximately 95% of the population was classified as rural. The urban population is located in three main towns - Mithi, Islamkot and Diplo. Figure 38 illustrates the location of the towns within the district. The rural population is located within approximately 2,321 villages, ranging in size from less than 50 to over 5,000 persons.
Figure 38: Distribution of population within the Tharparkar District
Source: Thar Coal Land Use Plan
Table 108 shows the population in the Tharparker District (last updated 1998). During the last census there were only four talukas. Currently there are six talukas. Table 108 also includes the projected population figures for 2012.
Table 108: Population in four talukas in the Tharparkar District (last updated 1998) Taluka Population 1998 Projected Population 2012 Male Female Urban Rural Total Chachro 202,276 155,481 - 357,757 357,757 550,780 Diplo 87,013 74,867 9,703 152,177 161,880 249,220 Mithi 129,143 112,405 30,124 211,424 241,548 371,872 Nagarparkar 81,427 71,679 - 153,106 153,106 235,712 Total 499,859 414,432 39,827 874,464 914,291 1,407,585 Source: National Census Pakistan 1998 and SESA 2013
43 Thar Coal Field Land Use plan
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The IAI consists of five villages with a total population of 2,250 people 44 . Initially there were six villages in Block VI; however the village of Kharo Jani is in the process of being resettled as part of the Block VI Lignite Mining Project. As of September 2016, the land ownership survey is underway and potential resettlement sites within the Block are being identified. Table 109 outlines the population living in the IAI (excluding Kharo Jani).
Table 109: Population within IAI No. Village name No. of households No. of people 1. Ranjho Noon 480 1,400 2. Yaqoob ji Dhani 5 21 3. Yousuf ji Dhani 120 600 4. Gangoo ji Dhani 17 65 5. Salar-ji-Dhani 14 95 Total 636 2,250 Source: Mott MacDonald Pakistan
15.4.3 Local residential and community land-use The Ministry of Environment in Pakistan uses ten categories of land classifications, including forest, agricultural land, open Ground/ fallow, exposed rocks, desert built ‐ up area/land, waterlogged and saline land, water bodies and snow/glaciers. Forest cover including scrub, riverain, mangroves and plantation is about 5% in the country. Agricultural land including irrigated, rainfed and rodkohi agriculture extracted from spectral reflectance of crop cover is about 20%. It does not include the fallow land which has been covered under open space/ground class (covering about 10% area of country). Rangelands covered over 27%, while rock outcrops occupied another quarter of the country. The snow/glacier coverage was recorded at about 2%. Deserts have about 10% and other uses (built up area, waterlogged and saline land and water bodies together accounted for a little more than one percent) 45 .
In the Sindh province mangroves are the main forest types covering 3.5 % of the province. These are concentrated on the Indus delta in the southern part of the province. Along the Indus River there are Riverain Forests covering an area of 1.4%. Tree plantation and orchards are mainly in the farm lands. The predominant agriculture is irrigated cultivation that covers 25.8% area of the province. Some Rod ‐kohi agriculture is also practiced in the province. Deserts areas cover about 22% of the western part of the province. Due to low gradient, water logging and salinity problem has occurred and covers about 2% of the area in the province 46 .
The Project is located in the western part of the Sindh province, in the desert area, which is why the LAI and the IAI are considered hostile environments to live in. The key natural feature that dictates the location of settlements is the availability of grazing land and land that can be used for cultivation of crops. Land covered with sand dunes has limited utility for grazing and cultivation and as such one of the major challenges for the people of the Tharparkar district is to find land for cultivation and grazing purposes. The LAI is 61% covered with sand dunes whereas only about 39% is categorized as plain land. Availability of water is also an important factor as it is required both for drinking and household needs as well as for the livestock.
44 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016
45 Ministry of Environment in Pakistan, 2009 46 Ibid.
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Monsoon and inconsistent rains result in a short agricultural growing season with agricultural activities occurring at a subsistence level only 47 . Although the majority of households use communal lands called gaucher land for livestock grazing, the socio-economic survey conducted as part of the Interim Resettlement Plan 48 found that 23% of the people affected by the Project had their own land. Settlements are typically located at the edge of land that can be cultivated. Settlements generally start when persons belonging to a single caste or tribe find an area which can support subsistence farming as well as livestock population.
15.4.4 Economy, employment and income Pakistan is a low-income country with economic growth of only 3.5% per annum (from 2008 - 2013). The gross domestic product (GDP) has been increasing since 2012, and was estimated to have grown by 4.2% in 2015. Services were the greatest contributor to GDP (estimated at 55.5% in 2015), with agriculture making up 25% and industry 19%. Important agricultural products include cotton, wheat, rice fruits and vegetables. Main industries include textiles and apparel, food processing, pharmaceuticals and construction materials. Pakistan’s exports are heavily reliant on its textiles and apparel industry 49 .
Agriculture is the biggest employer (43.7%) with services and industry also making important contributions (33.9% and 22.4 % of the labour force respectively). Pakistan is one of the main sources of labour for the Middle East and as a result remittances are an important source of revenue for many households. Unemployment is estimated at 6.5% (2015) although this is believed to significantly underestimate the true picture 50 .
The Sindh province plays a pivotal role in the national economic and development agenda. It has the highest concentration of urban population at 49%, as compared to an overall country average of 37%, making it the most urbanized and economically developed province of Pakistan. However, the Tharparkar district is largely rural (96% according to the 1998 census) and represents the most underdeveloped area in the Sindh province. The contribution of Sindh province to the national Gross Domestic Product (GDP) is around 33%, the second highest after the Punjab province. In addition, Sindh contributes 70% of the country‘s income tax revenues and 62% of its sales tax revenues. The high level of industrialisation in the Sindh province comes from the fact that the province is home to half of the country‘s textile and sugar units, 20% of the pulp and paper mills, and 35% of edible oil industry; accounting for 34% of Pakistan‘s total industrial capacity in large-scale manufacturing and 25% of small-scale manufacturing 51 .
Within the Tharparkar district, agricultural and livestock activities are the main source of income for the people. The district has more than 22% of all the livestock of the Sindh province according to a survey conducted in 2008 52 . Agriculture depends on rainfall, which is often erratic and falls between July and September only. After the rains, the desert subsoil aquifers are recharged and the pasturelands are regenerated. However, by February, the aquifers are often depleted and the pasturelands dry up.
Generally, livestock in the Tharparkar district depends on grazing in pastures and crop residues. The duration of livestock tenure (or share agreement) between livestock owners and shepherds
47 Draft SESA Report May 2013 Updated (2015) 48 Hagar Bailly, Interim Resettlement Action Plan, 2013 49 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html 15 August 2016 50 Ibid. 51 Ibid. 52 Herani G., Wasim P., Rajar A., Riaz S., Livestock: A Reliable Source of Income Generation and Rehabilitation of Environment at Tharparkar, 2008
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is typically 4, 6 and 7 years for goats and sheep, cows, and camels, respectively. The shepherds are responsible for looking after the animals, whereas the owner shares the cost incurred on purchase of fodder and medicine equally. Animals are sold with consent of both the owner and the shepherd. In addition to sharing, livestock herding is also done by hiring shepherds to look after the herd on daily or monthly wage basis. Women are especially involved in livestock herding and play an important role in this occupation.
In Tharparkar district, 21.4% of the people migrate due to a lack of employment and 10.3% due to marriage 53 . Men of those households who have enough resources to leave their dependents behind usually undertake migration, whereas poorer families are forced to migrate entirely. Majority of the households from Tharparkar district migrate seasonally for four to six months. Migration period usually starts from February onwards to provide labour for harvesting wheat and cutting sugarcane in the irrigated areas of Sindh province such as Sanghar, Mirpurkhas, Shadipali, Kunri and Nawabshah. These seasonal migrants move back in time to sow and harvest their own crops during the monsoon season.
