CITY DISTRICT GOVERNMENT KARACHI
MASTER PLAN GROUP OF OFFICES
Mrs. Rukhsana Abid (Owner),
R/O F-8, Block-5,
SUB: WITHDRAWAL/CANCELLATION OF NOC REGARDING CHANGE OF
LANDUSE/CONVERSION OF PLOT NO. F-8, BLOCK-5, CLIFTON,
KARACHI GRANTED VIDE NO. CDGK/MPGO/MPGO/COM/OC/75/L
REF: 1) NO.EPA/2010/8/18/EIA/46, Dated 18-10-2010
2) NO.EPA/2010/8/18/EIA/46, Dated 27-10-2010
You are aware that the Environmental Protection Agency (EPA), Government of Sindh while
conducting the public hearing on 14th
October 2010 on the Environmental Impact Assessment
(EIA) Report has rejected the proposed project on Plot No. F-8, Block-5, Scheme-5, Clifton,
The Environmental Protection Agency, Government of Sindh has also recommended the
MPGO. CDGK vide their above referred letters, for withdrawal/cancellation of subject
change of landuse/commercialization.
In view of the above, the Competent Authority viz City District Karachi, CDGK vide
Resolution No.15, dated 04-11-2010 has withdrawn/cancelled, the said change of Land use
NOC and the fee/charges paid by you in this regard may kindly be collected from this office.
Copy for Information please:
1. Secretary, Environment & Alternative Energy Department, GOS.
2. Secretary, Local Government Department, Government of Sindh.
3. Chief Controller of Buildings, KBCA
4. EDO, Revenue, CDGK
5. Director General, E.P.A Karachi
6. District Officer (LM-1), CDGK
7. Deputy Secretary (Staff) o Chief Secretary, Government of Sindh.
8. PS to Administrator/DCO CDGK
9. Secretary, Commercialization Committee, CDGK
Floor, City District Govt. Complex, University Road, Gulshan-e-Iqbal, Karachi-75300, Pakistan
District Officer (Com)
The Executive District Officer,
City District Government Karachi.
SUBJECT: DECISION ON ENVIRONMENTAL IMPACT ASSESSMENT (EIA) OF
CONSTRUCTION & OPERATION OF NOMAN CASTELLO
Enclosed please find copy of the decision of Environmental Impact Assessment report issued
by this office regarding construction of proposed multistory building at Plot No. F-8, Block
No. 05, Clifton Scheme No.05, Karachi for further necessary action in the matter.
Naeem Ahmed Mughal
1. District Coordination Officer, Karachi.
2. Chief Controller, Karachi Building Control Authority.
3. Managing Director, Karachi Water & Sewerage Board.
4. Managing Director, SuiSouther Gas Company
Reference No: EPA/2010/8/18/EIA/46
SUBJECT: DECISION ON ENVIRONMENT IMPACT ASSESSMENT (EIA)
1. Name and Address of Proponent: Mr. Mujtaba Passwala
Noman Builders & Developers
2. Description of Project: Construction & Operation of Noman
3. Location of Project: Plot No. F-8, Block No. 05, Clifton
Scheme No.05, Karachi
4. Date of Filing of EIA: 18th
5. After careful review of the Environmental Impact Assessment (EIA) the
Environmental Protection Agency (EPA), Sindh has decided to reject the project,
being contrary to environmental objectives, for the following reasons:-
i. Construction of proposed project pertains to commercialization of Khyban-e-
Saadi planned for its conversion from low density to high density zone which
refers to change of land use from residential status to commercial. The change of
such status required that Environmental Impact Assessment of the said cooridor
should have been conducted earlier for objectives of assessment of cumulative
impacts of high rise structures on environmental resources of the location
including of built environment/infrastructure and public utilities, Environmental
Impact Assessment conducted for conversion of individual residential plot to
construction of multistory building will not serve the purpose to assess the
impacts thereof in connection to environment social and ecological resources in
the vicinity of Khyan-e-Saadi. Also the mitigation measures stated in the EIA
report to address the impact cannot be considered sufficient in isolation of integral
ii. That the public hearing held under the regulatory provisions of Pakistan
Environmental Protection Act.1997 to listen the concerns of general public and
stakeholders concluded that there are grave apprehensions against construction of
said project does not meet requirement of sustainable development.
