EIA - SEWAGE WATER TREATMENT PLANT FFC MIRPUR MATHELO

SEWAGE WATER TREATMENT PLANT
WITHIN BOUNDARY WALL OF FFC MIRPUR MATHELO
ENVIRONMENTAL IMPACT ASSESSMENT
(EIA)
Prepared by:
Suite 4, 2nd
Floor, Link Arcade, Model Town Link Road, Lahore
Phone: 042-35887517, 35925693; Fax: 042-35855508
Email: ectech_ectech@yahoo.com
October-2012

Sewage Water Treatment Plant, FFCL
C O N T E N T S
EXECUTIVE SUMMARY i-vii
1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL 1
2.0 DESCRIPTION OF THE REPORT AND ITS ALTERNATIVES 5
2.1 The status of the report in the project cycle 5
(pre-feasibility, feasibility or detailed design)
2.2 Description of the planning, design and implementation stages 5
2.2.1 Planning 5
2.2.2 Design 5
2.2.3 Implementation 5
2.3 The requirements for raw materials, water, energy and 6
equipment
2.3.1 Raw materials 6
2.3.2 Water 6
2.3.3 Equipment 6
2.4 The planed operational characteristics-hours of operation, 6
processes , products
2.4.1 Hours of operation 6
2.4.2 Process 7
2.5 Visual aids (maps of the area, site and plant layout, 8
flow charts of production, and photographs of the site
and similar projects)
2.5.1 Location map 8
2.5.2 Plant layout 8
2.6 Comparison of report options ( size, siting, technology, 8
layout, energy, sources, sources of raw material)
2.6.1 Size (Capacity of the Plant): 8
2.6.2 Siting (discussion of the project siting alternatives) 8
2.6.3 Technology 9
2.6.4 Layout 9
2.6.5 Energy sources 9
2.7 Summary of the technical, economic and environmental 10
features of the report
2.7.1 Technical 10
2.7.2 Economic 10
2.7.3 Environmental 10

3.0 DISCUSSION OF REPORT AND CURRENT LAND USE 12
POLICIES
3.1 Land use 12
3.2 Regulatory framework 12
3.2.1 Deregulation of the economy 12
3.2.2 Import policy 12
3.2.3 Infrastructure facilities 12
3.2.4 Incentives 13
3.3 Legal Framework 13
3.3.1 National Conservation Strategy (NCS)-Pakistan 14
3.3.2 Pakistan Environmental Protection Act (PEPA), 1997 15
3.3.3 National Environmental Quality Standards (NEQS) 16
3.3.4 Regulations for Environmental Assessment 16
3.3.5 Guidelines for Environmental Assessment 17
3.3.6 Guidelines for the Preparation and Review of 17
Environmental Reports:
3.3.7 Guidelines for Public Consultation: 18
3.3.8 National Resettlement Policy and Ordinance 18
3.4 Institutional Framework 19
3.4.1 National Environmental Regulatory/Legal Requirements: 19
3.4.2 National Conservation Strategy (NCS) – Pakistan 20
3.4.3 Pakistan Penal Code (1860) 21
3.4.4 Pakistan Environmental Protection Act, 1997 22
3.4.5 Policy and Procedures for the Filing, Review and 23
Approval of Environmental Assessments
3.4.6 Guidelines for the preparation and review of 23
Environmental Reports (NOVEMBER 1997/2000)
3.4.7 Guidelines for Public Consultations 24
3.4.8 National Environmental Quality Standards 24
(NEQS)-1993, Amended August 2000
3.4.9 Guidelines for Sensitive and Critical Areas 25
3.4.10 National Resettlement Policy and Ordinance 25
3.4.11 Forest Act, 1927 26
3.4.12 Industrial Relation Ordinance, 2002 27
3.4.13 Industrial Relations Ordinance 2011 Promulgation
3.4.14 Other Relevant Laws
3.4.15 National Electric Power Regulatory Authority (NEPRA)
Act 1997
3.4.16 Power Policy 1998
3.4.17 Factories Act, 1934
3.5 Environment Related Relevant International Agreements in
Pakistan’s context:

4.0 DESCRIPTION OF EXSITING AND EXPECTED CONDITIONS 28
4.1 Spatial and temporal boundaries adopted for the 28
various aspects of the study
4.2 Existing (baseline) conditions of the biophysical 28
and socio-economic environment, trends and
anticipated future environmental conditions should
the project not go ahead
4.3 Environmentally sensitive areas of special or unique 28
value Physical resources of the project area:
4.3.1 Physical resources of the project area 28
4.3.1.1 Topography and geology 29
4.3.1.2 Land 30
4.3.1.3 People 30
4.3.1.4 Languages 32
4.3.1.5 Sports and Entertainment 32
4.3.1.6 Wildlife – Plant 32
4.3.1.7 Industries 38
4.3.1.8 Infrastructure 38
4.3.1.9 Transportation: roads, rail, airports, 39
navigable rivers:
4.3.1.10 Land use planning: 39
4.3.1.11 Power sources and transmission: 39
4.3.1.12 Agricultural and mineral development: 39
4.3.1.13 Quality of life: 40
5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES 43
5.1 Assessment of any environmental impact on local population 43
and the environment during construction and operational phase
5.1.1 Likely adverse impacts from plant during construction 43
5.1.1.1 Environmental Adverse Impacts 43
During Construction
5.1.1.2 Pollution impacts and remedies 44
5.1.2 Environmental Adverse Impacts During Operation stage 45
5.2 The relevant environmental data and predictive methods used 46
and any underlying assumptions made
5.2.1 Base line environmental data 46
5.2.1.1 Ambient Air Quality-Ambient 46
5.2.1.1.1 Gaseous 47
5.2.1.1.2 Particulates 47
5.2.1.1.3 Noise Levels 47
5.2.1.1.4 Water Quality 47

5.3 Gaps in knowledge and uncertainties encountered 48
5.4 Compliance with relevant environmental standards 48
5.4.1 Effluents-discharges and environmental controls: 48
5.4.2 Noise Levels 48
5.4.3 Solid wastes: 48
5.5 Assessed significance of the impact stating the standards or 49
criteria used as a basis for judgment
5.6 Possible measures for avoiding or mitigating the impact 49
6.0 COMPARATIVE EVALUATION OF ALTERNATIVES AND 51
IDENTIFICATION OF THE PREFFERED OPTION
6.1 Labour 51
6.2 Basic infrastructure 51
6.3 Site availability for the plant 52
6.4 Environment 52
6.5 Energy availability 52
7.0 ENVIRONMENTAL MANAGEMENT PLAN, MONITORING 53
PLAN AND PROPOSED TRAINING
7.1 Environmental Management Plan 53
7.1.1 Mitigation/Compensation Measures during 53
Construction Phase
7.1.2 Mitigation/Compensation Measures during Operation Phase 53
7.2 Assigning responsibility for implementation (by name or position) 60
7.3 Reporting and reviewing procedures 62
7.4 Training needs 63
7.5 Third party monitoring 63
7.6 Environment quality control laboratory 64

8.0 REFERENCES 65
9.0 SOURCES OF DATA AND INFORMATION AND LIST 67
OF REFERENCE MATERIAL USED
10.0 TEAM MEMBERS WHO CARRIED OUT THE STUDY AND 68
PREPARED THE EIA
11.0 TERMS OF REFERNCES FOR THE ENVIRONMENT REPORT 72
12.0 PUBLIC CONSULTATIONS: 73
ANNEXURES
ANNEXURE-I 77
Pakistan Environmental Protection Act, 1997
ANNEXURE-II 102
National Environmental Quality Standards (NEQS)-2000 Pakistan
ANNEXURE-III 108
National Environmental Quality Standards for Ambient Air
(NEQSAA)-2010 Pakistan
ANNEXURE-IV 114
Letter from Sindh Irrigation & Drainage Authorty
ANNEXURE-V 115
Guidelines for the preparation and review of Environmental Reports,
October 1997/2000
ANNEXURE-VI 162
The Plant Location Map
ANNEXURE-VII 163
The Plant Layout Map
ANNEXURE-VIII 164
Guidelines for Self – Monitoring and Reporting by Industry (SMART)
Final Report March 1998
ANNEXURE-IX 174
Ambient Air Gaseous Monitored Data

ANNEXURE-X 175
Ambient Air Particulate Matter Monitored Data
ANNEXURE-XI 176
Noise Levels Monitored Data
ANNEXURE-XII 177
Laboratory Analysis Report of Water Samples
ANNEXURE-XIII 182
Public Consultations (PC)
PHOTOLOGS

EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY
Fauji Fertilizer Company Limited (FFCL); at its Plant-III located at Mirpur Mathelo,
Ghotki-Sindh; are in the process of installing a sewage treatment plant for the treatment
of sewage from the FFC Staff Colony. The treatment plant is in its final stage of
completion.
FFCL intend to dispose the treated sewage into nearby Massu Wah canal. The authority
Incharge of the canal asked the company to fist get Environmental Approval (EA)/ No
Objection Certificate (NOC) from the Environmental Projection Agency (EPA),
Government of Sindh as precondition to allow to discharge the treated sewage into the
Massu Wah Canal.
The sewage treatment plant has the capacity to treat 100 m3
/hr of sewage being generated
from the Fauji Fertilizer staff colony. According to its capacity, the project falls under
category “A” of the projects requiring EIA report to obtain EA/NOC from the EPA,
Government of Sindh. Therefore, this EIA report is being submitted to the EPA, for
issuance of EA/NOC under the Pakistan Environmental Protection Act 1997, Section 12.
The EIA report has been prepared in accordance with the Government of Pakistan’s
officially approved “Guidelines for the preparation and review of Environmental Reports,
October 1997/revised 2000”.
Ground water is used for all domestic purposes including washing, bathing, cleaning etc.
After use, the waste water will be sent to the sewage treatment plant under reference of
this EIA report. The treatment plant is being installed within the four walls of the staff
colony of FFCL. The electricity requirement of the plant will be fulfilled from the mother
Fauji Fertilizer Company Limited situated adjacent to plant site.
Title and location of the project:
Township Sewage Water Treatment Plant,
FFCL Employees Colony,
Fauji Fertilizer Company Limited,
Mirpur Mathelo, Ghotki, Sindh.

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Head Office:
93-Harley Street, Rawalpindi.
Phone 051-8450001, 051-111 332 111
Name of the proponent:
M/S Fauji Fertilizer Company Limited,
Address as above.
Contact person:
Mr. Sardar Ali,
Manager Production,
Mirpur Mathelo.
Phone: 0723- 652301 EXT 3202 Fax: 0723-661462-63
Email: sardar_ali@ffc.com.pk
Environment Consultants:
ECTECH–Environment Consultants;
Suite No. 4, 2nd
Floor, Link Arcade,
Model Town Link Road, Lahore
Phone: 042-35887517, 35925693
Fax: 042-35855508
E-mail: ectech_ectech@yahoo.com.