Except for livestock farming, there are very limited opportunities for income generation. Salt is exported from Diplo and other areas. However due to the lack of transportation the granite and china clay found in the Nagarparkar region are currently extracted in limited quantities. There is little industry in the district although it is rich in mineral resources. There are no major industrial units. The Tharparkar district industry includes two ice factories, over 700 carpet making centres and 59 local flour mills (Atta Chakies) 54 . Commerce centres around handicrafts, wood works, sheep wools and carpets. Handicrafts are skills common amongst Thari’s. Shawls made of silk, wool or cotton, handmade bed sheets, Khes of goat 55 and camel hair skin and wool blankets are some of the major products. Although these types of income generating activities typically provide low revenues for the producers, interest has grown in the carpet industry with some villagers moving away from agriculture to carpet weaving with the number of carpet looms increasing 56 .
The focus group discussions conducted in the IAI confirm that unemployment is high in the five IAI villages and that agriculture is the main form of employment. The majority of men migrate seasonally, as described above, in order secure an income for their families.
15.4.5 Education and skills The estimated national literacy rate in 2015 was low at only 57.9%, with higher rates amongst men (69.5%) compared to women (45.8%). The average number of years of education a child can expect to receive is eight (nine years for males and seven for females) 57 . According to the 1998 Census, the literacy ratio in the Tharparkar district was 18.3% (28% of men and 7% of women). A higher proportion of the urban population were literate (57%) compared to rural (16%).
Literacy rates in the Tharparkar district are below those of the Sindh province and Pakistan as a whole. Net education enrolment rates have increased for both sexes from 59% in 2002 to 73% in 2014 58 . However, a number of factors continue to make it challenging such as the proximity of
53 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016
54 Draft SESA Report May 2013 55 Black goat’s hair shawl 56 Inception Report 2011 57 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html 15 August 2016 58 UNESCO Institute for Statistics, 2016
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schools for rural students, low numbers of female teachers, shortages of secondary and tertiary educational institutions and absence of basic facilities such as electricity in most schools. Education for girls is particularly challenging with only 15 schools for girls in the whole district 59 . Social constraints do not allow girls to travel long distances alone and the shortage of female teachers further limits the educational opportunities.
The majority of the population within the IAI is illiterate (numbers range between 70%-90% 60 illiteracy between the villages), with only a small amount of the population being educated, and only to primary school level. Limited availability of schools and teachers along with the fact that school aged children are often engaged in income generating activities, like labour or maintaining of livestock herds, means there is little chance for education. The existing schools in the IAI are in poor condition and teachers are unavailable to fill the required positions. Table 110 shows the number of primary schools within the affected villages located in Block VI.
Table 110: Number of Schools inside Block VI Village Name No. of Schools Ranjho Noon 2 Yousuf Ji Dhani 1 Salar Ji Dhani 1 Gangoo Ji Dhani 0 Yaqoob Ji Dhani 0 Total 4 Source: Mott MacDonald Pakistan
15.4.6 Ecosystem services Ecosystem services refer to the benefits that people obtain from ecosystems and are often grouped into four categories: supporting services, provisioning services, regulating services and cultural services. In the LAI people utilise provisioning ecosystem services - natural resources used to support their income and livelihoods. These include food, medicinal plants, raw materials making things, water and energy. Cultural ecosystem services – natural resources which provide spiritual, cognitive, reflective, recreational or aesthetic benefits - are also accessed. Examples of natural resources that support incomes and livelihoods, and cultural traditional identified within the LAI are briefly outlined below 61 .
● Calotropis procera (Ak) – it is a useful tree that grows on the sides of small dunes. The wood of ak is used in the construction of houses. Cotton like material extracted from this plant is used in making pillows 62 . It is also used for making ropes which are used for drawing water from wells. ● Tecomella undulata (Rohiro) – this tree grows in the fields and on the sides of sand dunes. The wood of rohiro is very strong and valuable. Its wood is used for making furniture and toys and baskets are made from the sticks. ● Acacia senegal (Konbat) – the wood of konbat tree is used to make plows. ● Prosopis cineraria (Kando or Kandi) –the wood is used to make pulleys used in drawing water from wells.
59 Socio-Economic & Environmental Aspects of Coal Mining in Tharparkar District, 2009, Thardeep Rural Development Programme, Karachi, quoted in IA Block VI Lignite Mining Project, 2013 60 Focus Group Discussion conducted by Mott MacDonald Pakistan, 2016 61 EIA Block VI Lignite Mining Project, 2013 62 Nadiem. I. H., 2001, Thar, The great Pakistan desert: Land, History and People, Lahore, Sang-e-Meel Publications.
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● Salvadora oleoides (Khabar Jar) – The wood of khaber jar is used in the construction of houses. ● Ziziphus nummularia (Ber) – the wood of this tree is useful for certain crafts. People make handles of spade and axe from its wood as well as wooden frames that can be placed on the camel’s back and used for sitting. ● (Bairi) – the roots of this plant are used for making churning pots as well as water containers. ● Plants such as Amaranthus viridis (Pipon) and Momordica charantia (Karela) are also used by the locals as vegetables ● Herbs such as (thali), (laks), (marhas), Citrullus colocynthis(tooh), Amaranthus viridis (pipon), (marero) and Momordica charantia(karela) have various medicinal uses and are used by the locals for curing human ailments such as gastric problems and diabetes. ● Shrubs are used to provide fodder for the grazing animals ● Leptadenia pyrotechnica or (Khip) – this shrub is used to make mats, ropes and building material for houses ● (Sen) – this shrub is used for making ropes, fodder for livestock and thatching of homes. ● Dondhan) –the fluffy material from this shrub is collected by local people and sold or used to make pillows. ● Mud and clay is used in the construction of houses ● Capparis decidua (Karer) – the wood of this tree is used for making musical instruments such as Alghoza (double flute) and flutes. ● (Kado) – The wood of this plant is used for making flutes. People collect a variety of herbs from sand dunes, thali (land lying between two sand dunes), pastures (which are located in dahars), laks and marhas to cure various human ailments. Herbs are also used to cure livestock diseases. Women are more knowledgeable about the use of herbs. The most preferred herbs are tooh, pipon, marero and karela (bitter gourd). Tablets, made from the paste of tooh, are used for gastric problems whereas pipon is used for diabetics. Many Tharis also use pipon as vegetable. Likewise, karela, used for diabetics, is also used as vegetable by people in the local area 63 .
15.4.7 Access to electricity, water, sanitation and transportation Pakistan’s total installed capacity is 24,38 MW (2014 estimate). Its electricity consumption is 78,890GWh (2013 estimate) and it currently imports 392GWh (2013 estimate). Approximately two thirds of the country’s total installed capacity is generated from fossil fuels, with nearly a third from hydroelectric plants and only 3% from nuclear fuels 64 . Only 6.75% of households in the Tharparkar district have electricity. Most households (92.5%) use kerosene oil. Kerosene use is higher in rural areas (95%) compared to urban areas (31%) 65 . Villages surveyed for the Lignite Coal EIA did not have access to electricity. Outside Block VI, only 35% of surveyed villages had electricity and no one used natural gas. Households surveyed used fuel wood and charcoal as cooking fuel 66 .
In 2015, most of the national population were estimated to have access to improved drinking water; with urban rates being slightly higher than rural (93.9% compared to 89.9%). In
63 ESIA Block VI Lignite Mining Project, 2013 64 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016 65 Draft SESA Report May 2013 Updated, sourced from the 1998 census data for Tharparkar 66 ESIA Block VI Lignite Mining Project, 2013.
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comparison, the Tharparkar district has poor water and sanitation provision. It was ranked the lowest district in terms of water supply and sanitation coverage within Sindh province and nationally within the 10 bottom districts. Availability of piped water is negligible with only 2% of households having access - 34% of urban households compared to 1% of rural households.
In the Tharparkar district many households use well water for their basic needs. Some wells are government owned although many dug wells are owned and operated by the communities themselves. However only 48% of the water from wells can be considered fit for human consumption due, in part, to the salinity of the groundwater. The availability of hand pumps across the district is low and they are therefore only used by 1.2% of households. Rainwater for drinking is also collected by most households using traditional channels called tarais, underground and overhead tanks, and earthen jars although these are not considered to be efficient collection systems 67
Across Pakistan, 83% of urban populations have access to improved sanitation facilities compared to 51% of the rural population (estimated in 2015) 68 . At the district level, most of the rural population defecates in or near cultivated fields. Less than half of urban sewage is drained off through sewers and only a small fraction of that is treated before being disposed of into water bodies. The lack of sanitation facilities and poor hygiene is identified as one of the main causes of communicable infections within the country 69 .