iii. That the construction of proposed building will cause incremental effect on
concentration of pollutants in ambient air quality will increase noise levels in the
vicinity due to increased vehicular movement in the project area.
iv. That construction of proposed building will cause additional burden on sewerage
network, water supply system and electricity consumption which will enhance
sufferings of local residents. Therefore commercialization in absence of enhanced
infrastructure will only be a great nuisance instead of providing benefits of
v. That the construction of proposed high rise building and subsequent construction
on the other plots facing the road side of Khyaban-e-Saadi will adversely affect
privacy of many residents living in the backside of the plot, will also lead to
devaluation of their property. the residents will also encounter interruption in sun
light. Obstruction of wind flow as well as shadow effect of building leading to
unaesthetic values in the vicinity. During construction phase the piling work using
heavy machinery will cause vibration in subsurface formations which will lead
damage to the property of residents in close proximity of the plot.
Naeem Ahmed Mughal
The Executive District Officer,
City District Government Karachi.
SUBJECT: ENVIRONMENTAL IMPACT ASSESSMENT OF PLOT F-8, BLOCK-5,
Your kind attention is drawn to the objections raised in the public hearing held in
response to a Public Notice published in leading newspapers inviting comments from the
general public on the Environmental Impact Assessment filed by the owner of above
mentioned property on Thursday 14th
October 2010. Keeping in view the importance of the
issue and in public interest, EPA-Sindh invited your good self to attend the hearing so as to
respond to the concerns of stakeholders, but no representative from your organization
attended the hearing to respond to the objections.
You must be aware that under Category II (I) of Schedule II of the EIA and IEE
Regulations 2000 read with the provisions of the Pakistan Environmental Protection Act,
1997 the submission of EIA report is a mandatory requirement prior to allowing
commercialization of the roads (change of land use). It may be noted that the same was also
accepted by the consultant of the owner of the subject properly at the hearing.
In view of the informed decision in the EIA process it is to bring in your knowledge
that hundreds of aggrieved persons raised serious concerns and apprehensions due to
commercialization of Khyaban-e-Saadi in general as well as commercialization and
construction of a multistory building at Plot # F-8 on the said Corridor in particular.
A series of justified and well grounded observations recorded in the public hearing are
Security risks including letter from Police Department saying that increased
densification would create a security threat to the residents of the area as well as to
sensitive buildings located within the proximity of the area.
Adverse health impacts on students included lead poisoning
Strain on existing utilities i.e. electricity, sewage and water
Reference No: EPA/2010/8/18/EIA/46
Complete disruption of personal privacy of residents of the area
Increase in noise pollution
No system for disposal or increased solid and liquid waste
Devaluation of property on account of commercialization
Dangers caused by seismic activity
Increased dangers caused by Fire
In view of the foregoing HPA, Sindh is of firm opinion that proposed development is
against the principles of sustainable development which requires development must be
economically viable, socially acceptable and least damaging to environment. Under the
circumstances we are seeking action at your end as to whether City District Government
Karachi would in light of above consider reversing the commercialization of the plot # F8,
Block 5, Clifton, and Khayaban-e-Saadi Corridor.
Naeem Ahmed Mughal
Karachi – numero uno
UNFORTUNATE it is that President General Pervez Musharraf has chosen to surround
himself with Neanderthal men. His Gag-man (if he reads this) should know that there
abound in Pakistan men who can get any gagged message or movie onto his PC one night
and then onto a thousand other PC screens by dawn the following day. How unfortunate
and luckless can the citizens of Pakistan be that they are so mocked by those put in
positions of power.