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Contribution to economic uplift of the people/ job opportunities
As a result of the project installation, people of the project area will be benefited in a
number of ways.
i) During construction phase local people will get jobs. Maximum unskilled jobs
will be provided to the people of the area; even other jobs wherever suitable
people are available from within the area will also go to them.
ii) During regular operations of the plant if some new persons are to be recruited, the
people of the area will be preferred subject to their suitability for the job.
iii) Employment opportunities will improve overall economic status of the people.
This will bring all out positive, qualitative and quantitative change in the entire
walk of life of these people.
iv) They will be tempted to send their children to schools.
v) The project proponent, like in the past, will try to contribute to the economic
development of the people of the area wherever possible.
vi) Wherever and whenever required, basic infrastructure like roads and other means
of communication will be improved through the project activity. This will bring
an over all socio economic change in all walks of life of the people.
Salient features of the project proposal
This project proposal provides project background including like details of investments,
employment opportunities and type of activities within the mandate of the project.
The proposal highlights the socio economic status of the people of the area and
biophysical conditions. Environmental settings including climate, vegetation, crops,
water, soil, forestry, wildlife, air, heritage, environmental status, and biodiversity,
scientific and historical buildings are also highlighted in this project proposal.

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This proposal provides details of the stages of the project completion from planning to
design and implementation. It also gives rational for site selection while taking into
considerations availability of raw materials, energy, water, environment, space
availability for plant etc. as basic essentials to run the project.
The proposal describes likely adverse impacts that could occur due to the wastes from the
project activity, both during construction and regular operations of the project are also
highlighted. The proposal also provides details of the remedial measures to be adopted to
address the problems of wastes for protection of environment. This EIA Report
recommends Environmental Management Plan (EMP) and Environmental Monitoring
Plan (EMtP).
The pollution controls are to follow compliance with the National Environmental Quality
Standards (NEQS) and Pakistan Environmental Protection Act—1997 (PEPA-1997).
The proposal provides description of the prevailing and future expected conditions
including biophysical and socio-economic conditions, environmentally sensitive areas of
unique or special value especially soils, vegetation, water bodies, fishery, biodiversity,
forestry, wildlife, cultural heritage, scientific institutions, socio-economic scenarios
among many other factors.
Environmental monitoring, to generate baseline data, has been carried out and the
monitored environmental data are provided in this report.
Composition of the team participating in the preparation of this proposal has been given.
The documents consulted during the course of preparation of the proposal are also listed
in this EIA report.

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The major impacts
Plant operations will be under strict environmental controls. Wastes of all sorts i.e.
effluent, gaseous emissions (from vehicular emissions and construction machinery during
construction phase), particulate matter, solid wastes and noise levels will be managed in
environmentally sustainable fashion and in accordance with the NEQS limiting values.
Protection of all segments of environment i.e. forests, biodiversity, buildings, structures,
fishery, aquatic biology, wildlife, cultural or other heritage, vegetation, climate etc. will
be safeguarded as mandatory legal compliance.
Environmental impacts and remedies:
Environmental impacts:
The pollutants to be generated from the project operations and their likely impacts on
people and environment, in case no environmental management is carried out (both
during construction and operation phases) and mitigation measures are briefly
discussed here. However, it must be borne in mind that since the project is to operate
under recommended Environmental Management Plan and in compliance with the
legal requirements of the PEPA-1997 ANNEXURE-I and the NEQS, ANNEXURE-II
obviously adverse impacts are not to occur from the project activity.
a)- Effluents:
In case untreated effluent is discharged into any water body it can deteriorate the
quality of water and may render it unfit for its end use. The treated effluents of plant
will be discharged to main Massu Wah canal which has sufficient capacity to
accommodate the effluent. In this way it will further reduce concentration of the
pollutants and keep canal water safe for its use in irrigation.

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b) - Stack Gaseous Emissions:
Since plant operation does not involve any fuel burning activity, therefore, there are
no gaseous or particulate matter emissions from the plant operation.
c) - Solid wastes:
The solid waste to be generated from the project activity, during construction and
regular operation, mostly include sludge, waste packing, redundant cartons, wood
pieces, metallic pieces, plastic from packing, metallic shavings, plastic and metallic
drums.
With the exception of plastic drums containing chemicals, none of the other solid
wastes will pose any harm either to environment or human beings. The drums will be
returned to their suppliers for recycling. The redundant packing and cartons and other
solid wastes will be sold in the market for reuse.
d)- Noise:
The plant machinery does not contain any machinery which may rub against each
other to produce high noise levels. As such the plant is not going to yield noise levels
beyond the prescribed limits of the National Environmental Quality Standards for
Noise (NEQSN) November 26, 2010- ANNEXURE-III.
Recommendations for mitigation and compensation:
Briefly, the following recommendations for mitigating environmental adverse
impacts are made. For more detailed account refer to Section 5.0.
Implement EMP and EMtP in letter and spirit.
Environmental management staff should be trained adequately.
On site environmental laboratory should be adequately equipped.

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Regular monitoring of the desired parameters, as recommended in the EMP
and EMtP, should be adhered to and results be communicated to the EPA
Sindh.
Dusty areas within the plant boundary lines should be kept wet as far as
possible to minimize dust.
Environmental monitoring on monthly basis should be carried out even during
construction to ensure that environmental order is maintained.
Proposed monitoring:
Environmental Management Plan and Environmental Monitoring Plan have been
recommended to further provide safeguards against any possible environmental
damages. For its details reference is made to Serial No: 7.0.
Public Consultations (PCs):
Public Consultations play positive role in managing a project in environmentally
sustainable order. PCs were held with the public of the area of project influence.
Their written comments are appended in this report.
All those participated in the PCs; hope to have job opportunities besides industrial
development of the area as positive step.

1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL

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1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL
Fauji Fertilizer Company Limited (FFCL), at its Plant-III located at Mirpur
Mathelo, Ghotki-Sindh is in the final stage of installing a sewage water treatment
plant model ST 635 CT for the treatment of sewage from its staff Colony.
The project estimated cost is Rs. 12.0 million. The project will spread over an
area of about 625 square feet. The plant has been designed by National Water
Engineering (Pvt) Ltd. Karachi.
The plant has the capacity to treat 100 m3
/hr of sewage being generated from the
Staff Colony of Fauji Fertilizer. The design of the plant has been engineered on
simple straight-line logic. All components are independently installed, connected
through pipes and flanges only. The plant is of robust construction and with a
very little care; it can safely be expected to last for more than 25 years.
Ground water is used for all domestic purposes including washing, bathing,
cleaning etc. After use this water will be sent to sewage water treatment plant
which has been installed within the four boundary walls of FFCL.
The treatment plant, with the latest state of the art technology, will be highly
efficient and respond to meet the requirements of the National Environment
Quality Standards (NEQs) Pakistan. As stated, after treatment all the parameters
of treated sewage water are to comply with the prescribed limits of NEQs-
Pakistan ANNEXURE-II.
The treated sewage will be used for irrigation of vegetation, plants and trees
within the boundary walls. However, the left over sewage, if any, will be
discharged into the Masu Wah Canal which is passing between the FFC Township
and FFC plant.

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According to Pakistan Environmental Protection Agency (PEPA), 1997, Section
12 ANNEXURE-I No Objection Certificate (NOC)/Environmental Approval
(EA) from Environmental Protection Agency (EPA), Government of Sindh is
legal requirement, to start construction and then to discharge the treated sewage
out of the boundary walls of the colony of FFCL. Since it was previously planed
not to discharge any quantity of the treated sewage out the boundary of the FFCL,
therefore, the required EIA report for getting NOC from the EPA was not filed.
It is now planned to discharge the treated sewage in to the Massu Wah canal. The
Authority Incharge of the canal has asked vide his office letter
No.MD/SIDA/6529 dated November 4, 2010 ANNEXURE-IV to get
Environmental Approval from the EPA, Government of Sindh. The Masu Wah
Canal passes between the FFC Staff Residential Colony and FFCL plant.
Thereafter, permission to discharge the treated sewage will be allowed. Therefore,
this EIA report is being submitted to the EPA Sindh for issuance of the EA/NOC
to get EA from the EPA.
Environmental management Plan (EMP) and (EMtP) are operational to further
ensure legal environmental compliance. Biannual overall environmental
monitoring by a third party will further ensure environmentally sound operation
of the plant.
The EIA report deal with the environmental adverse impacts of the project that
could occur during regular operations and the mitigation measures to be adopted
to counter them so as to protect human health and air, soil, water bodies, natural
heritage, wildlife, fishery, vegetation, forestry, biodiversity, historical buildings,
structures, climate, land use, socio economic set up etc. The entire environmental
and social set up of the project area of influence is described.

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Relevant documents, as required under the project write up, are annexed. Public
Consultation (PCs) was held with the people in the project area. Their recorded
statements are appended at the end of this report. People have no issue for the
project installation and its operation in their area.
The proposal describes Government policies about the need of industrialization of
the country, taking into account the incentives being provided for promoting
industrialization.
Environmental Management Plan (EMP) and Environmental Monitoring Plan
(EMtP) given in this report when practiced, will ensure environmental protection and
safeguards against any possible adverse environmental aspects of the project
activity during operation phases.
The major elements of the EIA report according to the “Guidelines for the
preparation and review of Environmental Reports, October
1997/2000”ANNEXURE-V included:
i- Executive summary.
ii- Description of the objectives of the proposal.
iii- Description of the proposal and its alternatives (status of the proposal in the
project cycle, description of planning, design and implementation stages,
requirements for raw materials, energy and equipment),
iv- Discussion of the proposal and current land use and policies (current land use
controls in the context of the Government policies),
v- Description of existing and expected conditions (boundaries adopted to study
various aspects of the study),

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vi- Evaluation of the impacts and their mitigation (assessment of any impact on
the local population, relevant environmental data, gaps in knowledge,
compliance with relevant environmental standards, assessed significance of
the impacts, possible measures for avoiding or mitigation of the impacts)
vii-Environmental management plan monitoring plan and proposed training
(description of the actions, schedule for operation, assigning responsibility for
operation, monitoring program to assess performance, reporting and reviewing
procedures and outline of training needs).
This Environment Impact Assessment (EIA) report has been prepared according
to the format for preparation of Environmental Impact Assessment Reports (EIA)
ANNEXURE-V, as approved by the Government of Pakistan. This report is to be
submitted to the Sindh Environmental Protection Agency (SEPA), Government of
the Sindh, Karachi for issuance of Environmental Approval (EA) in accordance
with requirements of Section 12 of Pakistan Environmental Protection Act 1997
(PEPA 1997)- ANNEXURE-I.
For further details reference be made to the respective sections of this report