Within the Study Area the distances of the blacktop and unsealed roads are 20km and 127km, respectively. In addition, there are 27km of unsealed tracks that are available for travel for most part of the year except between July and September when fields are cultivated.
The main mode of transport in the district is by road. Transport facilities are in the form of passenger vans, which traverse different parts of the district. In some parts of the district, traditional means of transport, mainly transport by camels, are still used. Kekra, a form of local transport made from the army trucks belonging to the World War II period and locally adapted for desert use, has been a reliable mode of transport in the Thar Desert and is still used for travel through the desert along the sealed and unsealed roads (see Figure 39 and Figure 40).
Figure 39: Modes of Transport in the Study Figure 40: Modes of Transport in the Study Area - Kekra Area – Travel by Camel
67 Draft SESA Report May 2013 Updated 68 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html . 15 August 2016 69 Draft SESA Report May 2013 Updated
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Tharparkar has limited access and communications which adversely affects its economy. There are only 195km of paved roads across the district. A mobile phone service is available through the wireless local loop system, although main line telephones are not available 70 .
The focus group discussions held in the IAI provide confirm that there are no clean drinking water and sanitation facilities available in the affected communities. Furthermore, electricity is not available in any of the settlements within Block VI.
15.4.8 Health Life expectancy in Pakistan remains relatively low at 67.39 years. There is a disparity between life expectancy for males which is 65.47 years and for females at 69.4 71 . The main causes of mortality in Pakistan are non-communicable diseases (heart disease, stroke, chronic obstructive pulmonary disease and diabetes), communicable diseases (lower respiratory infections, diarrhoeal diseases and tuberculosis); and ante and post-natal complications (preterm birth complications, birth asphyxia and birth trauma, neonatal sepsis and infections) 72 . Infectious diseases that are prevalent in Pakistan include bacteria diarrhoea, hepatitis A and E, and typhoid fever (food / or waterborne diseases); and dengue fever and malaria (vectorborne diseases) 73 .
Infant mortality is high, with Pakistan ranking 26 th in the world (55.67 deaths / 1,000 live births). Maternal mortality is also relatively high with 178 deaths / 100,000 live births, ranking 44 th in the World (both estimated in 2015) 74 . Malnutrition amongst children is high with a third of children under five years underweight (ranked 11 th in the World). Prematurity, acute respiratory infections, birth asphyxia, diarrhoea and neonatal sepsis are the most common causes of deaths in children under five years (2013) 75 .
The Tharparkar district has the lowest Human Development Index 76 of all districts in the Sindh province. It is one of the most impoverished and marginalized areas of the Sindh province with almost 90% of households living below the poverty line. High levels of total dissolved salts (TDS) and fluoride in underground water coupled with lack of easy access to clean drinking water and sanitation facilities contribute to the health issues faced by the local population. Waterborne diseases are very common throughout the desert area of Tharparkar. Unsanitary conditions and lack of awareness of personal hygiene are attributed to a rise in hepatitis B and C with almost 25% of population suffering from it. Skin conditions such as scabies, psoriasis and fungal infections affect 25-40% of the population of various villages and are also linked to sanitation and hygiene. Maternal mortality is high in Tharparkar. Unskilled birth attendants, lack of gynaecologists at hospitals, traditionally women not visiting town hospitals and inability to pay for delivery expenses are contributory factors. Malaria is also common in the monsoon season.
70 Draft SESA Report May 2013 Updated 71 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html . 15 August 2016 72 Pakistan WHO statistical profile. http://www.who.int/gho/countries/pak.pdf?ua=1 . 15 August 2016
73 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html . 15 August 2016 74 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html . 15 August 2016 75 Pakistan WHO statistical profile. http://www.who.int/gho/countries/pak.pdf?ua=1 . 15 August 2016 76 UNDP Pakistan http://hdr.undp.org/en/countries/profiles/PAK
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According to 1998 Census, Tharparkar District has one civil hospital, three taluka hospitals operated by the District Health Office (DHO), two rural health centres, 30 basic health units, two maternity and child welfare units and 40 district council dispensaries. There was one hospital bed for every 7,000 persons in Tharparkar district and only one doctor for every 11,000 persons.
The focus group discussions conducted in the IAI revealed that the most common health impacts were malaria and snake bites. In addition, the local population has to travel long distances to reach the towns of Islamkot or Mithi and pay prohibitive prices in order to receive medical treatment. Furthermore, according to the Infrastructure Baseline and Spatial Referencing Report, there is only one basic health facility located in Block VI 77 , which means the area is underserved in terms of health services.
15.4.9 Ethnicity, religion and caste An ethnic group is defined as members of any culture who share certain beliefs, values, habits, customs and norms 78 . There are a number of ethnic groups represented within Pakistan: Punjabis make up the largest group 94.7%), followed by Pashtun (15.4%) and Sindhi (14%). Distinctions may arise due to language, religion, historical origin, geographic isolation and kinship. In the Tharparkar District Hindus and Muslims form the two ethnic groups and are further sub-divided into multiple castes. Table 111 gives the percentage distribution of population by main religious groups, in the Tharparkar District. Muslims are in majority, forming 59.4% of the district‘s population. However, in and around the IAI and LAI Hindu community is in majority, where the population of Hindus and Muslims is 62% and 38%, respectively.
Table 111: Tharparkar District population in percentage by religion, 1998 Religion All areas Urban Rural Muslim 59.4% 29.5% 60.8% Hindu 40.5% 69.6% 39.1% Others 0.1% 0.9% 0.1% Source: District Census Report of Tharparkar, 1998, Population Census Organization, Statistics Division, Government of Pakistan
Hindu and Muslim societies have caste systems which is a social class separated from others by distinctions of hereditary rank, profession, or wealth. It carries a different meaning for the Hindus and Muslims. Muslim castes are divided into sub castes and further into lineages. For example, the Langa caste is divided into sub-castes Dodani and Chanesarani, which are further divided into Mithani and Gulani lineages. The Hindu caste structure follows the traditional Varna model. According to this model, there are four castes or jatis, namely Brahman (priest), the Kshatriya (noble), the Vaishya (commoner), and the Shudra (servant) 79 . The main caste among Hindus included Brahman and Rajpoot (Thakur). Bajeer is a common caste for both Muslims and Hindus. The Scheduled castes (commonly Hindu) included Menghwar, Bheel and Kohli 80 .
Caste also defines peoples’ occupations. Menghwars originally were mostly involved in leatherwork. They were known for skinning dead animals (for leather related work) and hence were referred to as dhed. They have now set themselves apart by devoting themselves to occupations such as weaving and opportunities involving higher education skills. The Bheels initially led a nomadic life and migrated seasonally to the irrigated areas for labour, occupying
77 Infrastructure Baseline and Spatial Referencing Report, Mott MacDonald Pakistan, 2013 78 This section does not cover indigenous peoples as per the World Bank or IFC definitions, Indigenous peoples will be addressed further in the mitigation section 79 Focus Group Discussion with five affected villages in Block VI, Mott MacDonald Pakistan 80
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their home villages for only a few months in a year. They are now involved in other occupations, such as, farming and services. Kolis, the only original inhabitants of the Tharparkar District, were the poorest and least established members of society. Originally, hunters and soldiers, the Kolis now live by herding and farming.
A tribe is a social division in a traditional society consisting of families or communities linked by social, economic, religious, or blood ties, with a common culture and dialect, typically having a recognized leader. There are three main tribes represented within the Tharparkar district – Rajputs, Baloch and aboriginal Dravadians. Within the LAI and IAI the main tribes amongst Muslims are Syed, Baluch, and Rajputs.
15.4.10 Language In Pakistan, although Urdu is the official language it is spoken by only 8% of the population. Punjabi is the most common language spoken (48%), followed by Sindhi (12%) and Saraiki (a variant of Punjabi) (10%). The main language of Tharparkar district is Sindhi (97%-99% have it as their mother tongue); other languages spoken include Urdu, Dhatki, Balochi, Saraiki, Gujrati and Parkari 81 .In the IAI the most common language used by Muslims is Sindhi and the language most commonly used by Hindus is Dhatki. However most Muslims and Hindus understand and converse in both languages 82 .
