Final report eia (kmc)

Final Report
June, 2014
ENVIRONMENTAL MANAGEMENT CONSULTANTS
503, Anum Estate, Opp. Duty Free Shop, Main Shahrah-e-Faisal, Karachi.
Phones: 9221-34311466, 34311467, Fax: 9221-34311467.
E-mail: mail@emc.com.pk, nadeem@emc.com.pk
Website: www.emc.com.pk
ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
“Grade Separated Traffic Improvement
Plan from Park Tower Intersection to
A.T. Naqvi Roundabout”
In The Name of Allah, The Most Beneficent, The Most Merciful

Disclaimer:
This report has Attorney – Client Privilege. Environmental Management Consultants has prepared this
report based on the Information provided by Karachi Metropolitan Corporation (KMC) – the Proponent.
The comments, recommendations and conclusion of the study given in the report should be taken as
considered opinion of the Consultant since these are based on the findings of the EIA and the Traffic Study
conducted by a third party whose statistics were used to evaluate the feasibility of the project. This report
is for the sole and specific use of KMC. Any other person who uses any information contained herein will
do so at his/her own risk. This report cannot be used in the court of law for any negotiation or
standardization.
© Environmental Management Consultants 2014

Environmental Impact Assessment (EIA) Study
“Grade Separated Traffic Improvement Plan from Park Tower Intersection to A.T. Naqvi Roundabout”
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Executive Summary
The existing road network of Karachi caters to the movement of vehicular traffic from the Port area/
Central Business District (CBD) to the east and northeast. It only marginally addresses the situation
created by the centrifugal forces comprising the population pressure and economic development
due to which the megapolis has expanded in all directions including the waterfront area of Clifton
and the DHA.
On the other hand the centripetal forces comprising safety, security risk and deficiencies in the
governance system including traffic management have induced reversal in trend inwards to the
environs of the CBD and coastal area. The latter force has been given a boost by the decision of the
Karachi Metropolitan Corporation (KMC) to densify the built environment along the main arteries in
CBD which includes the Clifton area.
The decision to densify the CBD was in response to the growing economy and consumption pattern.
Housing sector and hence the building industry is so far among the best instruments to stimulate the
economy of the countries the world over. The centrifugal force that drove the population resident in
the core areas to areas outside the CBD is now yielding to the centripetal force in that there are
scores of people who are seeking residence in the core areas. Building of high risers in the form of
residential and commercial buildings only temporarily responded to sustain the equilibrium between
the centrifugal and centripetal forces. In realization of the demand to further densify the CBD, the
Karachi Metropolitan Corporation (KMC) allowed construction of building of over 50 meter height. A
number of buildings whose height exceeds 100 metres including Bahria Icon Tower which will have
270 metres height; while at least 84 buildings that have height more than 50m. In Karachi there are at
least 30 skyscrapers which are currently under construction, and planned to rise at least 70 m.
Advantage of this allowance was taken by builders and developers e.g. Dolmen City, Park Tower,
Bahria Icon Tower, COM-3, Riviera 70 who have gone ahead with the construction of residential and
commercial buildings on main arterials and along the 3-9m contour line that runs from Cape Monze
to Gharo.
Clifton area is inhabited by residential developments, shopping centers, schools, consulates and the
sandy beach. Clifton roads provide major access to DHA through the 26th
Commercial Street,
Zamzama Boulevard, Khayaban-e-Hafiz and Sea View Road. The traffic generated from residential
and commercial establishments from within DHA causes congestion on the existing Clifton road
network. However, the existing transport network of Clifton is old, with no new road network
enhancement programs initiated in the recent past. Clifton area has high car ownership ratio as
compared to other parts of the city, with little public transport facilities. The constant increase in traffic
on the existing infrastructure contributes significantly to congestion along many of the street
corridors.
Accordingly all approach roads heading towards low risk areas have assumed tremendous
importance. The traffic movement from the Port and outskirts of CBD are taking low risk routes. It is