2.0 DESCRIPTION OF THE PROPOSAL AND ITS ALTERNATIVES

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2.0 DESCRIPTION OF THE PROPOSAL AND ITS ALTERNATIVES
2.1 The status of the proposal in the project cycle
(Pre-feasibility, feasibility or detailed design)
The proposal is an integral part of project report in the entire project cycle.
2.2 Description of the planning, design and implementation stages:
It was in the above back ground that the IEE/EIA report has been prepared and
submitted to the SEPA Sindh Environmental Protection Agency for its
consideration to issue NOC. As already mentioned, the project is in its final stage
of construction.
2.2.1 Planning
All planning work relating to the project aspects has been completed.
2.2.2 Design
The project has been designed by highly experienced professionals,
National Water Engineering (Pvt) Ltd. Karachi.
2.2.3 Implementation
The plant is in the final stages of completion

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2.3 The requirements for raw materials, water, energy and equipment:
2.3.1 Raw materials
Following chemicals are being used for treating sewage water:
i) Aluminium Sulphate = 100 Kg/day.
ii) Sodium Hypochlorite = 24 Kg/day.
iv) Ammonium Sulphate/Urea = 15-20 kg/day
v) Polymer = 0.5 kg/day
2.3.2 Water
There is no requirement of water at the plant site.
2.3.3 Equipment:
The major plant equipment is listed as under:
i) Oil and grease skimmer
ii) Primary Clarifier
iii) Lamella Clarifier
iv) Static Mixer
v) Multimedia Rapid Filtration Unit
vi) Dosing Pump
2.4 The planned operational characteristics-hours of operation, processes,
Products.
2.4.1 Hours of operation:
The plant will remain operational for 24 hour per day.

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2.4.2 Process:
Process Description:
The sewage treatment plant installed at the FFC-MM is based on chemical
treatment process, using Al2SO4 as coagulant, and employing LAMELLA
CLARIFIER which ensures laminar flow and high degree of separation of
solid from the suspension in a small space. To remove any floating
material, inorganic compounds and to equalize the flow, a primary
clarifier with flocculation zone has been added. At the start of the system
an O&G skimmer, with jet aeration has been employed to remove
oil/grease
Additionally, it has three MMRF (multimedia rapid filters) units for
polishing and removal of any excess chlorine and colloidal matter. To
complete the loop, the facility has sludge drying beds for sludge storage
with supernatant return to the system and the final discharge of the treated
water for disposal or reuse. The treatment process is described below
Equalization Temp. ControlRaw sewage
collection
pH Adjustment Treatment P.E. Addition Sludge
Coagulation
Sludge PrecipitationSludge Separation (via
clarifier) &Treatment
Treated effluent
ready for end use
Treated sludge ready for disposal
as manure/fuel/landfill
Treated effluent
(through weirs)

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2.5 Visual aids (maps of the area, site and plant layout, flow charts of
production, and photographs of the site and similar projects)
2.5.1 Location map
The plant location map is exhibited in ANNEXURE-VI.
2.5.2 Plant layout
The plant layout is shown in ANNEXURE-VII.
2.6 Comparison of proposal options (size, siting, technology, Layout,
energy sources):
2.6.1 Size (Capacity of the Plant):
The quantity of sewage to be treated is the main considerations upon
which plant capacity has been determined.
2.6.2 Siting (discussion of the project siting alternatives)
While taking into consideration project siting alternatives, the most
important and the major parameters taken into consideration included
availability of land, availability of dependable source of energy, labor,
basic infrastructures and environment.
However, in the present case it is a typical situation where the plant is to
be installed to the nearest place of the sewage generation. Since the
purpose of the sewage treatment plant is exclusively to treat the sewage
being generated from the Township of FFCL therefore, this was the only
consideration so specifically to be followed for installation of the pant at

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the project site. Obviously, under the specific need the other parameters
like raw materials, availability of water, labour, basic infrastructure, site
availability for the plant and environment were not applicable for
consideration of alternative to select site.
2.6.3 Technology
The technology is acquired from National Water Engineers (PVT) Limited
Karachi with its most modern features.
2.6.4 Layout
Health, Safety and Environment (HSE); operational requirements,
economic factors and last but not the least Hazardousness and Operability
(HAZOP) play important role in plant layout. Accordingly, these major
factors have been considered while deciding plant lay out.
Environmental considerations have also been taken into account with
special reference to treatment and wastes disposal. Plant layout is shown
in the ANNEXURE-VII.
2.6.5 Energy sources
Total energy required for the plant will be provided by Fauji Fertilizer
Company Limited which is situated adjacent to the plant site.

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2.7 Summary of the technical, economic and environmental features of
the proposal
A brief of technical, economic and environmental aspects of the project is
given hereunder.
2.7.1 Technical
The sewage water treatment plant has been designed and installed by
National Water Engineering (PVT) Limited Karachi. They have
guaranteed that the plant will operate to treat the sewage as required by the
applicable limiting values of the NEQS ANNEXURE-II. Since, the
technology is local; therefore, this will reduce capital cost of the plant, low
expenditure for its repair and maintenance, low cost replacement of
various worn out parts and correspondingly decrease in the capital and
recurring cost on account of repair and maintenance of the plant.
The major technical steps involved in treatment include Oil and grease
Skimming, primary clarifier, Lamella Clarifier, Static Mixer, Multiple
rapid filtration unit.
2.7.2 Economic
The estimated project cost is Rs. 12.0 million
2.7.3 Environmental
This EIA report describes duly likely environmental impacts of various
kinds both during construction and operational phases. It further provides

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the measures to be adopted to mitigate these adverse impacts. For detailed
account of the same reference be made to Section 5.0.
The report also describes details of an Environmental Management Plan,
Monitoring Plan and proposed Training Programme at Serial No: # 7. The
operation of these mechanisms will further ensure adequate environmental
management to undo the adverse impacts of the pollutants to accrue from
the project activity.
And last but not the least, Environmentally sensitive areas of special or
unique value including forestry, biodiversity, fishery, soil, water, heritage,
cultural, scientific, historical buildings, etc. have also been discussed
under Serial No: 4.0.
The proposal concludes as to how all aspects of environment as related to
the project activity will be managed in compliance with the Pakistan
Environmental Protection Act 1997 ANNEXURE-I and the National
Environmental Quality Standards Pakistan ANNEXURE-II.

3.0 DISCUSSION OF PROPOSAL AND CURRENT LAND USE AND
POLICIES AND LEGAL FRAMEWORK

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3.0 DISCUSSION OF PROPOSAL AND CURRENT LAND USE AND
POLICIES AND LEGAL FRAMEWORK
3.1 Land use
The land around the project area is under agriculture use. More than 65% of the
land is owned by the framers themselves and around 35% is cultivated by the
tenant framers. Land holding range from as low as 2.5 acres to well over 1000
acres. Farmers in the area keep small cattle herds of poultry, sheep, goats,
buffalos and cows to supplement their income and to obtain milk and other dairy
products.
3.2 Regulatory framework
Of the salient features of Government policies for facilitating investment in
Pakistan some are described as under:
3.2.1 Deregulation of the economy
Deregulation is the policy of the Government of Pakistan. Under this
policy deregulation of the economy and privatization of the state owned
companies is going on.
3.2.2 Import policy
Import policy has been liberalized to a great extent through giving various
incentives. There is an increased reliance on development of the industrial
sector and enhancement of international trade.
3.2.3 Infrastructure facilities
Infrastructure facilities such as road network, water and power supply,
means of transportation and communications etc. are being improved
speedily.

13
3.2.4 Incentives
To keep Pakistan competitive in international markets and support the
viability of investments in the country, the following incentives are
available to both foreign and local investors:
a- initial depreciation allowance (IDA),
b- amortization and
c- normal tax rates.
3.3 Legal Framework:
Comprehensive environmental framework is available in the country covering
environmental management to control environmental degradation.
With the approval of the 18th
Amendment in the constitution of The Islamic
Republic of Pakistan-1973, the subject of environment has largely been delegated
to the provinces. The federal Ministry of Environment has been abolished and
instead the Ministry of National Disaster Management has been created under
which Pakistan Environmental Protection Council; Pakistan Environmental
Protection Agency; Pakistan Environmental Planning and Architectural
Consultants Limited; Global Environmental Impact Study Centre; Islamabad
policy, legislation, plans, strategies and programme with regard to disaster
management including environmental protection and preservation, coordination,
monitoring and implementation of environmental agreements with other
countries, international agencies and forums have been put. The Pakistan
Environmental Protection Agency (Pak EPA) looks after the environment related
issues for the federally controlled areas and territories. Lacking laws at the
provincial levels; the laws, rules, regulations etc those already available at the
federal level and operational at the provincial levels will continue as such.
Hereunder, the major legal framework is given:

14
3.3.1 National Conservation Strategy (NCS)-Pakistan.
The National Conservation Strategy (NCS) - Pakistan as approved by the Federal
Cabinet in March 1992 is the guiding document on the environmental issues in
the country (Ref. EUAD/IUCN, 1992). The NCS outlines the country’s primary
approach towards encouraging sustainable development, conserving natural
resources, and improving efficiency in the use and management of resources.
The NCS has 68 specific programs in 14 core areas in which policy intervention is
considered crucial for the preservation of Pakistan’s natural and physical
environment. The core areas that are relevant in the context of the envisaged
project are pollution prevention and abatement, restoration of supporting forestry
and plantations, and preservation of cultural heritage. A mid-term review of the
achievements, impacts and prospects of Pakistan’s NCS was undertaken between
1999-2000.
The Pakistan Environmental Protection Act (PEPA), 1997 ANNEXURE-I is the
legal controlling instrument. The Sindh Environmental Protection Council
(SEPC) is responsible for administering the provisions of the Act.
Among the members of the SEPC, major ones include representatives of the
Provincial Government especially the Sindh Provincial Environmental Protection
Agencies (SEPA), industry, non-governmental organizations, academia,
environment experts, The Sindh Chamber of Commerce and Industry and the
private sector, NGOs etc. The SEPA is required to ensure compliance with the
National Environmental Quality Standards (NEQS) and establish monitoring and
evaluation systems. As a primary implementing agency in the hierarchy, it is
responsible for identifying the need for, as well as initiating legislation whenever
necessary. SEPA is also authorized to delegate powers to its lower staff, one of
the functions of the SEPA is the review and approval of Environmental Impact

15
Assessment (EIA) and Initial Environmental Examination (IEE) reports of the
projects undertaken in its jurisdiction.
3.3.2 Pakistan Environmental Protection Act (PEPA) 1997
Among many other salient features of the Pakistan Environmental Protection Act,
1997 ANNEXURE-I it empowers the Sindh EPA to:
delegate powers, including those of environmental assessment, to the its lower
staff;
identify categories of projects to which the Initial Environmental Examination
(IEE) and Environmental Impact Assessment (EIA) provisions will apply;
develop guidelines for conducting IEE and/or EIA and procedures for the
submission, review and approval of the same;
develop environmental emission standards for parameters such as air, water
and noise and
Enforce the provisions of the PEPA -2011 through environmental protection
orders and environmental tribunals headed by magistrates with wide-ranging
powers, including the right to fine violators of the Act.
The PEPA can frame environmental regulations tailored to the requirements of
the province. They are also required to review and approve EIAs/IEEs of all the
development projects undertaken in the Sindh province.