15.4.11 Governance The Islamic Republic of Pakistan has a federal parliamentary system with a president as head of state and a popularly elected prime minister as head of government. The president, in keeping with the constitutional provision that the state religion is Islam, must be a Muslim. He or she is elected for a five year term and is eligible for one re-election 83 .
Seats in the government are allocated to each of the four provinces, the Federally Administered Tribal Areas, and Islamabad Capital Territory on the basis of population. National Assembly members serve for the parliamentary term, which is five years, unless they die or resign sooner, or unless the National Assembly is dissolved. Although the vast majority of the members are Muslim, about 5 % of the seats are reserved for minorities, including Christians, Hindus, and Sikhs. Elections for minority seats are held on the basis of separate electorates at the same time as the polls for Muslim seats during the general elections 84 .
Pakistan's four provinces enjoy considerable autonomy. Each province has a governor, a Council of Ministers headed by a chief minister appointed by the governor, and a provincial assembly. Members of the provincial assemblies are elected by universal adult suffrage. Provincial assemblies also have reserved seats for minorities. Although there is a well-defined division of responsibilities between federal and provincial governments, there are some functions on which both can make laws and establish departments for their execution. Most of the services in areas such as health, education, agriculture, and roads, for example, are provided by the provincial governments. Although the federal government can also legislate in these areas, it only makes national policy and handles international aspects of those services 85 . The law and order situation in the district is generally peaceful. Fewer than 0.5% of registered
81 Draft SESA Report May 2013 Updated (2015) 82 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016 83 US Federal Research Division of the Library of Congress, 2016 84 US Federal Research Division of the Library of Congress, 2003 85 Ibid.
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criminal cases in Sindh, were from Tharparkar (35 out of 11,900 registered criminal cases) 86 . There are 14 police stations in the district; none of which are located in the study area.
The traditional governance system of villages with multiple castes residing in them is different from that in the villages with a single-caste. In villages with a single caste the wadero, if the caste is Muslim, or the patel, if the caste is Hindu, are the village heads. Minor disputes such as family feuds are resolved by the village wadero or patel. In villages with multiple castes, each Shudra caste has its own patel and they are subordinates to the patel of Thakur caste or wadero of the Muslim caste, if the Muslims are also residing in the same village 87 .
Apart from the wadero and patel, there also exists a village council or the panchayat for Hindus. Amongst the Muslim, wadero holds the ultimate political influence in a village. However, the council of the elders also works with the wadero in tandem. Each elder in the council represents his respective lineage. Panchayat and patel are losing their influence rapidly, while the wadero is gaining authority amongst the local IAI communities. This could be because in comparison to the patel, the wadero has more influence outside of the IAI, in the local government 88 .
15.4.12 Gender relations The 2014 World Economic Forum ranked Pakistan 141 of 142 countries worldwide for gender equality, with only Yemen performing worse. In 2012, a World Bank report detailed the difficulties Pakistani women face in gaining access to capital due to social constraints — needing permission from a male to even qualify for a loan, for example. According to the study, 50% to 70% of microloans given to women in Pakistan may actually be used by their male relatives 89 . Men are the main breadwinners in Pakistani society, while women are mainly involved in domestic activities. Recent efforts have been made to enhance the status of women, for instance by including women on elected bodies. Legal reforms and an allocation of seats within parliament have resulted in an increase in the number of seats held, 21% of seats in Parliament are women 90 .
There are some organisations working to improve gender equality and provide more opportunities for women in Pakistan. The Citizens Foundation, a non-profit organization, runs schools across the country, encouraging female enrolment with the goal of having its campuses gender balanced. The Kashf Foundation, founded in 1996, became the first microfinance institution in Pakistan to target women from low-income communities. The First Women Bank was founded in 1989 to support businesswomen. Pakistan’s Small and Medium Enterprises Development Authority (SMEDA) also provides support for female entrepreneurs 91 .
In the IAI, for all castes, the male household head was found to be primarily responsible for external and internal household affairs. He is not only responsible for representing the household in the village and wider community, but he is also the person who takes all of the decisions within the household. Women do however play a major role in supporting the household and in addressing food security and nutritive wellbeing. In the IAI women are responsible for cooking, dishwashing, milking livestock, looking after children and the sick, fetching water, washing clothes, and collecting fuel wood. In addition, women belonging to the poorer households help in agricultural work in the fields along with male family members and
86 Development statistics of Sindh, 2006, published by Sindh Bureau of Statistics, Government of Sindh. 87 Hagar Bailly, Interim Resettlement Action Plan, 2013 88 Ibid. 89 Women, girls and Malala: Research on gender and education in Pakistan, and beyond, Harvard Kennedy School, 2014
90 Draft SESA Report May 2013 Updated 91 Women, girls and Malala: Research on gender and education in Pakistan, and beyond, Harvard Kennedy School, 2014
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migrate with them to provide farm labour in the irrigated areas of Sindh for four to six months of the year. Most women, regardless or religion or caste, are also involved in making handicrafts like embroidered sheets and clothes, although income from selling these handicrafts usually goes to the male household head.
15.4.13 Poverty, deprivation and vulnerable groups One third of Pakistan’s population continues to live in poverty, corresponding to some 50 million poor individuals. Women and children (out-of-school/working), disabled, and potentially the elderly, are the most vulnerable groups of poor. The poor live mainly in rural areas, are unskilled, and work in the informal sector. Employment opportunities are scarce and real earnings have declined in the last decade. The poor also lack in all of the basic physical and productive assets and have limited or no access to essential social services.
After the Balochistan province, the Sindh province is considered to have the highest rural poverty incidence at 31%. According to the Social Policy Development Center (SPDC) in 2005 indicated Tharparkar as the second-most deprived district in Sindh, ranking it 15 th out of 16 districts. According to the Thardeep Rural Development Program (local Non-Governmental Organisation) the population living below the poverty line is 28.92% 92 .
In the IAI around 52% of the households fall below the poverty line and are amongst the most vulnerable 93 . In addition, there are seasonal migrants (21.4%), ethnic minorities and female headed households, who are all considered vulnerable groups 94 .
15.4.14 Cultural heritage There are a number of sites of religious, cultural and archaeological significance in the Thar Desert area which include the hills of Karunjhar, sacred Hindu temples in Nagarparkar, Gaomakhi Waterfall, Bhemgoda Pond, Chandan Garh Fort (built in 1859) and Naukot Fort 95 .
Muslim places of worship include mosques and shrines, and Hindu places of worship include temples and shrines (Figure 41 and Figure 42). All villages in the IAI have mosques and most have temples. Shrines are located in only some of the villages. The same shrines can have religious significance for both Muslims and Hindus although would be known by different names. Shrines with mutual significance and dual identities can be seen in many parts of lower Sindh and South India 96 . Hindu and Muslim religious buildings are usually constructed differently. Muslim shrines are generally called dargah and are roofed buildings decorated with stucco. Hindu shrines known as than (open-platform) are usually simple or open-platforms. Shrines are generally found outside the house or at the entrance of the cluster whereas temples are mostly located inside the house.
92 http://www.thardeep.org/thardeep/tharparker.html 93 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016 94 Ibid. 95 ESIA Block VI Lignite Mining Project, 2013 96 Ibid.
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Figure 41: Places of Worship in Study Area Figure 42: Places of Worship in Study Area - Mosque in Ranjho Noon - Temple of Rama Pir in Mansingh Bheel
Previous archaeological surveys in the Thar desert have suggested some form of pastoral nomadic culture in the region dating back at least 7,000 years. There is potential in the area for nomadic burials of considerable antiquity 97 . The area also has potential for the presence of Palaeolithic (130,000 years bp) and Mesolithic (15/10, 000 year bp) activity often in the form of stone tool and lithic/flint scatters on sand dunes and around saltwater basins 98 . The archaeological and historical evidence does not suggest the presence of any major civilization associated with large towns or cities within Block VI. However, such a possibility cannot be entirely discounted. Although there are no major water courses close to the Project area there are small ephemeral channels that capture run off during and after heavy rainfall and these temporary water bodies may have attracted seasonal/temporary settlement in prehistoric and historic periods.