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this type of force that has induced and promoted development of residential and commercial centres
on Sharah-e-Firdousi, Shahra-e-Iran, Clifton road, 26th
street, Khayaban-e-Sadi, Khayaban-e-Ghalib,
Khayaban-e-Sahil and other arterials. The result is that the said arterials are bearing the brunt of
heavy congestion which in turn has been on an increase during the past decade.
The environmental assessment process described in this document has evaluated the environmental
impacts of proposed “Grade Separated Traffic Improvement Plan from Park Tower Intersection to A.T.
Naqvi Roundabout.” The proposed Traffic Improvement Plan comprises: i) flyover along 26th
street/shahrahe firdausi, ii) improved traffic management at A.T. Naqvi chowk under the above
flyover, iii) underpasses for entry/exit movements to/from Bahria Town Icon tower and Clifton
funland, iv) interchange between shahrahe Iran and shahrah firdausi near Park Towers intersection
leading to 2-Talwar intersection, v) other at-grade improvements for better traffic management in the
corridor of impact, and vi) provision of a number of grade-separated pedestrian crossings at
important locations.
The project responds to the emerging need of traffic management resulting from continuity of
development activities sought by Karachi Metropolitan Corporation (KMC) in the Clifton area. There
has been continuous increase in the volume of vehicular traffic while the project area is constrained
by capacity of the roads. The activities in the Project area are likely to entail a tremendous increase in
Trip attraction/generation rates for which a master plan must be in hand to forecast the traffic
movement and its handling.
Pakistan Environmental Protection Agency (Review of EIA/IEE) Regulation 2000 define Schedules (I &
II) of projects in terms of requirement of EIA or IEE. As per Schedule I (List of projects requiring an IEE),
Category I (3) Urban Development Projects, the subject Project: “Grade Separated Traffic
Improvement Plan from Park Tower Intersection to A.T. Naqvi Roundabout”, falls in the category of
projects that requires Initial Environmental Examination (IEE). An IEE was duly submitted in fulfilment
of the requirement of the above regulation and it was also approved by the competent authority
(Sindh EPA). Work was started after obtaining the approval and had to be restrained when a petition
was filed against the categorization of project. The petition had taken the plea that this Project came
within paragraph D:2 of Schedule II and hence an EIA was necessary. This reads as follows: “Federal or
Provincial highways or major roads (except maintenance, rebuilding or reconstruction of existing
roads) with total cost of Rs. 50 million and above.” Accordingly the Honorable High Court considered
it necessary to reexamine the status of categorization by conducting an EIA. This report has therefore
reconsidered the status of the project and its severity in terms of negative and positive impact.
Mitigation measures will have to be provided to contain the emissions and other negative impacts
that may arise during the course of construction and subsequent operation.
It may be reiterated that the environmental assessment is concerned with the management/
implementation of the Traffic Improvement Plan. The exceedence of cost over Rs. 50 million will be
the cost that the KMC will have to bear for improvement of quality of life. The main aim of the Traffic
Improvement Plan being facilitation of travel demand in the microenvironment of the recreation area

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at Clifton, the project remains in the category of “urban development projects”. Accordingly the
submission and approval of an IEE is justified. This EIA has reexamined the assessments made earlier,
has taken the stakeholders on board, addressed to their concerns and has found that sustainability of
the project lies in following the mitigation measures in letter and spirit.
The Project responds to the need of the segment of population that is seeking safety, security and
improvement in quality of life. Availability of infrastructure facilities for establishment of residential
cum commercial complexes and their location on low risk area ideally suits the building industry.
The project has responded to the need emerging from creation of High Density Zone and the
consequent necessity to improve the Traffic management in the different zones vide “The Sindh High
Density Development Board Act, 2010”. The High Density Development Board was created under
Section 3 of the Act, while Section 4 of the Act empowered the Board to identify and earmark the
high-density zones in the urban centres of the cities of the Province as per the defined procedure. It is
pertinent to mention here that high density zones were created to respond to the centripetal forces
that had developed during the process of rapid urbanization.
A Traffic Impact Assessment study was initiated as per the recommendations of the Sindh High
Density Development Board that was held on December 22, 2011 under the chairmanship of
Honorable Governer Sindh. The recommendations mandated the proponents of high risers to
develop a traffic management plan taking all the stakeholders on board. The Traffic Impact
Assessment (TIA) study was complete in July 2012; it focussed on mitigation and transport
improvement of the areas adjacent to the main high risers including Bahria Icon. The report primarily
focused on addressing the prevailing traffic & transport situation in the microenvironment and
suggested mitigation measures to address the situation so created.
The screening process has taken cognizance of i) the persistence of environmental degradation on
said intersections resulting from the decision to convert the area into a ‘High-Rise-Zone’ without
conducting Strategic Environmental & Social Assessment (SESA) which is now a mandatory
requirement under Sindh Environmental Protection Act, 2014, ii) rapid development that does not go
hand in hand with sustainability principles, iii) Proceeding from IEE to Environmental Impact
Assessment following Honorable Sindh High Court Order, iv) Traffic Impact Assessment study
conducted by KMC for the Clifton area, v) Increase in the Complexity of the operation of traffic
resulting from high risers and accomodation of the squatter settlements, and the weak geological
structure on which the shrine of Abdullah Shah Ghazi, Mahadev Mandir and Jahangir Kothari Parade
are located, vi) the residual impact after construction and during operation of the traffic on the roads
to see if the project has achieved its objectives, and vii) Guidelines for classification of polluted and
unpolluted sites with respect to their airshed, watershed, soil, sensitivity of ecosystem including fauna,
flora, wildlife, aquatic life, historical, cultural & archaeological sites and their values have been
reviewed.
The current situation is that the excavation work for laying the foundation of the underpass and
flyover has been halfway through. The construction work was underway when there was intervention