16
3.3.3 National Environmental Quality Standards (NEQS)
The National Environmental Quality Standards (NEQS) ANNEXURE-II were
first promulgated in 1993 and have been amended in 1995 and 2000.
The following standards are specified therein:
Maximum allowable concentrations of pollutants (32 parameters) in municipal
and liquid industrial effluents discharged to inland waters, sewage treatment
facilities, and the sea (three separate sets of numbers).
Maximum allowable concentrations of pollutants (32 parameters) in Drinking
water (including physical, chemical, biological, organic and radioactive
parameters).
Maximum allowable concentrations of pollutants (16 parameters) in gaseous
and particulate matter emissions from industrial sources.
Maximum allowable concentrations of pollutants in gaseous and particulate
matter emissions from ambient air.
Maximum allowable concentrations of noise in ambient air.
The Guidelines for “Self-Monitoring and Reporting” (SMART) ANNEXURE-
VIII for the industry as approved by the Pakistan Environmental Protection
Council (PEPC) adopted by the PEPA.
3.3.4 Regulations for Environmental Assessment
Under Section 12 (and subsequent amendment) of the PEPA-1997 ANNEXURE-
I, a project failing under any category specified in Schedule I (SRO 339 (I)/2000),
requires the proponent to file an EIA with the concerned PEPA. Projects falling
under any category specified in Schedule II require the proponent to file an EIA
with the federal agency. Within ten working days of the IEE or EIA having been
deposited, the federal/provincial agency will confirm that the document submitted

17
is complete for the purpose of review. During this time, should the
federal/provincial agency require the proponent to submit any additional
information, it will return the IEE or EIA to the proponent for revision, clearly
listing those aspects that need further discussion. Subsequently, the federal agency
shall make every effort to complete an IEE review within 45 days and an EIA
review within 90 days of filing.
At the time of application, the project proponent is also required to pay a specified
official fee to the PEPA to process the case.
3.3.5 Guidelines for Environmental Assessment
The Pak-EPA published a set of environmental guidelines for conducting
environmental assessments and the environmental management of different types
of development projects. These guidelines have been adopted by the Sindh EPA
(SEPA). The guidelines that are relevant to the proposed project are listed below:
3.3.6 Guidelines for the Preparation and Review of Environmental
Reports:
The guidelines on the preparation and review of environmental reports target the
project proponents, and specify:
- The nature of the information to be included in environmental reports,
- the minimum qualifications of the EIA conductors appointed,
- the need to incorporate suitable mitigation measures at every stage of project
implementation and
- the need to specify monitoring procedures.
The report must contain baseline data on the project area, detailed assessment
thereof, and mitigation measures.

18
3.3.7 Guidelines for Public Consultation:
These guidelines deal with possible approaches to public consultation and
techniques for designing an effective program of consultation that reaches out to
all major stakeholders and ensures that their concerns are incorporated in any
impact assessment study.
3.3.8 National Resettlement Policy and Ordinance
At this point, the only legislation relating to land acquisition and compensation is
the Land Acquisition Act (LAA) of 1894. Following a national consultative
process, a national resettlement policy and a related ordinance were drafted. The
draft policy and the ordinance are presently being reviewed by the provinces, and
have yet to be approved and notified by the government. The salient applicable
features of the Draft Resettlement Policy are given below:
The Sindh EPA will be responsible for both environment-related as well as
resettlement-related matters, with overall control of the provincial Planning
and Development (P&D) Department.
All categories of ‘loss’ arising from development projects that entail
resettlement, need to be addressed: these include not only loss of land, built-
up property, other infrastructure, and crops and trees, but also loss of income,
job opportunities, and access to natural resources, etc.
Vulnerable groups whose issues need to be addressed in particular include:
women, children, destitute persons, tribal communities, squatters, those with
usurper rights, and landless groups.
There should be a special emphasis on consultation with affected groups when
preparing a Resettlement Action Plan (RAP).

19
3.4 Institutional Framework
The capability of regulatory institutions for environmental management largely,
ensures the success of environmental assessment for ensuring that development
projects are environmentally sound and sustainable. For decision-making and
policy formulation in the environmental and conservation issues, the institutional
framework, as it exists in Pakistan, is described below.
3.4.1 National Environmental Regulatory/Legal Requirements:
After the 18th
Amendment to the Constitution of The Islamic Republic of
Pakistan-1973, the regulation & management of environment has largely
been delegated to the Provinces. The Federal Ministry of Environment has
been abolished and instead the Ministry of National Disaster Management
(MoNDM) has been created which shall be controlling: Pakistan
Environmental Protection Council; Pakistan Environmental Protection
Agency; Pakistan Environmental Planning and Architectural Consultants
Limited; Global Environmental Impact Study Centre; and federal policy,
legislation, plans, strategies and programme with regard to disaster
management including environmental protection and preservation,
coordination, monitoring and implementation of environmental
agreements with other countries, international agencies and forums.
Therefore, wherever the name of the previous Ministry of Environment
(MoE) in mentioned it deemed to mean the MoNDM.
The Pakistan Environmental Protection Agency (Pak EPA) looks after the
environment related issues for the federally controlled areas and
territories. Lacking laws at the provincial levels; the laws, rules,
regulations etc., those already available at the federal level and operational
at the provincial levels will continue as such.

20
3.4.2 National Conservation Strategy (NCS) - Pakistan
The National Conservation Strategy (NCS) – Pakistan, as approved by the
Federal Cabinet in March 1992 is the guiding document on the
environmental issues in the country (Ref. EUAD/IUCN, 1992). The NCS
outlines the country’s primary approach towards encouraging sustainable
development, conserving natural resources, and improving efficiency in
the use and management of resources.
The NCS has 68 specific programs in 14 core areas in which policy
intervention is considered crucial for the preservation of Pakistan’s natural
and physical environment. The core areas that are relevant in the context
of the envisaged project are pollution prevention and abatement,
restoration of supporting forestry and plantations, and preservation of
cultural heritage. A mid-term review of the achievements, impacts and
prospects of Pakistan’s NCS was undertaken between years 1999 - 2000.
The Government of Pakistan promulgated “Pakistan Environmental
Protection Act” in 1977 ANNEXURE-I. Two organizations, the Pakistan
Environmental Protection Council (Pak-EPC) and the Pakistan
Environmental Protection Agency (Pak-EPA), are primarily responsible
for administering the provisions of the Act. The Pak-EPC oversees the
functioning of the Pak-EPA. Among its major members include
representatives of the Federal and Provincial Governments especially the
Provincial Environmental Protection Agencies, industry, non-
governmental organizations, academia, environment experts, Federation of
Chamber of Commerce and Industry and the private sector.
The Pak-EPA, through the Provincial EPAs, is required to ensure
compliance with the National Environmental Quality Standards (NEQS)
and establish monitoring and evaluation systems. As a primary

21
implementing agency in the hierarchy, it is responsible for identifying the
need for, as well as initiating legislation whenever necessary. Pak-EPA is
also authorized to delegate powers to its provincial counterparts, the
provincial EPAs. One of the functions delegated by the Pak-EPA to
provincial EPA is the review and approval of Environmental Impact
Assessment (EIA) and Initial Environmental Examination (IEE) reports of
the projects undertaken in their respective jurisdictions.
3.4.3 Pakistan Penal Code (1860)
The Pakistan Penal Code usually called PPC is a penal code for all
offences charged in Pakistan. It was originally prepared by Lord Macaulay
in 1860 on the behalf of the Government of British India as the Indian
Penal Code. After the partition of British India in 1947, Pakistan inherited
the same code and subsequently after several amendments [e.g. Protection
of Women (Criminal Laws Amendment) Act, 2006, Criminal Laws
(Amendment) Act, 2004 (I of 2005), Criminal Law (Amendment)
Ordinance (LXXXV of 2002), Criminal Laws (Reforms) Ordinance
(LXXXVI of 2002), etc.] it is now mixture of Islamic and English Law.
Pakistan Penal Code is a general criminal law, applies all over the country,
and contains specific provisions on the subject. Thus it prohibits mischief
by killing or maiming animals, or damaging works of irrigation or a river
or a road or a bridge or drain or firing explosive substances with intent to
cause damage. The Code also prohibits public nuisance by acting
negligently to spread the infection of disease or disobeying quarantine rule
or causing adulteration of food or drink or drug, or fouling water or
making the atmosphere noxious to health etc.

22
3.4.4 Pakistan Environmental Protection Act, 1997
The promulgation of the Environmental Protection Ordinance, 1983 was
the first codifying legislation to the issue of environmental protection.
Later, the Government passed the Pakistan Environmental Protection Act
(PEPA), 1997 ANNEXURE-I, which is the basis of IEE/EIA studies
carried out for the projects in Pakistan.
PEPA, 1997 is a fairly comprehensive legislation and provides protection,
conservation, rehabilitation and improvement of the environment. It
contains concrete action plans and programs for the prevention of
pollution and promotes sustainable development. The salient features of
the law are:
It covers the air, water, soil, marine and noise pollution including
pollution caused by motor vehicles.
The Act provides National Environmental Quality Standards (NEQS)
for wastewater, air emissions and noise.
Law provides clear cut guidelines for IEE/EIA for various projects as
per their magnitude and anticipated impacts.
Law also empowers Federal Government to issue notices and to
enforce them for the protection of the environment.
For the effective implementation of the provisions of PEPA, 1997,
Pakistan Environmental Protection Agency, headed by a Director General
was constituted. On the same pattern, Provincial Environmental Protection
Agencies (EPA’s) were created in all the provinces. Environmental
Tribunals were also constituted according to PEPA, 1997.