Historic religious architecture includes a mosque and some Jain temples scattered over southern Thar, around the small town of Nagarparkar (132km from Mithi). The potential for the presence of archaeological remains associated with major/urban settlements within the Thar area is low 99 .
There are no known pre-historic archaeological sites located in the IAI. This was confirmed by focus group discussions conducted with the affected villagers. The nearest federally protected 100 archaeological site to Block VI is located about 30km to the east. In the Thar desert. There are documented archaeological sites including the hills of Karunjhar and sacred places of worship for Hindus and Jains in Nagarparkar. Site of possible archaeological significance include the Gad of Mirs (Talpurs) located about 5 km south of Block VI in the south of Seengaro Village, and Thario Halepotto, a ruin dating to the Buddhist period and located in Islamkot about 6 km away 101 .
97 Ibid. 98 Ibid. 99 ESIA Block VI Lignite Mining Project, 2013 100 Sites protected by the Federal Government of Pakistan under the Antiquities Act 1975. 101 Ibid.
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15.5 Likely impacts and assessment of significance
15.5.1 Overview This section identifies and assesses the construction and operational phase significant impacts for the construction and operational phases of the Project. Social impacts that are predicted to be ‘Major’ or ‘Moderate’ are classified as significant. The significant impacts identified in relation to this Project are employment generation and influx management. Additional potential Project risks are also discussed in relation to occupational and community health, safety and security and labour rights and resettlement and land acquisition. As detailed earlier in section 15.1.1, the various environmental impacts (air quality, noise, dust, traffic) from construction impacts are assessed in their respective chapters and are not covered here to avoid double counting of impacts.
15.5.2 Construction impacts
15.5.2.1 Construction phase short term employment generation Temporary employment generation will result from the construction of the Project components and associated facilities. Construction phase employment is expected to peak at approximately 1,000 workers. The skills base in the community is low and therefore affected stakeholders would only be able to access unskilled labour jobs such as manual labour as well as provision of services for workers such as food and refreshments, cleaning of accommodation, sanitation and hygiene. Women will have even more limited opportunities for employment due to cultural and societal perceptions and customs.
A key social impact will be the provision of an income source for workers and their families contributing to their wellbeing and enhancing their quality of life, particularly in the case of migrant workers who will not need to travel to benefit from this employment. Considering also the high incidents of poverty in the IAI (52%) and the prevalence of vulnerable populations, local employment can provide particularly important benefits for them. Although the construction jobs will be temporary, the skills and experience gained will benefit future job prospects as workers are likely to develop new and or enhance existing skills. Construction activities will provide temporary but greater livelihood security. Indirect socio-economic benefits will result from workers earnings being spent on local goods and services.
Local jobseekers are considered to have high sensitivity due to the poverty levels and high demand for employment. The magnitude is considered to be minor due to the relatively low number of jobs that will be available to local workers and the temporary nature of the impact. As such, construction phase employment is considered to be moderate beneficial, and therefore significant.
15.5.2.2 Population influx The simultaneous construction of the coal power plant in Block II (adjacent to Block VI), the open pit mine in Block VI and this coal power plant in Block VI means that there is likely to be a large number of non-local workers coming into the area. While some of the construction jobs will be accessible to local workers, there will be need for outside skills. Considering that the local population is only 2,250 people, even an influx of 500 workers would constitute 20% of the local population. The extent of migration is usually determined by project characteristics and a number of factors which have been given consideration are provided in Table 112, below.
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Table 112: Key factors leading to high rates of influx and adverse social impacts Influx factor Analysis Scale of project: This Project has a three year construction period and has a construction workforce of around larger projects attract more 1,000 people and could therefore be attractive to additional migrants also. migrants There will be two additional projects (one mine in Block VI and one coal power plant in Block II) with similar sized work forces being construction at the same time. Area’s capacity to meet project The Project is located in the Thar Desert, which is a poor and deserted part of the country. needs/population density of The local capacity to cope with population influx is very low, as there is high incidents of project area poverty and low availability of infrastructure and social services. Opportunities for compensation The adjacent mine project resettled a village of a total of 1,200 people and provided and benefits speculation compensation and land. Given that it is a remote area, it is possible that the resettlement is not widely known, as even some of the people living within the Project area appear unaware. However, given that there are three construction sites there might be cumulative benefits that are considered attractive. Conclusion: Overall, the Project is expected to attract external workers and some opportunistic economic migrants or ‘camp followers’ during the construction phase. In addition, given the remote location and the inability of locals to deal with influx at present it is considered a significant impact Source: Mott MacDonald based on IFC 2009 guidance on IFC Handbook Project-Induced In-Migration.
Local people are considered to have high sensitivity due to their poverty levels, limited access to social services and their remote location. Influx has the ability to bring about cultural changes and cause people to feel out of place in their own home. In addition, there is an increased risk of disease, insecurity and overburdening of already inexistent social services. The magnitude is considered to be moderate as there will be multiple construction sites at the same time. As such, construction phase influx is considered to be major adverse , and therefore significant .
15.5.2.3 Construction phase loss of ecosystem services As noted in section 14.5.1.3, the Project will result in the permanent loss of a small area of agricultural fields, sand dunes and sandy plains including 15.75ha within the footprint of the Project and 2.25ha on a separate site for the accommodation camp. These habitats are considered to be widespread. and no individuals or communities have been identified as depending on these resources for their livelihoods or subsistence or for nonmaterial cultural benefits. The Project is expected to have a negligible impact on ecosystem services and therefore is not significant .
15.5.2.4 Construction phase impacts on cultural heritage The Project will not have any direct adverse impacts on religious facilities, or known prehistorical or archaeological sites in the IAI. However, there is potential within Block VI for archaeological finds ranging from Palaeolithic, early Prehistoric through to later Prehistoric archaeological and artefactual. The magnitude is considered to be moderate given the potential for permanent loss of archaeological finds within the Project footprint. The construction of the Project is expected to have a low adverse on cultural heritage and therefore is not significant .
15.5.3 Operational impacts
15.5.3.1 Employment generation The operational phase is expected to generate fewer direct employment opportunities than the construction phase with the number of skilled jobs to perform maintenance and operation of the plant estimated at approximately 200-300. Some roles such as office staff may be performed by the same personnel as in the construction phase, so the actual number of new jobs created may be slightly lower. Many of the positions will be skilled roles and it is not known at this stage how many will be available to local community members with limited skills sets.
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The majority of the job seekers that will benefit are likely to have some existing skills and therefore more livelihood opportunities than the construction workforce. The potential employment opportunities for operational workers are considered to have moderate sensitivity. The impact magnitude is considered to be negligible to minor due to the relatively low number of jobs and the necessary skills needed. According to these categorisations, the impact of operational is considered to be a negligible to minor beneficial impact, and therefore not significant .
15.6 Potential risks
15.6.1 Overview Whereas the previous sections discussed social impacts that are considered highly likely to occur, this section discusses potential social risks that could occur but are less likely. The Project will take a precautionary approach to avoid and mitigate risks through appropriate social management measures.
15.6.2 Land acquisition and resettlement The Government of Sindh in conjunction with Mott MacDonald developed a resettlement policy/strategy in 2013 for the entire Thar Coalfield, which encompasses all developments in Block VI. The Developer and its consultants then developed an Interim Resettlement Action Plan (RAP) in 2013 which is compliant with Pakistani and international IFC requirements and outlines all of the land acquisition and resettlement activities to be conducted in Block VI. Following the enactment of the Government of Sindh’s Resettlement Policy Framework – Thar Coalfields (RFP) in May 2015 the Interim RAP was updated to conform with the Government’s RPF.
The village of Kharo Jani with a population of 1,200 (160 households) and much of its cultivated lands, is the only village to be displaced. The resettlement process is currently undergoing as part of the Block VI Lignite Mining Project (2013). The 2011 Resettlement Framework and the above mentioned interim RAP, which have been the guidance documents for undertaking the resettlement. The remaining villages will not experience resettlement or land acquisition for the next 40 years, as this is when phase II of the Block VI lignite mining project is likely to take place, which could have further resettlement impacts.
In the unlikely event that there is potential resettlement, the interim RAP will need to be updated to a compliant RAP for the affected people and the procedures that will need to be followed.