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from some of the stakeholders. The construction work had to be stopped as per High Court Orders
leaving the site for underpasses and flyover in unaesthetic condition. The stoppage of work has had
serious impact on the business and commercial activities in the surrounding and also on the project
financers. The stakeholders in the surrounding particularly the management of the Ratneshwar
Mahadev Mandir and Abdullah Shah Ghazi’s shrine have demanded immediate resumption of the
construction activity and its completion before the onset of the monsoons.
The following are the findings of environmental audit which inter alia provides the current status of
the project:
The construction activity which was started in March after the approval of IEE and stopped following
the High Court Orders has significantly slowed down all businesses and has negatively impacted the
business and commercial activities in the shopping areas. The temporary loss of business so incurred
has resulted in grievances from the concerned business operators. The stakeholders were not
opposed to the Traffic Improvement Plan but they sought immediate resumption/completion of the
project.
The shop owners/business operators are particularly concerned about the slow down of business
during the Monsoons and peak season of Ramadan. The apprehensions in this regard were conveyed
to the monitoring team. There is therefore need for implementation of the Traffic Management Plan
that may ensure resumption of business activity. It is recommended that the KMC must maintain an
active liaison with the commercial enterprises.
At the outset it may be stated that the ridge on which the Ratneshwar Mahadev Mandir, Abdullah
Shah Ghazi Mazar and Jahangir Kothari Parade are located is on the triple point where seismic activity
is continuously producing shocks that are below magnitude IV on Richter scale. The ridge falls at the
end of the deltaic synclinorium which is under tectonic pressure from the Indian Plate due to which
there is continuous movement at a rate of 4-6 cm/year. The two historical structures are either on top
of the hill or in the cave. As such they are only weakly grounded. Any subsequent structure
introduced in this scenario will have to take such mitigation measures that can withstand the
geological structure and seismic activity. Such being the case the proponent is following the
recommended mitigation measures which include construction of bored reinforced concrete piles
and following the requirements of seismic zone 2B.
It was observed that the excavation of land did not take cognizance of having a buffer zone between
the sensitive structures and the Corridor. Since a buffer zone is mandatory by law, there is need for
immediate redressal by reversing the damages done and maintaining the mandatory buffer zone
specified by the Law or finding an alternative design which bypasses the sensitive structures and
monuments leaving sufficient space for their protection.
The cumulative impact of construction activity on weak structures has to be taken into consideration
and conservation measures should be provided to strengthen the weak structures in the
neighborhood. Such measures have been recognized for Abdullah Shah Ghazi Mazar which is located

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on top of the hill but has not been extended to the depth of the cave in which Mahadev Mandir is
located. The proponent is committed to adopt conservation measures to protect all the structures
particularly those which are not well grounded for e.g., Mahadev Mandir which is in the cave.
The proponent must give top priority to the recommended conservation measures and formulate a
plan in consultation with the Management of Mahadev Mandir and Jahangir Kothari Parade
(Heritage). What is needed is the consolidation of the weak geological structure of the cave without
disturbing the sanctity and hydrogeology of the microsite.
Safety issues seem to receive low priority at the construction site as was observed by the monitoring
team. Health, Safety and Environment are major components of the Environmental Management Plan
(EMP) of which monitoring of the environmental performance is an integral part. The proponent has
to ensure strict adherence to the measures and guidelines stated in the EMP and the contractor must
be made to follow the Standard Operating Procedures for construction activities.
A traffic diversion plan was prepared but the implementation was weak which resulted in
inconvenience to road users during the construction stage. It was also not shared with the
stakeholders in the neighborhood. This was cause for complaints from road users and also the public
in the neighborhood. It was observed that the traffic diversion plan was still not being followed, for
example the information on closure of the access roads and alternate routes were not shared with the
public particularly the concerned citizens. Following measures are therefore required to be
implemented: i) Maintain the service roads in good condition to allow smooth traffic movement;
provide necessary personnel to guide and control the traffic; ii) Provide alternative traffic
arrangement/detours so that traffic can be distributed and move on different roads; and, ensure that
public/residents association is informed about such traffic diversions, iii) Provide information to the
public through media – daily news papers and local cable television (TV) services about the need and
schedule of work, and alternative routes, iv) To maintain transparency of the project, public
information/caution boards must be provided at the work site information shall inter-alia include:
project name, cost and schedule; executing agency and contractor details; nature and schedule of
work; traffic diversion details, if any; entry restriction information; competent official’s name and
contact information for public complaints.
During the construction phase, impacts mainly arise from generation of dust from soil excavation and
refilling; and from the disturbance of residents, businesses, traffic and important buildings by the
construction work. These are common impacts of construction in urban areas, and there are well
developed methods for their mitigation. Among these, public and worker safety due to large scale
construction using heavy-duty construction equipment, traffic disturbance during construction is
considered to be significant.
Important measures suggested include: i) dust control measures such as water sprinkling and
covering the loose material during transport, ii) proper planning and scheduling of noise generating
activities, iii) maintaining service roads and pedestrian walks in good condition and provision of
personnel to guide traffic, iv) providing alternative traffic routes/detours and informing public about