23
3.4.5 Policy and Procedures for the Filing, Review and Approval of
Environmental Assessments
This document sets out the key policies and procedural requirements. It
contains a brief policy statement on the purpose of environmental
assessment and the goal of sustainable development and requires that
environmental assessment be integrated with feasibility studies. It also
defines the jurisdiction of the Federal and Provincial EPA’s. It lists down
the responsibilities of the proponent and states the duties of responsible
authorities. It provides schedules of reports that require either an IEE or
EIA.
3.3.6 Guidelines for the preparation and review of Environmental
Reports (NOVEMBER 1997/2000)
These guidelines are descriptive documents regarding the format and
content of IEE/EIA reports to be submitted to EPA for “No-Objection
Certificate (NOC)/Environmental Approval (EA)”. Following are the
major areas, which are covered by these guidelines:
The IEE/EIA report (scope, alternatives, site selection, format of IEE
report)
Assessing impacts (identification, analysis and production, baseline
data, significance)
Mitigation and impact management (and preparing an environmental
management plan)
Reporting (drafting style, main features, shortcomings, other forms of
presentation)
Review and decision making (role, steps, remedial options, checks and
balances)

24
Monitoring and auditing (systematic follow up, purpose, effective data
management)
Project Management (inter-disciplinary teams, programming and
budgeting)
3.4.7 Guidelines for Public Consultations
These guidelines deal with possible approaches to public consultation
(PC) and techniques for designing an effective program of consultation
that reaches out to all major stakeholders and ensures the incorporation of
their legitimate concerns in any impact assessment study. These guidelines
cover:
Consultation, involvement and participation of Stakeholders
Techniques for public consultation (principles, levels of involvements,
tools, building trust)
Effective public consultation (planning, stages of EIA where
consultation is appropriate)
Consensus building and dispute resolution
Facilitation involvement (including the poor, women, building
community and NGO capacity
3.3.8 National Environmental Quality Standards (NEQS)-1993,
Amended August 2000
The National Environmental Quality Standards (NEQS) were first
promulgated in 1993 and have been amended in August, 2000
ANNEXURE-II.
The following standards are specified therein:

25
Maximum allowable concentrations of pollutants (32 parameters) in
municipal and liquid industrial effluents discharged to inland waters,
sewage treatment facilities, and the sea (three separate sets of
numbers)
Maximum allowable concentrations of pollutants (16 parameters) in
gaseous emissions from the industrial sources
The Guidelines for “Self-Monitoring and Reporting” (SMART)
ANNEXURE-VIII for the industry as approved by the Pakistan
Environmental Protection Council (PEPC).
A copy of the Government of Pakistan, Gazette Notification dated August
10, 2000 regarding NEQS is attached as ANNEXURE –II.
3.4.9 Guidelines for Sensitive and Critical Areas
These guidelines identify sensitive and critical areas in Pakistan, in
relation both to the natural environment and the cultural aspects.
3.4.10 National Resettlement Policy and Ordinance
At this point, the only legislation relating to land acquisition and
compensation is the Land Acquisition Act (LAA) of 1894. Following a
national consultative process, a national resettlement policy and a related
ordinance were drafted. The draft policy and the ordinance are presently
being reviewed by the provinces, and have yet to be approved and notified
by the government. The salient applicable features of the Draft
Resettlement Policy are given below:
The Pak-EPA will be responsible for both environment-related as well
as resettlement-related matters,

26
The responsibilities for implementation at a provincial level are to be
delegated to the concerned provincial EPAs with overall control of the
provincial Planning and Development (P&D) Departments.
All categories of ‘loss’ arising from development projects that entail
resettlement, need to be addressed: these include not only loss of land,
built-up property, other infrastructure, and crops and trees, but also
loss of income, job opportunities, and access to natural resources, etc.
Vulnerable groups whose issues need to be addressed in particular
include: women, children, destitute persons, tribal communities,
squatters, those with usurper rights, and landless groups.
There should be a special emphasis on consultation with affected
groups when preparing a Resettlement Action Plan (RAP).
The provisions of the Draft Resettlement Policy are consistent with the
requirements of the World Bank OD 4.30 on involuntary resettlement.
3.3.11 Forest Act, 1927
All India Forest Act, 1927 was adopted by the Government of Pakistan,
which was subsequently implemented by the respective provinces.
Basically, the law was enacted to conserve and protect the forest resources
of the country for sustainable development. It lays down Rules and
Regulations for exploitation of various categories of forests such as
reserved, protected or unclassified. Further, the Act spells out the licensing
method for timber cutting, grazing, hunting etc. It also gives the details of
magisterial powers of Forest Department officers and penalties for
offences committed with regard to forest resources and products.

27
3.4.12 Industrial Relation Ordinance, 2002
The ordinance has been promulgated to amend, consolidate and rationalize
the law relating to formation of trade unions, regulation and improvement
of relations between employers and workmen and avoidance and
settlement of any differences or disputes arising between them Pakistan’s
labour laws trace their origination to legislation inherited from India at the
time of partition of the Indo-Pak subcontinent. The laws have evolved
through a continuous process of trial to meet the socio-economic
conditions, state of industrial development, population and labour force
explosion, growth of trade unions, level of literacy, Government’s
commitment to development and social welfare. To meet the above named
objectives, the government of the Islamic Republic of Pakistan has
introduced a number of labour policies, since its independence to mirror
the shifts in governance from martial law to democratic governance.
While Article 18 of the Constitution affords every citizen with the right to
enter upon any lawful profession or occupation, and to conduct any lawful
trade or business, the Industrial and Commercial Employment (Standing
Orders) Ordinance was enacted in 1968 to address the relationship
between employer and employee and the contract of employment. The
Ordinance applies to all industrial and commercial establishments
throughout the country employing 20 or more workers and provides for
security of employment. In the case of workers in other establishments,
domestic servants, farm workers or casual labour engaged by contractors,
their labour contracts are generally unwritten and can be enforced through
the courts on the basis of oral evidence or past practice.
The Constitution of Pakistan contains a range of provisions with regards to
labour rights found in Part II: Fundamental Rights and Principles of
Policy.

28
Article 11 of the Constitution prohibits all forms of slavery, forced
labour and child labour;
Article 17 provides for a fundamental right to exercise the freedom of
association and the right to form unions;
Article 18 proscribes the right of its citizens to enter upon any lawful
profession or occupation and to conduct any lawful trade or business;
Article 25 lays down the right to equality before the law and
prohibition of discrimination on the grounds of sex alone;
Article 37(e) makes provision for securing just and humane conditions
of work, ensuring that children and women are not employed in
vocations unsuited to their age or sex, and for maternity benefits for
women in employment.
3.4.13 Industrial Relations Ordinance 2011 Promulgation
The Government has promulgated Industrial Relations Ordinance 2011.
The Ordinance has been approved by the President on the Advice of the
Prime Minister. The Government has promulgated Industrial Relations
Ordinance, 2011 in view of the current legal vacuum created due to
deletion of the concurrent Legislative List through the 18th Constitutional
Amendment. The Industrial Relations has also been transferred to the
Provinces which have promulgated provincial laws to regulate industrial
relations. However, there is no law in place to deal with Industrial
Relations in the Islamabad Capital Territory or in respect of national level
trade federations and for resolutions of trans-provincial industrial issues.
The Parliament has yet to promulgate the Ordinance as law.

29
3.4.14 Other Relevant Laws
Some of the other relevant laws and legislations are listed below:
Canal and Drainage Act, 1873
The Explosives Act, 1884
The Fire Wood and Charcoal (Restriction ) Act, 1964
Motor Vehicles Ordinance, 1965
The West Pakistan Regulation and Control of Loudspeaker and Sound
Amplifier Ordinance, 1965
Agriculture Pesticides Ordinance, 1971
The Antiquities Act, 1975
3.4.15 National Electric Power Regulatory Authority (NEPRA) Act
1997
The NEPRA Act was approved by Parliament and signed into law in
December 1997. It seeks to create an autonomous, independent regulatory
authority, which will be solely responsible for the power sector. It will be
responsible for the oversight of the power sector and will exercise control
through its power to license power generation, transmission and
distribution. It will regulate tariffs for all these activities. It will perform
its functions through transparent processes to be enshrined in rules that are
being framed in a transparent manner through appropriate rules.
3.4.16 Power Policy 1998
The revised power policy was implemented in 1998. The objective and
intentions of the Government of Pakistan (GOP) to new policy is to move
towards the creation of a competitive power market in Pakistan. It
proposes to do so by restructuring and privatizing the existing thermal

30
power generation, the power transmission and distribution functions and
assets of existing public sector utilities (WAPDA/KESC), by the creation
of a fully autonomous regulatory authority, the National Electric Power
Regulatory Authority (NEPRA), and through its future IPP policy.
The salient features of the Policy are;
The basis for selection of private power project will be minimum
levelized tariff through International Competitive Bidding. Variable
tariffs over the life of the project will be permitted under terms
specified prior to bidding. The process of selection will involve pre-
qualification, issuance of a Request for Reports (RFP), bidding and
evaluation of bids against bid criteria clearly laid out in the RFP.
It is recognized that without a proper feasibility study for a particular
site-specific hydel or indigenous coal based project, it will not be
possible to invite competitive bids and receive firm offers. Thus,
detailed feasibility studies for such projects will be prepared before
bids are invited.
Hydel projects will be implemented on a Build-Own-Operate-Transfer
(BOOT) basis; to be transferred to the province in which it is situated
at the end of the concession period, and thermal projects on a Build-
Own-Operate (BOO) basis.
Competitive Tariffs will comprise an Energy Purchase price and a
Capacity Purchase Price with adequate provisions for escalation.
3.4.17 Factories Act, 1934
There is no independent legislation on occupational safety and health
issues in Pakistan. The main law, which governs these issues, is the
Chapter 3 of Factories Act, 1934. All the provinces, under this act, have
devised Factories Rules. The Hazardous Occupations Rules, 1963 under
the authority of Factories Act is another relevant legislation. These rules

31
not only specify some hazardous occupations but also authorize the Chief
Inspector of Factories to declare any other process as hazardous.
The other related laws are:
Workmen Compensation Act, 1923
Provincial Employees Social Security Ordinance, 1965
West Pakistan Shops and Establishments Ordinance, 1969
Boilers and Pressure Vessels Ordinance, 2002
Chapter 3 of the Act has general provisions on health and safety at the
workplace. Provincial governments are allowed to make rules under this
Act and inspectors under this Act also have discretion in defining the
rules. Chapter 3 talks about various safety arrangements. This list is being
provided just to show how meticulously labor law covers these issues.
Cleanliness
Disposal of wastes and effluents
Ventilation and temperature
Dust and fume
Artificial humidification.
Overcrowding
Lighting
Drinking water
Latrines and urinals
Spittoons
Precautions against contagious or infectious disease
Compulsory vaccination and inoculation
Power to make rules for the provision of canteens
Welfare officer
Precautions in case of fire