15.6.3 Occupational health and safety and labour rights Site preparation, construction and operational activities pose the following main OHS risks to workers:
● Exposure to physical hazards from use of heavy equipment ● Trip and fall hazards ● Exposure to dust, noise and vibrations ● Falling objects ● Exposure to hazardous materials; and exposure to electrical hazards from the use of tools and machinery ● Working at height, with live power equipment and lines ● Exposure to electro-magnetic fields (EMFs)
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There will likely be 400 workers accommodated on site which poses potential risks to the health, safety, security and therefore wellbeing of construction workers if not managed appropriately. Health and safety issues associated with the use of temporary accommodation sites include those relating to sanitation, disease, fire, cultural alienation, sleeping space, quality and quantity of food, personal safety and security, temperature control and recreation, amongst others.
There are risks to workers’ wellbeing through delayed payment of wages, potential for forced or child labour and people working without contracts and other safeguards. Similarly, there is the risk of adverse occupational health and safety impacts related to personal accident or injury on any construction site. Some of the OHS risks which could arise during the construction phase of the Project, and are typical to projects of this type of facility include: exposure to physical hazards from use of heavy equipment and cranes; falling from height; foundation pits/trenches; working in confined spaces; trip hazards; exposure to dust and noise; falling objects; electrocution risks. Risks specific to the Project location include exposure to extremes of climate.
Whilst workers on the Project, particularly sub-contracted construction workers, are vulnerable to risks to their health safety and wellbeing on a daily basis, the Pakistani regulatory standards provide some protection. Appropriate planning and execution of health and safety management planning, workforce management measures and accommodation management must be undertaken by the EPC contractor and the Developer to reduce the risks as far as possible.
15.6.4 Community health, safety and security There are a number of activities in the construction phase which if not mitigated could cause risks to local communities. Increased traffic volumes may result in road safety risks and can affect the already vulnerable population in adverse ways. The Project will need to conduct a traffic awareness raising program and ensure that people understand the risks and dangers faced.
There could be a health and safety risk to the local community posed by the existence of construction sites and possible presence of armed security guards. Access to construction sites by community members presents health and safety risks similar to those described in section 15.6.3 above and the presence of the construction workforce presents a risk of spread of sexually transmitted infections and increased pregnancies amongst local women. Air quality and noise impacts are discussed in chapters 7 and 9.
15.7 Mitigation and enhancement measures
15.7.1 Stakeholder engagement and grievance management A stakeholder engagement plan (SEP) will be produced as part of the Project’s environmental and social management system (ESMS). The SEP should be developed and implemented during both the construction phase of for the lifetime of the Project. The SEP will reflect the ESIA consultation requirements outlined in section 15.2.1.1 in order to enable the Project to comply with the necessary stakeholder engagement legislation. Moreover, due to the high levels of vulnerability in the IAI, the SEP must include sufficient channels for stakeholder engagement and grievance redress in order to mitigate any adverse impacts that might occur and could affect the local community.
The SEP must be used as a management tool using a culturally appropriate approach to information disclosure and consultation. The SEP will coordinate, guide and maximise the full value of the engagement processes for the Project. Participation of stakeholders, in particular those who are directly affected, is considered essential to realising the full benefits of the
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Project. The SEP will include identification and analysis of stakeholders including vulnerable groups. Planned stakeholder engagement activities, responsibilities and timelines will be included in the strategy, including disclosure and consultation activities
The SEP will include a community grievance mechanism with grievance reporting and resolution procedures and roles and responsibilities of CLOs in terms of grievance management. The contact details of the CLOs will be disclosed to stakeholders, especially Project affected communities prior to construction commencing.
15.7.2 Local content strategy A local content strategy needs to be developed in order to enable local people to benefit from the creation of employment opportunities and thus facilitate that the high demand for local employment is met. To this end, the Developer has developed a recruitment and skills development policy which outlines the establishment of an employment liaison forum. The forum is designed to engage local representation to assist the recruitment process and to thus facilitate that local cultural and religious traditions are taken into consideration when developing working practices and working patterns. This forum will meet on a regular basis to ensure local concerns are addressed as they arise.
This policy does not directly refer to the hiring of local people but the Developer has made a commitment to hire as many local people as possible in order to enable the maximum benefit for the local population. The ESMP will contain a framework for a local content strategy and the Developer’s existing recruitment and skills development policy will be developed further to specifically include local recruitment.
The local content strategy will include requirements for job opportunities to be disclosed locally to Project affected peoples, with priority in recruitment given to vulnerable populations. The strategy will include the means by which local people hired on a short-term basis during construction can obtain permanent contracts on the Project during the operational phase.
In addition, to maximise job opportunities for local people, the local content strategy will need to facilitate skills development of the local workforce. The local content strategy will reflect the Developer’s commitments (as per their recruitment and skills development policy) to adhere to non-discriminatory practices and opportunities should be made available to all local people regardless of their ethnicity, caste, religion, gender or age. The overarching aim should be to provide longer-term benefits to local people beyond the lifetime of the Project, therefore enhancing everyone’s future employability.
15.7.3 Occupational health and safety plan In order to mitigate the large amount of risks associated with working on construction sites and safeguard worker’s well-being, an OHS plan is required to identify preventative and protective measures to protect the health and safety of workers on-site. The Developer has developed HSE policies and an EPRP.
Mitigation measures that must be covered in the Developer’s OHS policy will include the following:
● Exposure to physical hazards from use of heavy equipment ● Trip and fall hazards ● Exposure to dust, noise and vibrations ● Falling objects
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● Exposure to hazardous materials; and exposure to electrical hazards from the use of tools and machinery ● Working at height, with live power equipment and lines ● Exposure to EMFs ● Working in confined spaces ● Proper use of PPE by all workers ● Contractor to have an appropriately equipped first aid room and staff to address workers’ and communities’ health needs ● Site safety awareness training ● Monitoring and reporting of accidents, injuries, lost-time incidents, near misses and community interactions on health issues ● Worker accommodation monitoring ● Tool box talks on hygiene and sanitation at least every six months ● Good housekeeping on site ● Control and quality assurance of drinking water ● Pest and vector control activities ● The plan will cross reference the workers code of conduct that has been developed by the Developer, which outlines rules by which workers have to abide by in order to safeguard against any harmful practices that might affected the local communities and/or other workers on site.
15.7.4 Community health and safety plan There are a number of activities during the construction phase which need to be mitigated in order not to cause any risks for local communities. Therefore, a community health and safety plan will be developed to safeguard local community members and the public. It will include but not be limited to measures to address:
● Appropriate signage and fencing ● A site registry system to prevent unauthorised access to the public ● Safety exclusion zones ● Traffic management measures ● Health screening for nearby residents ● A safety awareness campaign The traffic management measures will need to include: an awareness raising campaign for local populations, adequate signage, speed restrictions and circulation restriction of vehicles, particularly at night.
The plan will cross reference with other relevant management plans such as the OHS Plan and the SEP. Local health care and emergency services will be consulted in the development of the plan.
15.7.5 Site security plan There are a number of potential safety risks for local communities associated with large scale construction sites. In order to ensure these are adequately mitigated a Site Security Plan has been developed to manage security arrangements and safeguard the human rights and wellbeing of members of the public and local communities when encountering security
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providers. The plan will make a commitment to comply with national law and Project’s approach is underpinned by the principles of proportionality and good international industry practice. The plan must include provisions for:
● Responsible hiring (including vetting for past criminal offences) ● Training ● Means of security and equipment ● Use of force and weapons ● Access and incidence logging ● Community grievance mechanism (summary of that presented in the SEP) ● Use of government security ● The plan also provides contract details of the Project management and specifies monitoring measures.