Last week there came into my mail box a highly depressing message which concerns all of
us who live in Karachi. Excerpts warrant reproduction, just in case they awaken our so-
called „leaders‟ into whose hands our government has been delivered, and our
administrators who must follow, but who at least can be made aware of what is what and
can voice their objections. It came from Engineer Zulfikar Sarosh currently residing in
Austin, Texas :
―I am a member of IEEE (Institute of Electrical and Electronic Engineers), the largest professional
body of electrical engineers. It was after reading an article in ‗Spectrum‘, the flagship publication of
IEEE that I decided to write to you.
―This month (June 2007) ‗Spectrum‘ did a special report on mega-cities. Karachi was named twice in
that report, both times in a negative light. Since you are one of the few people who take up the real
issues (non-political) regarding Karachi, I decided to share this information with you.
―First of all, Karachi has the ‗honour‘ of being the most polluted city in the world. In the words of
‗Spectrum‘, ‗Air Pollution : Particulate matter smaller than 10 micrometers in diameter (pm10) is the
most dangerous to human health, because it can pass through the nose and throat and enter the lungs
— leading to asthma, lung cancer, cardiovascular problems, and premature death. Of the mega-cities,
Karachi, Pakistan, had by far the worst pm10 problem in 1999, the last year for which complete data
were available. New York City had the cleanest air.‘
―If it is any consolation, Karachi was followed by Delhi, Cairo and Dhaka. But they were far behind
Karachi. As you may note, this was the data from 1999. I am sure by now the situation must have
grown far more serious. I beg you to please write about this issue. I have spent the best years of my life
in Karachi and my parents and parents-in-law and most of my family live there, so I have a deep
emotional attachment to the city. This is a very serious issue, as it concerns the health and indeed the
very lives of Karachiites.
―The report is available on the internet : http://spectrum.ieee.org/ jun07/5148/3 To see the GDP for
mega-cities check out : http://spectrum.ieee.org/jun07/5148 (Karachi is third from the bottom).
―One graph which showed the slum populations is not available online, but was in the print copy and
showed Pakistan as having the fifth largest slum population, way behind China and India in numbers.
But it also showed that 74 per pent of urban dwellers in Pakistan live in slums (as opposed to 56 per
cent in India and 38 per cent in China).
―Another shameful fact appeared in The National Geographic magazine, where, writing about
Dharvi, a slum in Mumbai, this is what the author said: ‗In Asia, Karachi's Orangi Township has
surpassed Dharvi [as being the largest slum in Asia] ....
―So Karachi has two crowns to wear – one being the most polluted mega-city in the world and second
the host of the largest slum in Asia.....bravo Karachi! ―Don‘t forget to don a mask as you go out. You
live in the most polluted city. And also don‘t forget the bullet proof vest...I am sure it is also the most
unsafe city as well.‖
Now, this being the current state of our city, and with the pm10 problem having surely
magnified alarmingly over the space of eight years what can possibly be the justification for
the Sindh Environmental Protection Agency (SEPA) to have given its clearance, on June 6, to
the City District Government to construct the 25-kilometer long Karachi Elevated
Expressway (KEE) which has been rejected by many experts (genuine this time) on the
grounds that it is highly environmentally damaging? The sole justification one can think of
is that it is another money-making machine, money being the magic that makes our
government go round and which is always needed by its honourable members both here
and, of course, far off in fair London town.
Karachi‟s proposed „road-on-stilts‟, running from Jinnah Bridge to Quaidabad, which I have
previously discussed, has been given a go-ahead by SEPA on the basis of „do good, and
avoid evil‟. But does this city need, and can it sustain, an elevated expressway? Architects,
engineers, planners and advocacy groups think not. Environmental, aesthetic, technical and
procedural flaws that have been identified go against it.
A cardinal principle for reducing congestion on roads and mitigating adverse traffic impact
is that new roads should only be built after all reasonable alternatives for minimising the use
of single-occupancy vehicles, that is, cars, have been exhausted. Consequently, the first
priority of the city government must be to implement an affordable, comprehensive, and
environment-friendly mass transport system in Karachi which will radically reduce the
proliferation of polluting, gas-guzzling, noisy, traffic-congesting vehicles that are coming
out onto our roads in their hundreds each day, thanks to our banks and their need to make
money out of upwardly mobile unwary citizens.