32
Fencing of machinery
Work on or near machinery in motion
Employment of young persons on dangerous machines
Striking gear and devices for cutting off power
Self-acting machines
Casing of new machinery
Prohibition of employment of women and children near cotton openers
Cranes and other lifting machinery
Hoists and lifts
Revolving machinery
Pressure plant
Floors, stairs and means of access
Pits, sumps, opening in floors, etc.
Excessive weights
Protection of eyes
Power to require specifications of defective parts or tests of stability
Safety of building, machinery and manufacturing process
Precautions against dangerous fumes
Explosive or inflammable dust, gas, etc.
Notice of certain accidents
3.5 Environment Related Relevant International Agreements in Pakistan’s
context:
Pakistan is a party to the following treaties and agreements in furtherance
of its environmental goals and programme.
Treaty Pakistan Status
Convention on the Protection of Ozone Layer on Ratified

33
Dec 18, 1992.
The Amendment to Montreal Protocol on
Substance that Depleting Ozone layer
Signed
UN Framework Convention on Climate Change on
June 13, 1992
Signed
Convention on the Continental Shelf on October
31, 1958
Signed
The Convention on High Seas on October 31, 1958 Signed
Convention on the Fishing and Conservation of the
living Resources of the High Seas on October 1958.
Signed
The UN Convention on Law of the Sea on
December 10, 1982
Signed
The Convention on Territorial Sea and the
Contagious Zone and the Agreement for the
establishment of Network of Aquaculture Centers
in Asia and the Pacific
Signed
The Convention on Wetlands of the International
Importance on July 23, 1976
Ratified
The Convention on protection of the World
Cultural and Natural Heritage on July 23, 1976
Ratified
The Convention on International Trade in
Endangers Spice of Wild Fauna and Flora
Signed
The Convention on Conservation of Migratory
Specie of Wild Animal on Dec 01, 1987
Signed
The Convention on Biological Diversity in 1994
and became party to the CBD, Convention duly
recognizes the intrinsic value of biological
diversity, genetic, social, economic, cultural,
educationist, recreational and esthetic values of
Ratified

34
biodiversity and its components
The International Plant Protection Convention. Signed
The Plant Protection Agreement for Area & pacific
region
Signed
The Agreement for the establishment of a
convention for controlling the desert lost in eastern
region of its Distribution Area in South East Asia
Signed
The Treaty Banning Nuclear Weapon Test in the
Atmosphere, in Outer Space and under Water on
March 3, 1988
Signed
The International Convention on Oil Pollution
Preparedness Response and Corporation
Signed
The Convention on prohibition of Military or any
other Hostile Use of Environmental Modification
Techniques and Accession of Feb 27, 1986
Acceded
Pakistan became a party to Montreal Protocol by
Ratifying the protocol and its London amendment
on Dec 18, 1982.the subsequent amendments
known as Copenhagen Amendment which,
accelerate the phase out for rectified in Jan 1995.
Signed
Convention of International trade Endangerous
Species (CITS)
Signed
World heritage Convention Ramsar Convention Signed
United Nation Convention to Combat Ozone
Depletion (CCD). The convention signed and
ratified in 1996
Signed
Stockholm Convention for Phasing out Parenting
Organic pollutants (POPs) in 2001.
Signed

4.0 DESCRIPTION OF EXISTING AND EXPECTED CONDITIONS

28
4.0 DESCRIPTION OF EXISTING AND EXPECTED
CONDITIONS
4.1 Spatial and temporal boundaries adopted for the various aspects of
the study
While carrying out the present study, factors including present environmental
settings and likely future trends around the project site were taken into
consideration. Availability of basic infrastructure, water, raw materials, labor,
transport and electricity were the major among other factors considered in the
project area. Socio-economic conditions were also considered during the course
of the study.
4.2 Existing (baseline) condition of the biophysical and socio-economic
environment, trends and anticipated future environmental conditions
should the project not go ahead
A detailed account the Socio-economic environment is given under serial #
4.3.1.13.
4.3 Environmentally sensitive areas of special or unique value Physical
resources of the project area:
Topography and geology; Soils and Climate; water; Ecological resources:
Fisheries and aquatic biology, Biodiversity, Forestry, Wildlife, scientific
institutions, Socio-economic, Cultural and other heritage.
4.3.1 Physical resources of the project area
Physical resources of the project area are described as below.

29
4.3.1.1 Topography and geology
Pakistan lying in the northwestern part of the Southern Asian
Subcontinent, occupies the western end of the Indo-Genetic Plain,
which is beyond bounded in the north by mountain wall of the
Great Himalayas and their offshoots.
Physiology of the earth is description of the behavior of the upper
crust. The land in this area consists of the alluvial soil deposited by
the waters of the river Indus, so it is naturally very fertile. Almost
60% of the land is cultivated while the rest is under forest. Major
crops are wheat, cotton and sugarcane. Sunflower and a variety of
vegetable are also grown. In addition to the river Indus a number
of canals including Ghotki Feeder provide the necessary irrigation
system.
The area is classified as hot arid on overall basis; however canals
are available for irrigation purpose. December and January are the
coolest months of the year while June and July are the hottest.
Total annual rainfall is in the range of 125 to 250 mm.
More than 65% of the land is owned by the framers themselves and
around 35% is cultivated by the tenant framers. Land holding
range from as low as 2.5 acres to well over 1000 acres. Farmers in
the area keep small cattle herds of poultry, sheep, goats, buffalos
and cows to supplement their income and to obtain milk and other
dairy products.

30
4.3.1.2 Land
The land in this area consists of the alluvial soil deposited by the
waters of the river Indus, so it is naturally very fertile. Almost 60%
of the land is cultivated while the rest is under forest. Major crops
are wheat, cotton and sugarcane. Sunflower and a variety of
vegetable are also grown. In addition to the river Indus a number
of canals including Ghotki Feeder provide the necessary irrigation
system.
Hand pumps and tube wells are also common in this area because
of a very shallow water table which may rise as high as 1.5 feet
below ground in some Katcha area.
The area is classified as hot arid on overall basis; however canals
are available for irrigation purpose. December and January are the
coolest months of the year while June and July are the hottest.
Total annual rainfall is in the range of 125 to 250 mm.
More than 65% of the land is owned by the framers themselves and
around 35% is cultivated by the tenant framers. Land holding
range from as low as 2.5 acres to well over 1000 acres. Farmers in
the area keep small cattle herds of poultry, sheep, goats, buffalos
and cows to supplement their income and to obtain milk and other
dairy products.
4.3.1.3 People
There are several small human settlements in the form of villages
scattered throughout the project area. The main village is usually
surrounded by a number of small settlements named as Goths.

31
These are named after the family chief and are inhabited by the
few households related to these families.
The people living in this area are strongly tied in the tribal systems.
There are more than 50 tribes/sub tribes or castes consisting of
Muslims and Non-Muslims. The prominent ones include:
- Muslims:
Syed, Soomro, Memon, Merani, Bohar, Dakhan, Sanghar, Leghari,
Jaskani, Khosa Baloah, Khohawar, Waso, Chachar, Drigh, Lakhan,
Solangi, Malik, Mahar, Thaheem, Bharo, Manganhar, Ghotta,
Sundrani, Kalora, Bhutta, Machhi, Bozdar, Pitafi, Lond.
- Non-Muslims:
Hindus, Marvani, Oad.
The majority of population is directly or indirectly engaged in the
agricultural activities which continue whole year. The ratio of
farmers, laborers and servicemen is almost uniform throughout the
villages and ranges between
Farmers 70-80%
Laborers 15-20%
Servicemen 05-10%
Majority of the people living in this area belong to the middle and
lower classes. The number of persons in these classes varies from
village to village but normally ranges between

32
Middle class 20-40%
Lower class 60-80%
4.3.1.4 Languages:
Sindhi is the only dominant language of the area which is used as
the official and business language. The literate people have
knowledge of Urdu but English is known only by few highly
educated people. Literacy in the project area very low. In the larger
villages, literacy rate is relatively higher than the smaller ones. In
the main towns of Qadirpur and Goth Jumma, it ranges between 10
to 20% in both sexes while in males it is about 10% age points
more.
4.3.1.5 Sports and Entertainment:
The medium of entertainment and information is radio and
television. There are no proper play grounds or other facilities for
children, and playing in the fields is their favorite pastime.
4.3.1.6 Wildlife - Plant
As mentioned before, about 40% of the land of this area sustains
forest which is classified as thorny forest. A number of tree and
bush species exist here which include Acacia nilotica, Prosopis
julifora, Procopis cineraria, Zizyphus numularia, Arundo donax,
Cymbopogon sp. and Chrysopogon sp. These species of trees grow
in Katcha area, where in Pacca area scattered trees of Acasia
prosopis Zizyphus and Albezzia species are common.
Forests and their approximate acreage are given in the following
table.