15.7.6 Influx management plan An influx management plan should be produced to avoid and mitigate the effects of Project- induced migration, particularly the non-local workforce that will be present on the three local construction sites (Block II – coal power plant, Block VI – open pit mine and Block VI – coal power plant). This would include consideration of the following measures to be undertaken in consultation and in partnership with regional government (key stakeholders will be spatial planners) and civil society:
● Organising Project recruitment and employment to minimise potential workers going to the Project site ● Ring-fencing community investment funds for spatial planning and to support local initiatives to address greater demand for social and community services and infrastructure. The company should develop a dedicated community investment plan, outlined in section 15.7.7 below. ● Holding influx forums every year during construction to bring together stakeholders and service providers to create awareness of influx status, share monitoring data, identify lessons learned, and disseminate good international industry practice ● Supporting financial management through providing financial management seminars to workers, and consulting with the Government to promote presence of banking and micro finance services for local entrepreneurs and small and medium businesses in the IAI. NGOs working specifically with women must be able to participate in order to enable women to benefit from these allocated funds. In addition, the Project should ensure that workers are provided with their own health services such as an onsite clinic and relevant medical staff. Furthermore, the company should provide transportation for workers to access hospitals outside of the IAI in the case of emergencies. The other two developments in Block VI and II will also need to ensure that their workers are provided with adequate health facilities and safety measures are put into place in order for there to be no cross over of influx.
15.7.7 Community investment plan A needs-based community investment plan (CIP) should be developed and implemented to help mitigate the potential adverse impacts of Project-induced in-migration and to share Project benefits more fully with local communities. The CIP should be implemented in partnership with local and regional Government authorities, local leaders, NGOs and civil society bodies which
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have local ties with communities. Local peoples will be trained and hired as cadres to implement programmes. Funds will need to be ring-fenced with annual disbursement budgets disaggregated between programmes.
The assessment identified that the following interventions could contribute to local development:
● Agriculture – to support agricultural production, for instance through rural extension support and training in farming techniques as well as value chain benefits such as storage, access to markets, and inputs; livestock activities could be supported with veterinary services, animal feed, animal housing, and services for animal health and production. ● Livelihood diversification – technical training could be provided in alternative livelihoods such as sewing, equipment repair, and hospitality; this could be accompanied with capacity building in financial management and accountancy and access to micro-credit or savings and loans facilities or cooperatives. ● Education and health – Education services could include support to schools in terms of infrastructural improvements and materials such as books, uniforms, and computers; education infrastructure could be improved, for instance the provision of toilet facilities at existing schools, and the building of schools for girls; capacity building could be provided for local teachers; health infrastructure could be improved, for instance provision of clinics and services. The education and health measures should be undertaken in partnership with the Government and local civil society organisations to ensure sustainability and maintenance. ● Community infrastructure – including community solar lighting, clean water wells, road maintenance. The SEP and the influx management plan should align with the CIP. The CIP will need to include monitoring against clear key performance indicators. Annual revisions made to the CIP should use monitoring results to feed into the budget allocation process each year.
15.7.8 Chance find procedure The Project will not need to conduct an in-depth archaeology study, as there is not enough substantiated information that leads to the belief that there is considerable cultural heritage present in the area. However, the Project will need to develop a chance find procedure to mitigate for the possibility of uncovering historical remains, antiquity or any other object of cultural or archaeological importance that are unexpectedly discovered during construction phase.
15.7.9 Worker accommodation plan A Worker accommodation plan (WAP) will be required for both the construction phase and the operations phase in order to mitigate any impacts to workers and community members caused by the provision of temporary accommodation being provided for 400 workers on site.
The WAP should follow the EBRD/IFC guidance note on Worker’s Accommodation: Processes and Standards (2009) as good industrial industry practice. In particular, the WAP will need to address: sleeping areas; sanitary and toilet facilities; canteen, cooking and laundry facilities; standards for nutrition and food safety; medical facilities; and leisure, social and telecommunication facilities, considering different requirements for local and expatriate workers.
The WAP should ensure there is a management team responsible for the hygiene, safety and security of accommodation. The plans need to consider ways of safeguarding workers’ valuables, perhaps through the provision of individual safe boxes that can be stored safely and accessed as required. Workers will not be charged for accommodation and related services. If
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there are charges, these will be identified in the WAP and when workers sign their contracts. House rules and regulations that are reasonable and non-discriminatory will need to be included in the WAPs once workers’ representatives are consulted about them.
Employees’ living and working conditions will need monitoring. Government labour inspections are not systematic, often leaving work camps and construction conditions that are not compliant with basic occupational safety to continue unchecked. Monitoring of accommodation conditions will need to be addressed in the WAP and undertaken using the checklist in the IFC guidance note. Monitoring will be undertaken on a quarterly basis until at least two reporting periods have identified no corrective actions, after which monitoring can be six monthly.
15.7.10 Gender strategy A gender strategy should be developed as part of the ESMP to cover both the construction and the operations phase to ensure that women are able to access the benefits of the Project. The gender strategy will aim to:
● Raise gender awareness of the different roles and responsibilities within the community, the economy and agricultural production ● Implement a gender mainstreaming component in all Project related plans and programmes ● Suggest practical and measurable gender actions and targets to be achieved as a result of the Project and related programmes The gender strategy actions will be strongly connected to other plans and programmes related to the Project and harmonised with other management plans.
15.7.11 Indigenous peoples Although local people do not auto-identify as indigenous 102 , there are a number of different ethnic and religious groups in the IAI as outlined in Section 15.4.9 that could be considered indigenous. The Project should conduct an assessment to determine if any of these groups are considered indigenous as this would mean they could require additional mitigation measures. The Project should use the IFC PS7, which provides the most up-to-date guidance (2012). The IFC defines the characteristics for indigenous peoples as follows:
● Self-identification as members of a distinct indigenous cultural group and recognition of this identify by others ● Collective attachment to geographically distinct habitats or ancestral territories in the Project area and to the natural resources in these habitats and territories ● Customary cultural, economic, social, or political institutions that are separate from those of the dominant society and culture ● A distinct language, often different from the official language of the country or region If it is determined that indigenous peoples are present in the IAI, then the Project should develop an Indigenous Peoples Plan as outlined in the IFC PS7 guidelines.
15.8 Residual impacts The social impacts and mitigation and management measures discussed in the sections above are summarised in Table 113 below. The table also presents the conclusions on residual significance after the application of mitigation and benefit enhancement measures.
102 Focus Group Discussions conducted by Mott MacDonald Pakistan in June 2016
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Table 113: Summary of social impacts and mitigation / enhancement measures Activity Potential Impacts Sensitivity Magnitude Residual impact Mitigation or Statement of significance enhancement significance Construction Recruitment of Employment generation High Minor Moderate beneficial Local content strategy to Significant construction workforce for local communities be developed as part of Efforts will be made to the ESMP employ local people documentation (especially those SEP and local content considered vulnerable) strategy to specify providing upskilling so means for disclosure of their roles can continue employment through to the opportunities and operational phase. employment and training opportunities for local people. Influx management Influx of workers has High Moderate Major adverse Influx management plan Significant adverse impacts on the will be developed and The project company will local community implemented provide health facilities for their workers and transportation will be provided to ensure workers do not use the local facilities.
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16 Cumulative impact assessment
16.1 Introduction This section provides an assessment of cumulative impacts arising from the combination of the development of the power plant and the lignite mine in Block VI.
Cumulative impacts associated with the interaction of impacts that occur outside of Block VI and the combination of Block VI and other Blocks in the Thar Coalfields are outside the scope of this assessment. The cumulative impacts associated with development of all the Blocks in the Thar Coalfields are described in the SESA, commissioned by the Government of Sindh.
Cumulative impacts are evaluated and described as adverse or beneficial impacts, alongside their temporal and spatial scope, focusing upon combined, additive or synergistic impacts. Sensitive receptors are identified where relevant. Due to the nature of the impacts, the assessment methodology differs from the methodologies used in the respective ESIAs and is focused on a qualitative review of likely significant impacts identified in the respective ESIA reports.
The assessment also identifies any relevant mitigation and enhancement measures. These may be measures that are identified in the impact assessments and can be adapted in terms of their geographic scope, their scale or their timing.
Based on current information, construction phases of the Block VI lignite mining project and power plant will be undertaken in a similar time period as outlined below:
● Mine construction of access road, offices, accommodation, dewatering installation: Q4 2017- 2019, with overburden removal continuing until 2022. ● Power plant construction is planned to commence in 2018. The Block VI lignite mining project operational phase is expected to begin in Q3 2017, and the Block VI power plant from 2021. Both Projects are therefore expected to be in operation in unison for approximately 30 years.