The second priority, which will benefit not only the expressway corridor but the entire city,
would be to ensure traffic law compliance/discipline and the removal of road friction
(illegal parking, encroachments, etc) on existing thoroughfares. These principles have also
been the findings of this week‟s stakeholder workshops organised in Karachi by the Asian
Development Bank to examine its „Transport Sector Roadmap‟ for the Karachi Mega City
Sustainable Development Project.
The expressway has been dangerously designed without emergency lanes/shoulders. While
the Malaysian Highway Authority mandates that “All expressways must have at least four
lanes (two in each direction) segregated by a median divider. Both sides must have an
emergency lane”, the contractors, IJM Berhad from Malaysia (who chose them and how?),
propose to provide the citizens of Karachi less than the minimum facilities which are
mandatory in their own country.
Since the city does not have an overall traffic/transport management plan, isolated projects
like the expressway are merely a means of putting public money into private pockets. The
questionable contract-award procedure, the lack of transparent details of the „annuity-basis‟
BOT contract, the availability of a superior alternatives (rail for one) for inter-port and
upcountry traffic, the increased noise and air pollution, and many other factors would make
the project a non-starter in a civilised, clean and sane society.
The Director-General of SEPA, responding to questions put to him by architects, engineers
and environmentalists at a public hearing in April informed them that the city government
had formed a committee of „experts‟ to evaluate all reservations and assured the doubters
that problems would be addressed and resolved. Have they been?
The city government‟s project director of the KEE is Canadian
citizen Rauf Akhtar Farooqui, an OSD (officer on special duty),
a great favourite of the Pir of London and his appointed
Karachi City Nazim, young Mustafa Kamal who has a
Malaysian connection. According to Project Director Farooqui,
while discoursing on another „development‟ project, there is no
need for such “time-consuming exercises” as environmental
impact assessments, when the aim is “rapid development.” This
says it all.
Long may we live, healthily – breathing polluted air.
Castles on dung heaps?
By Ardeshir Cowasjee
Jun 18, 2011
GEORGE Burns, the comedian who generated laughter up to the age of 100 (much to
be said for having a sense of humour), once wryly observed: “The secret of success is
sincerity. If you can fake that, you‟ve got it made!”
This is a recipe our politicians and bureaucrats love: while crafting devious schemes to
line their own and their cronies’ pockets, they exude ‘sincerity’ by claiming that all
being done is in the ‘supreme national interest’.
One such recent scam is the Sindh High Density Development Board Act 2010
promulgated in May last year. At the time, this column explained how, in 2008, the
president of the republic had commissioned the Karachi (now Sindh) Building
Control Authority (SBCA) to promote the construction of 100-storey high-rises to
stimulate the flagging economies of the provincial cities.
The SBCA sprang into action: obtained 17 consultancy proposals from around the
world, formed an advisory committee of 11 prominent architects who researched
issues and submitted sensible recommendations (establish a supra Planning and
Development Authority, designate limited low-rise/high-rise high-density zones
based on urban-planning studies, create an Oversight Committee with minimum 50
per cent representation of citizens from professional, building, commerce and
industry, academic and NGO fields), drafted three versions of a High Density Bill for
Sindh, and finally had one passed based on a compromise basis — the governor
(MQM) and the chief minister (PPP) would be at the helm of affairs.
Most of the architects’ recommendations were ignored or diluted. Besides the district
nazim, the other seven board members were government-wallahs, none of them town-
Similar arrogance (and short-sightedness) was displayed by the Sindh government
earlier this year when it presented the Protection and Prohibition of Amenity Plots Bill
authorising the Assembly (apparently full of urban planners) to decide which amenity
plots were no longer needed and could be converted to residential/commercial use. It
turned out to be a ploy to sponsor land-grabbing.