33
- Forest Area in acres (Approx.)
Sundarani 1951
Jehanpur 745
Wasti 677
Budh 1197
Bahab 3022
Divisional forest officer is responsible for monitoring and
maintenance of these forests. The officer is stationed in Sukkur.
Also a forest guard is based in Qadirpur who is responsible for
preventing illegal logging.
- Wildlife – Animals
Ghotki project area is quite rich in wildlife due to its diversity of
habitat. The species of birds are especially common, a number of
reptiles and amphibian species are also found here. There is a long
list of mammals, birds and reptiles which are found here.
- Mammals:
Tatera indica (Antilope rat)
Lepus nigricollis (Black napedhare)
Herpestes edwardsi (Grey mongoose)
Hemiechinus auritus (Hedgehog)
Axis procinus (Hog deer)
Mus musculus (House mouse)
Ratus ratus (House rat)
Platanista indi. (Indus dolphin)
Canis aureus (Jackal)

34
Felis chaus (Jungle cat)
Funanbulus fennanti (Northern palm squirrel)
Lutra perspicillata (Otter)
Hystrix indica (Procupine)
Vulpes vulpes (Res fox)
Nesokia indica (Short tailed mole rat)
Sus scrofa (Wild boar)
- Birds:
Acridotheres gingianus (Bank myna)
Lanius vittatus (Bay backed shrike)
Dicrurus adsimilis (Black drongo)
Francolinus francolinus (Black partridge)
Larus ridibundus (Black headed gull)
Podiceps nigricollis (Black necked grebe)
Elanus caeruleus (Black winged kite)
Himantopus himantopus (Black winged stilt)
Bueto bueto (Buzzard)
Bubulcus ibis (Cattle egret)
Corvus splendens (Common crow)
Trunga hypoleucus (Common sandpiper)
Haliaetus leucoryphus (Fish eagle)
Anas querquedula (Gargany)
Francolinus pondicerianus (Grey partridge)
Saxicoloides fulicata (Indian robbin)
Torgos calvus (King vulture)
Vanellus indicus(Lapwing)
Phalacrocorax niger(Little cormorant)
Egretta garzetta(Little egret)
Egretta intermedia(Median egret)

35
Ceryle rudis(Pied kingfisher)
Anas acuta(Pintail)
Ardea purpurea(Purple heron)
Neophron peromopterus(Scavenger vulture)
Alcedo atthis(Small blue kingfisher)
Aquila rapax(Tawny eagle)
Halcyon smyrnensis(White breasted kingfisher)
Amaurornis phoenicurus(Whtie breasted waterhen)
- Amphibians and Reptiles:
Hardella thurgi(Crown turtle)
Trionyx gangeticus(Giant soft shelled turtle)
Kachuga smithii(Hard shelled turtle)
Chitra indica(Soft shelled turtle)
Natrix piscator(Water snake)
- Protected Animals:
Sindh Wildlife Department promulgated an ordinance in 1972 for
protection of Wildlife in the province which contains a list of
protected animals, some of which are found in the vicinity of
project area: Indus Dolphin and Hog Deer are of special
importance as they are endangered animals.
- Protected Birds:
All members of the family Ardeidae: i.e., all Herons, Night
Herons, Paddy Birds, Egrets or Bitterns.
All members of the family Pelecanidae: i.e., all Pelicans.
All members of the family Ciconidae: i.e., all Strokes.

36
All members of the genus Cygnus: i.e., all Swans.
All members of the family Phasianidae: i.e., all Pheasants,
Partridges, Quails, Supurfowls, Jungle fowls and Peafowls.
All members of the genus Heliopais: i.e., all Finfoots.
All members of the family Otidiae: i.e., all Bustards.
Pterocles alchata. – Large Pin-tailed Sandgrouse.
- Protected Mammals:
Macaca speciosa. – Stump-tailed Macaque.
Presbytis obscurus. – Dusky Leaf Monkey.
Vulpes cana. – Boanford’s Fox.
Felis viverrina. – Fishing Cat or Marsh Billi, Mach Bagral.
Azis axis. – Spotted Deer or Chittal, Chitra, Jhank, Pagal,
Hiran, Boro, Khetiya.
Axis porcinus. – Hog Deer or Para.
Boselaphus tragocamelus. – Blue Bull or Nilgai, Gond,
Bain, Ranjh, Rojra.
Platanista gangetica. – River Dolphin or sus, Susu, Susuk,
Sishuk, Bhulan, Sunsar.
- Protected Reptiles.
Crocidilus palustris. – Marsh Crocodile or Muggar, Magar
Mach.
Crocodilus porosus. – Estuarine Crocodile or Maggar.
All Snakes pf the genus Python: i.e., all Pythons, Azdha or
Arar.
All marinr turtles of the genera Dermochelys, Chelone,
Caretta and Eretomichelys i.e., all Leather back, Green or
edible, Hawks bill, Logger head and Tortoise-shell Turtles.
(Source: Sindh Wildlife Department, Karachi)

37
- Indus Dolphin:
According to the Sindh Wildlife Department there are about 16-18
schools of Indus Dolphins between Guddu and Sukkur Barrages
each having 15-30 individuals. Indus Dolphin is very rare and
specialized fresh water dolphin, being confined to fluvial not tidal
water. It differs from most other dolphins due to its broad spade
shaped flippers and the beak which is very long and slender. The
colour of this dolphin is pale brown with slightly paler ventrally.
Adult body length is about 5-6 ft and may weigh up to 100 kg.
They locate objects by sonar or echolocation which is specially
developed in this animal because its eyes have become non
functional lacking any lens.
Indus Dolphins prefer deep running waters and come out of water
surface for breathing every 2-3 minutes interval. Babies breathe
more frequently than the adults. The animals is quite social and
schools of 10 or more individuals circle around and swim together,
but solitary or a pair of animals are also observed.
The animals prey and feed in the early part of night. They
frequently move to shallow waters and enter the side channels of
main river to hunt. These regions are inhabited by small fishes
which form the major part of the dolphin’s diet.
- Hog Deer:
This deer is confined to the river forests in the plains particularly
where there are dense grass patches of Sacchaum and Tamarix.
This is a small ungulate with short delicate legs and bulky heavy

38
body. The General colour is dark olive brown. Adult males stand
24-28 inches high at the shoulders and measures 42-44 inches from
nose to tip of the tail. The females are slightly smaller than the
males and lack horns. The horns of male are 12-14 inches long
borne on hairy pedicles.
With the increase in cultivated area right up to the banks of river, it
is now confined to isolated pockets of jungles in the less accessible
regions. Main population of Hog Deer now survives in the Indus
River Forest Reserves of Sindh.
Hog Deer is not a social animal and lives solitary existence. In
feeding habits they are largely nocturnal. One of the principal food
of this animals is young leaves of Euphratic Poplar.
Other mammals include Wild Boar and Porcupine which are
considered pests for the crop.
4.3.1.7 Industries:
The project area is not yet developed in industrial terms. Qadirpur Gas
field, Fauji Power Plant, Mari Gas Field, Engro Chemicals, Liberty Power,
Engro Energy are some worth mentioning units present in the project area.
4.3.1.8 Infrastructure:
The area is supplied electricity from the National Grid of Water and Power
Development Authority. Almost all the bigger villages are connected
through roads the district head quarter of the area. Even small connecting
roads are available. Some big villages are supplied drinking water from
civil water supply. Variety of private road transport in the form of buses

39
and wagons are available to reasonable extent. Underground water from
shallow depth is also used for irrigation and drinking.
4.3.1.9 Transportation: roads, rail, airports, navigable rivers:
There is a reasonable network of roads connected by small roads in the
area. Virtually most of the villages are connected with each other through
these roads. The country’s main railway line also passes through Mirpur
Mathelo. There is Sukkur & Rahim Yar Khan airports in the project
around. River Indus and its tributaries canal flows near to the project site.
4.3.1.10 Land use planning:
The entire land use planning is carried out according to the provincial
laws. Under the present Government system, the District Government is
responsible for all land use planning.
4.3.1.11 Power sources and transmission:
WAPDA power network operates in the area. Transmission of power is
through overhead electric transmission lines. National grid is the source of
all power in the area.
4.3.1.12 Agricultural and mineral development:
Land holdings are very small. Agriculture mainly depends upon rain
water. Underground water form shallow depth is also used for agriculture
but due to cost factor this is unaffordable by many people. Agriculture
alone cannot sustain life of the people.

40
Natural gas is also available and exploitation of gas is going on for the last
so many decades. This exploitation is on major scale.
4.3.1.13 Quality of life:
- Socioeconomic values:
The land around the project area is not arid completely as canal water is
also available for irrigation. Average land holdings are very small. The
people also supplement their income also by rearing of goats, sheep and
cows on a limited scale. The people of the area are generally poor.
Since the area is not yet industrialized, therefore, job opportunities are
very less. A large number of the people do mostly labor and other menial
work especially at Islamabad, Faisalabad, Lahore and Karachi. However,
some are working in Middle East. Fairly over 10% of the younger
generation is in Pakistan Army.
There is also a highly educated, affluent and well placed segment of the
society in the area. Their way of life can be compared with that of any
developed segment of the society of Pakistan. They provide leadership
role for development of other classes of the society. They are quite helpful
to the people of their areas. They serve as Beacon house for the other low
placed class. Their role in the development of the area and society is quite
important.
People mostly follow old traditions in almost all walks of heir life. Elders
are very much respected and play vital role in decision-making. Old
people are mostly illiterate. Old customs are being practiced. Arranged
marriage system is followed and it is quite successful. People are proud of
their traditions and customs. Joint family system prevails and people reap

41
the fruits of this system. Families are quite coherent. Guests are welcome
as a tradition from the old past. Life style is simple.
Due to awareness about the importance of education most of younger
generation, including both sexes, is now trying to get education. There is a
rising trend in the society to change their old traditional socioeconomic
pattern of life. Print and electronic media are playing great role in bringing
tangible change in the old pattern of life.
- Public health:
Only small scale dispensaries are available at some villages of the area.
However, at Mirpur Mathelo, District hospital is run by Government.
- Recreational resources and development:
With the exception of the Sukkhur Barrage there is no other worth
mentioning recreational facility in the project area. Even the lake is not
developed befitting of requirements. The area is arid and rain is quite
scanty. There is worth mentioning development in the area in terms of
industry. There are many industries in the area including Engro
Chemicals, Liberty Power, Engro Energy, Mari Gas Filed, Fauji Power,
and Qadirpur Field.
- Cultural and aesthetic values:
Old traditional cultural and aesthetic values prevail among most of the
people. Where some people belong to middle class, there a large number
of the people are living life below poverty levels. However, media is
playing a big role to bring change in the traditional aesthetic values
presently prevailing among a large cross section of the society. There is

42
also a section of affluent people who follow even the modern aesthetic
pattern of life. A tangible change is appearing among a cross section of the
society who is trying to pursue the modern aesthetic values of life.
Financial and religious factors influence aesthetic and culture values of a
society. People are religiously having strong commitment to Islam. This
relation contributes to good aesthetic and cultural values among the
people.
Area around the project site is not completely arid zone; agriculture also
depends on irrigation (Canals). Some people own small land holdings.
Agriculture depends upon rain water and that too on very limited scale.
People cannot sustain life on this single agriculture source. Resultantly,
aesthetic and cultural practices of a poor and medium type of society are
dominant among a large cross section of the society.
On the over all basis, century old traditions of typical villages of Sindh are
prevalent in culture and aesthetic sense of life. Most of the people follow
quite old type of life, rituals and traditions.
Most of the old people are illiterate but awareness and importance of
education is attracting the people to send their wards to schools mostly up
to primary level and some inclination to high school education is also
shown.
Mostly, customs and rituals are primitive in nature. Some modernization
in the existing cultural values is appearing among those educated and
economically well off and those frequently mixing with urban society.