16.2 Employment generation cumulative impacts As a result of the combined construction of the Block VI power plant and Block VI lignite mining Project, there are likely to be cumulative beneficial impacts upon local communities associated with temporary employment generation during the construction period. Although the skill base of local communities is low, and therefore jobs would likely be limited to unskilled labour, local communities have a high demand for employment.
Despite the temporary nature of the majority of jobs, workers may develop new or enhance existing skills, which may increase the transferrable skill base and future income generation prospects of those workers. These skills learnt on one Project could be directly transferred to work on the neighbouring Project, thus extending the employment length of some workers.
A social impact as a result of this employment generation is likely to be an enhancement in quality of life as a result of the provision of income for workers and their families, particularly given the high poverty levels in the immediate area of influence of Ranjho Noon, Yaqoob ji Dhani, Yosuf ji Dhani, Gangoo ji Dhani and Salar ji Dhani. Wider socio-economic benefits may be experienced by the local economy as a result of the spending of worker earnings on local goods and services.
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A variety of actions have been identified to be undertaken by both the Block VI lignite mining Project and Block VI power plant to enhance the benefits which may be experienced by local communities. These include:
● A local content strategy will be included in the ESMP for the Block VI power plant, and a SEP which will specify means for disclosure and employment opportunities. ● The Block VI lignite mining Project will engage a local employment priority policy, and will establish a vocational training centre in the early phases of construction to increase the ability of local people to compete for job opportunities. A coordinated approach between Projects regarding the employment of local populations and the upskilling of unskilled workers should be undertaken. Furthermore, recruitment and human resources processes should be aligned for both Projects from the outset, to ensure the fair and consistent treatment of workers.
16.3 Influx of workers’ cumulative impacts Both Projects have identified the need for skilled constructional and operational labour requirements which cannot be met in full by the local population. This will therefore lead to the influx of migrant workers, and potentially some opportunistic economic migrants, which can have negative impacts upon local communities in both stages of the Project, but particularly during construction due to the transient nature of the construction workers. As the population of the five villages within the Block is only 2,250 people, even an influx of a small number of workers is identified as having potential negative impacts upon these local populations such as cultural changes, strains upon already inexistent social services and increase incidents of risk- taking behaviour.
A variety of actions have already been identified by both Projects to mitigate the negative impacts possible as a result of worker influx. For example:
● This ESIA identifies an influx management plan to be developed as part of the environmental and social management plan, and also a community investment plan will be implemented. ● As part of the Block VI lignite mining Project, a social mitigation plan will be implemented, including measures such as a “cultural emersion and sensitisation course” as part of the induction plan for new employees. A coordinated approach should therefore be taken to ensure that adequate services are provided for workers to ensure workers do not use local facilities, and that actions to mitigate/enhance impacts are undertaken as outlined in both Projects’ management plans. Furthermore, management plans identified in both EIAs for mitigating issues of worker influx could be combined, to enable the minimising of negative impacts upon local communities and services.
16.4 Landscape and visual amenity cumulative impacts This ESIA identified that during both construction and operation, negative cumulative impacts are predicted to occur upon nearby receptors, particularly those within 2km of the site. Changes in landscape character as a result of land use change from desert to power plant and mine, a loss of vegetation, and an increase in light pollution levels will contribute to long-term adverse impacts upon both visual amenity and landscape character. During operation the physical presence of the new Block VI power plant and Block VI lignite mining Project will permanently alter the landscape character and visual amenity.
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During construction, it is expected that best practice operating procedures will be followed to avoid or mitigate where possible visual or landscape impacts upon nearby receptors. These mitigations are identified to include down-lighting of any temporary lighting, the limiting of land occupation to the minimum necessary for the works, and the identification of opportunities for landscaping on site. Similarly, during operation external lighting will be minimised. As part of the Block VI power plant mitigation, the lower parts of Project buildings should be painted in neutral colours to be representative of the surrounding landscape and thus minimise cumulative visual impact.
Therefore, there is an opportunity to take a Block-wide approach to landscaping (vegetation and of buildings) and lighting during the operation phase. A site-wide strategy could be put in place, taking account of any sight-lines from local communities.
16.5 Noise cumulative impacts Although noise impacts associated with the power plant are not predicted to result in significant impacts in this ESIA, the cumulative impact of Projects could result in some local communities in close proximity to the Projects experiencing negative impacts which are of longer duration or greater collective magnitude than identified in individual assessments for these Projects.
Both Projects have identified measures to control and avoid noise emissions. For example, this ESIA identified Yusef di Jhani residential area as the closest and most sensitive receptor to noise from the power plant. However, this was assessed as not significant if mitigation measures such as limiting noisy works to daytime hours only where necessary are put in place. Similarly, for the Block VI lignite mining Project, best practice mitigation measures such as noise mufflers on machinery are proposed.
In addition to mitigation measures outlined in both ESIAs, stakeholder activities should include consultation with people in Yusef di Jhani and other nearby residential areas, to identify any cumulative noise-related nuisance.
16.6 Air quality cumulative impacts During construction, there are not expected to be significant cumulative impacts with regards to air quality as a result of construction of the Project site and the mine, as most emissions from sources such as construction vehicles and the two Block VI lignite mining project generators are likely to be minor and localised in nature, and the main emission source of the Block VI power plant will not be in operation.
During operation, this ESIA considered the main emission source of the proposed Block VI power plant stack and found that impacts on sensitive receptors were not significant. Although there will be other sources of emissions such as on-site vehicle movements as a result of mining operations, these impacts will also be localised and unlikely to result in a cumulative impact on receptors.
Best practice techniques will be employed at both sites and through all phases of the Projects to minimise air emissions as described in the relevant management plans, including measures such as using a fuel efficient model choice of generators, and the use of modern, best available technologies in each Project. In addition, a coordinated approach to any grievances related to air quality should be undertaken to account for any cumulative impacts.
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16.7 Dust cumulative impacts High levels of fugitive dust are a common phenomenon due to the nature of the ground and the climate in the Thar region, and although dust emissions are assessed as not significant at all stages of the power plant Project, it is possible they may have some cumulative impacts upon nearby receptors when combined with the dust impacts of the mine facilities (for example dust from lignite stockpiling activities, the movement of construction vehicles around Block VI and between the mine and power plant during operation), particularly any sensitive receptors within 350m of the sites.
Extensive mitigation measures are proposed in this ESIA for both construction and operational phases, and will form part of the ESMP, which include measures such as:
● The minimisation of dust during construction and operation through international best practice measures, control measures, and dust suppression techniques. ● Ensuring that a grievance mechanism is in place for effective reporting and action for any dust issues. Similarly, the mining development will use dust control measures such as water spray and the covering of stockpiles, which will greatly reduce the ability of fugitive dust to travel beyond the boundary. Therefore, there is an opportunity to capture the best practice techniques that are relevant to the activities undertaken at both the Projects and adopt one common list of measures that control dust.
16.8 Hydrology and hydrogeology cumulative impacts The hydrology, hydrogeology and flood risk chapter of this ESIA includes an assessment of the cumulative impacts upon hydrology and hydrogeology. It is understood that the GoS is preparing a water management plan for the entire Thar Coalfield, which would establish a baseline for all water resources in the area and allow a cumulative assessment of the impacts upon water quality and quantity as a result of new developments.
Therefore, it is recognised that this is an important issue where cumulative impacts could arise and therefore the issues relevant to both Projects in Block VI need to be effectively communicated and represented in the water management plan.
16.9 Summary This chapter identifies the cumulative impacts that may result from the construction and operation of Block VI lignite mining Project and the Block VI power plant Project. Cumulative impacts associated with the interaction of impacts that occur outside of Block VI and the combination of Block VI and other Blocks in the Thar Coalfields are outside the scope of this assessment. The main opportunities identified in this chapter are: ● Opportunities to align approach to local content/recruitment, human resources processes and opportunities for workers to extend employment by working on both Projects, where appropriate. ● A coordinated approach to managing the influx of workers required for the Projects, to minimise disruption to existing local communities and services. ● Adoption of a site-wide approach to landscaping, during operation and decommissioning. ● Adoption of common site-wide measures to control air quality emissions, dust generating activities and noise emissions during construction and operation, complemented by stakeholder engagement to detect community grievances.
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● Make representations to the GoS as they develop the water management plan for the Thar Coalfields, to ensure the needs of Block VI development are taken into consideration.
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