The detailed intent of this avaricious High Density Act 2011 was finally exposed with
the notification last month of the Sindh High Density Development (Rules &
Without technical studies of the urban areas involved, rules have been arbitrarily made
to increase the amount of construction permitted. In high-density zones, residential
plots will now be used for commercial and high-rise purposes by merely paying a fee
(existing procedures only allow change of land-use on 28 designated roads, which Sepa
has ruled require an entire road EIA study to protect the environment from
Numerous plots can now be amalgamated without any limitation of size, radically
altering the character of residential neighbourhoods when, say, five 1,000 sq yd plots
are combined to form a 5,000 sq yd plot. Height-related setbacks of buildings (required
for light penetration) have been eliminated. Parking requirements are totally
Allowable sizes of buildings on residential plots have been boosted by over eight times
on plots between 3,000-5,000 sq yds and by over 12 times for plots over 5,000 sq yds.
The corresponding demands of the building occupants for scarce water, fluctuating
electricity, sewerage, gas, garbage collection, road traffic, parks, playgrounds, hospitals,
police stations, and other amenities/facilities will swell by the same proportion.
In a number of landmark judgments, our Supreme Court has quoted the Encyclopedia
Britannica on the social goals of modern city planning: orderly arrangement of areas:
residential, business, industrial, etc; efficient system of circulation/transport; optimum
standards: plot size, sunlight, green spaces, parking, building spacing; safe, sanitary
and comfortable housing; recreation, schools and community services; water supply,
sewerage, utilities and public services.
Further, analysing the interests of developers and builders (who some erroneously
consider ‘stakeholders’ in the urban development process), Britannica goes on to say:
“Zoning and sub-division controls. … It was realized [in the US], after bitter
experience with suburban land speculations in the 1920s, that the interest of the
owner and developer of raw land is sometimes temporary and purely financial, while
the urban community must live with the results for generations afterward.”
A thorn in the side of builders / developers and their government patrons
countrywide is the aerodrome-safeguarding requirements of the Civil Aviation
Authority (CAA). Within a radius of about 15km of an airport runway, and above an
increasing height up to 155 metres (less than 40 stories), no obstruction can be
erected. Consequently, proposed buildings within these limits have to obtain NOCs
from the CAA before proceeding to other government approvals.
In Karachi, the three aerodromes at Jinnah International, Faisal and Mauripur Air
Force bases have thrown a spanner into the works of many ambitious entrepreneurs,
e.g., the 47-storey „I.T. Tower‟ at Civic Centre became unviable in 2008 when the CAA
approved only 38 floors.
There are movers and shakers in Pakistan whose plots in Karachi (which they wish to
exploit to the maximum) fall within the affected radii of these aerodromes. Last week
at a meeting convened at the presidency, CAA officials had to reluctantly insist that,
firstly, even government buildings could not override these requirements, and
secondly, the NOCs, under International Civil Aviation Organisation rules, could not
be issued by the SBCA. If this were done, international flights (the few that remain)
would refuse to come to Karachi because of flight hazards.
A seminar in Karachi this past Thursday had a sizable group of architects, engineers,
town-planners, environmentalists and concerned citizens recommending to the
government that the urban-planning of Sindh’s cities be based on the original architects’
committee’s submissions, be carried out by master-planning experts not by a building
control agency, be kept simple and realistic, be done at the local level and not by
Islamabad, cater to all residents (especially the ever-increasing over 60 per cent katchi
abadi groups) not just the two per cent super-rich, and be provided requisite utilities
and physical/social infrastructure in advance.
As remarked one participant, we cannot build castles on dung heaps.
Original Plot 5 & 6 / CF-5 Clifton Quarter
(9,436 sqyds = 1.95 acres) housing the Hussain
D’Silva Park apartments, shown in the KDA
Scheme-5 layout. The rest of the plot is the
New Plot 5 & 6 / CF-5 Clifton Quarter
(17,336 sqyds = 3.58 acres) housing the Bahria
Town Icon Towers project, as occupied on the
ground (7,900 sqyds = 1.63 acres extra, which
comes out of amenity Bagh-e-Ibn-e-Qasim)
WWhheerree ddiidd tthhee
eexxttrraa 11..6633 aaccrreess
HHooww ddiidd rreessiiddeennttiiaall
&& aammeenniittyy ssppaacceess
Comparison of the Original and New
Plot 5 & 6 / CF-5 Clifton Quarter