5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES

43
5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES
Evaluations of the likely adverse impacts of the project activity on the
environment and mitigation measures to be adopted are discussed as below:
5.1 Assessment of any environmental impact on local population and the
environment during construction and operational phase
The possible adverse impacts that could appear on the environment from the
project operation, both during construction and regular operation are described
hereunder. These are followed by description of the mitigation measures to be
adopted to manage them.
It is pertinent to note at the very outset that the project is to be operated in
accordance with the legal requirements of PEPA-1997 and the NEQS Pakistan.
EMP and EMtP, as recommended in this EIA report at Serial No: 7 are to be
strictly adhered to. Further, the project proponent has filed with the EPA Sindh,
written Affidavit and Undertaking on judicial papers, that the project throughout
its life will be operated under Environmental Management Order. Failing
compliance with the legal requirements invites heavy penalties resulting in
ultimate closure of the project in case of continued violence of the NEQS goes on
beyond the legally prescribed limits of time. These conditions provide safeguards
to the environment against pollution from the project both during construction and
regular operation.
5.1.1 Likely adverse impacts from plant during construction
5.1.1.1 Environmental Adverse Impacts During Construction
The likely adverse environmental impacts to occur due to the
project activity during construction phase are described as below:

44
5.1.1.2 Pollution impacts and remedies
Excavation, construction activities, moving vehicles, machinery,
materials transport activity and plant installation are the likely
main sources of pollution during construction phase.
Extremely low concentrations of pollutants including emissions of
sulphur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide
(CO); particulate matter (PM) and noise from construction
machinery and vehicles to be used to transport materials of
construction. Sewage will be generated from the construction camp
for labour especially. Dust (PM) will also be generated especially
during excavation for civil construction, moving machines and
transport.
Construction activities will be carried out according to a well
planed action plan based on sound environmental management and
controls principles. Construction plan was prepared also keeping in
view avoiding maximum use of machinery at the same time.
Minimum number of machines and execution of minimum number
of operations/construction/plant installations jobs at a time will be
followed. Under all these construction and other operations
gaseous emissions, particulate matter and noise from the
machinery and vehicles will be the minimized and curtailed within
limited area of the project. Therefore, pollution factor will be
further reduced at source. As far as possible construction work was
carried out during day time.
Vehicles to visit the site, carrying plant machinery and other
materials are not to stampede at the project site. Rather their visit

45
was regulated under a well considered plan. They will approach
the project site at different intervals of time and in limited number.
Only vehicles of the latest models were engaged for the project
work. Therefore, all type of pollutants including gaseous, PM,
noise levels and so on was curtailed through these programming
and management mechanisms of number and time of visits of the
vehicles.
During construction sewage and spilled water in limited quantity
was generated from construction activity. This will be discharged
to main effluent pond from where it will be use for irrigation
purposes.
Even during plant machinery installation period the best
environmental management practices are to be strictly followed
according to a plan encompassing environmental element.
- Solid wastes:
Solid wastes in the form of Concrete, steel strips, plastic sheets,
steel and brick pieces, redundant aggregate and iron scrap will be
the major solid wastes. While brick pieces and redundant aggregate
from civil construction work will be retained for any further walls
foundations fillings, the rest of the items fetch a lot of market
where it will be sold for reuse.
5.1.2 Environmental Adverse Impacts During Operation stage:
Environmental pollution on all accounts from the project activity on
regular basis shall be managed by strict compliance with the
Environmental Management Plan (EMP) and Environmental Monitoring

46
Plan (EMtP) as recommended in this EIA Report and following
environmentally sustainable practices/cleaner production practices.
- Effluent:
As already mentioned that this is a sewage water treatment plant and
the treated sewage will meet the limiting values of the applicable
parameters as required according to the NEQS limiting value.
- Noise:
The plant has neither any process, nor operations nor the equipment to
be used for the treatment which will produce any noise.
- Solid wastes:
Night soil will be the semisolid waste. This will be treated to the extent
where its usefulness as organic mineral could be use as fertilizer.
5.2 The relevant environmental data and predictive methods used and any
underlying assumptions made
5.2.1 Base line environmental data
In order to know about the existing status of environment on the project site,
baseline environmental monitoring was carried out. The ambient monitored data
regarding Sulphur dioxide (SO2), Nitrogen Oxides (NOx), Carbon monoxide
(CO), PM and noise levels and water quality are exhibited in ANNEXURES–IX,
X, XI and XII. These data are necessary for any further reference and for its use
by EPA Sindh or the project proponent for a variety of their end uses.

47
5.2.1.1 Ambient Air Quality-Ambient
Details of the status of ambient gaseous pollutants and particulates are
reported hereunder:
5.2.1.1.1 Gaseous
Ambient air quality monitoring was carried out on the project site.
DRAGER, Germany manufactured ambient air quality monitoring
equipment was used. Monitoring was carried out for Sulfur dioxide
(SO2), Nitrogen oxides (NOx, NO and NO2) and Carbon monoxide
(CO). The monitored data are exhibited in the ANNEXURE-IX.
5.2.1.1.2 Particulates
Ambient particulates monitoring was also carried out at the project
site. Iso-Kinetic the Casella System (Instrument) designed to
comply with BS 3405 and ISO-9096 for compliance monitoring of
particulate matter (particulates) was used for the monitoring. The
base line/background data generated on the basis of this
monitoring are shown in the ANNEXURE-X.
5.2.1.1.3 Noise Levels
LEADER Sound Level Meter, Japan was used for noise levels
monitoring. The monitored data are reported in the ANNEXURE-
XI. Noise levels monitoring was done at the project site to have
background environmental data.
5.2.1.1.4 Water Quality
Water samples collected from the project site were tested in
laboratory. The test result of the water samples are reported in the
ANNEXURES-XII.

48
5.3 Gaps in knowledge and uncertainties encountered
No data gap/knowledge or uncertainties were experienced throughout the course
of the preparation of this EIA. The information and documents required were
available with the project proponent.
5.4 Compliance with relevant environmental standards
5.4.1 Effluents-discharges and environmental controls:
About 100 m3
/hr treated sewage water; will be generated. The effluent
after its treatment to the required levels of the applicable NEQs will be
discharged in to main Massu Wah canal which has very vast dilution
capacity of the sewage, thus further reducing the levels of the pollutants in
the already treated sewage.
5.4.2 Noise Levels
The plant has neither any process, nor operations nor the equipment to be
used for the treatment which will produce any noise. Therefore, noise
levels will remain within the prescribed limits of the NEQS ANNEXURE-
III.
Proper repair and maintenance of the equipment/ machinery, timely
replacements of parts of machinery and equipment will be ensured in
order to avoid sound levels during plant operational condition.
5.4.3 Solid wastes:
Night soil will be the semisolid waste. This will be treated to the extent
where its usefulness as organic mineral could be use as fertilizer.

49
5.5 Assessed significance of the impact stating the standards or criteria
used as a basis for judgment
Since no gaseous emissions are resulting from the present project, hence every
segment of the environment and human health are going to be protected.
The project is to run under strict environmental controls in compliance with the
SEPA 1997 and the NEQS Pakistan as legal binding. Under these environmental
control operations, human health and environment will be well guarded. The solid
wastes will be disposed off in the market under a well guarded and tracked
system.
5.6 Possible measures for avoiding or mitigating the impact
While the possible measures for avoiding or mitigating impacts from the project
activity have been described at the respective places in the preceding parts of this
report, yet the following measures are also recommended for adoption to further
ensure environmental protection.
i- “Cleaner Production” and “Good House Keeping” should be adhered to as it
goes a long way to:
- minimize resource inputs thus enforcing rational use of the resources and
their saving,
- reduce wastes generation,
- reduce losses,
- reduce water consumption,
ii- As far as possible economies on the use of water so that the sewage volume is
reduced. This will result in resource conservation and pollution abatement
besides saving the lot of recurring cost to be incurred on the treatment.

50
iii- As far as possible use automatic shut off taps. This will result in resource
conservation and pollution abatement besides saving the lot of recurring cost
to be incurred on the treatment.
iv- Use of water in floor washing should be restricted to reduce the sewage. This
will result in resource conservation and pollution abatement besides saving the
lot of recurring cost to be incurred on the treatment.

6.0 COMPARATIVE EVALUATION OF ALTERNATIVES (SITING) AND
IDENTIFICATION OF THE PREFERRED OPTION

51
6.0 COMPARATIVE EVALUATION OF ALTERNATIVES (SITING) AND
IDENTIFICATION OF THE PREFERRED OPTION
A comparative evaluation of the alternatives and identification of the preferred
options has been given under Serial No 2.6.2.
6.1 Labour
Although for the sewage treatment plant no surplus labour is required because of
its availability with FFCL, yet if required at any time it is easily available in the
project area.
6.2 Basic infrastructure
The project relates to the treatment of sewage from the FFCL staff colony.
Therefore the sewage treatment plant is necessarily to be sited very near to the
colony.
The night soil/sludge from the plant is very rich soil nutrients and organics. This
is a very good part substitute for synthetic fertilizer. In order to transport it from
the plant site to the farmer in the area for its use as fertilizer free of cost, there is a
good infrastructure of roads in the area. This will facilitates convenient and cost
effective transportation of the sludge to it’s endues places.
The project site is sited in the area where the land around is under extensive
agriculture use. Therefore, the sludge to be supplied to the farmers free of cost
will save them a lot of money as point substitute for synthetic fertilizer.
Telephone, telecommunication including telephone, internet and electricity are
available at the door steps of the project site.

52
6.3 Site availability for the plant
Land for the plant is conveniently available at the present site where the plant is
being constructed.
6.4 Environment
The plant, though being constructed near to the residential colony of FFCL staff,
yet the operation of the plant will be carried out with all necessary precautions to
avoid any pollution from the treatment. For this even the wind direction has been
taking care of to avoid drift of the bad smell from the plant to the residential area.
The duly treated sewage will be ultimately used for irrigation within the project
site and left over will be discharged in to main Massu Wah canal. This EIA report
has been prepared to get permission from the EPA Sindh and the Competent
Authority Incharge of the Massu Wah canal for discharging treated sewage into
this canal. Therefore, there is no possibility of any pollution to accrue from the
treated effluent.
6.5 Energy availability:
The electric power required to run the plant is available right at the plant site there
fore this factor also goes in favor of sitting the plant at its present location.

7.0 ENVIRONMENTAL MANAGEMENT PLAN, MONITORING PLAN AND
PROPOSED TRAINING

EIA - SEWAGE WATER TREATMENT PLANT FFC MIRPUR MATHELO

EIA - SEWAGE WATER TREATMENT PLANT FFC MIRPUR MATHELO

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