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the same, v) following standard and safe construction practices (barricading the site properly;
avoiding accidental traffic entry including pedestrians; deployment of safety and security staff;
providing warning/sign boards; provision of protection equipment; special precautions during risky
works like arranging the pre-cast elements and equipment safety checks, etc.)
The proposed infrastructure at the designated sites would not add to degradation. Contrarily it would
help relieve congestion and thus reduce the accumulation of pollutants commonly observed at traffic
intersections. Thus there would be a positive impact of the Project in so far as the overall level of air
and noise pollution in the CoI is concerned.
The likely impact owing to siting the Project in Seismic Zone that is placed between Zone 2 and Zone
3, corresponding to Magnitude between 5.0 and 6.5 on Richter Scale and Intensity between VII and IX
on Modified Mercallis Scale, the Ground Force in terms of Assumed Approximate Acceleration
equivalent of 0.3 g would be adopted.
To offset the impact of liquefaction/subsidence appropriate mitigation measures would be adopted
by construction of bored reinforced concrete piles to the depth of hard rocks with RQD values greater
than 50%. The piles of the piers/columns of the flyovers would be laid at depth of sandstone which
are hard and pose minimum risk to the liquefaction/subsidence threat during major (> 7 on Richter
Scale) earthquake.
Once the construction is over, the Project will function without any major maintenance so no major
impacts envisaged. Operation of the Project will, on adoption of the mitigation measures, have
reduced significance of impact on the physical as well as socioeconomic structure of the
microenvironment and macroenvironment of its corridor of impact (CoI). The impact on the
aesthetics, if any, will be mitigated through careful planning and land/street-scaping in collaboration
with concerned stakeholders.
The proposed Project, when commissioned, would be integrated into the concerned
microenvironment and will become a friendly component of its macroenvironment. The nature of
Project, its siting; adoption of adequate measures to minimize waste and control pollution during
construction as well as operation stages of the project will have residual impact of low significance on
the microenvironment and macroenvironment as well as on precious ecology.
Construction of flyover and underpasses at the proposed sites and operation of vehicular traffic is not
expected to have unacceptable/significant impact on the aesthetics of the microenvironment and
macroenvironment. The impact, if identified, will be mitigated through careful planning, suitable
landscaping and adopting appropriate mitigation measures, besides providing a monitoring and
contingency plan.
Mitigation will be assured by a program of environmental monitoring conducted to ensure that all
measures are provided as intended, and to determine whether the environment is protected as
envisaged. This will include observations on and off site, document checks, and interviews with

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workers and beneficiaries, and any requirements for remedial action will be reported to the EPA
Sindh.
There are two essential recommendations that need to be followed to ensure that the environmental
impacts of the project are successfully mitigated.The Implementing Agency (KMC) shall ensure that:
 All mitigation, compensation and enhancement measures proposed in this EIA report are
implemented in full, as described in the document;
 The Environmental Management and Monitoring Plan is implemented in letter and spirit.
Screening of potential impact suggests that proposed “Grade Separated Traffic Improvement Plan
from Park Tower Intersection to A.T. Naqvi Roundabout” will, on adoption of the suggested
mitigation measures, be an environmentally acceptable proposition.
Furthermore the Project will achieve the prime objectives of sustainable development in facilitating
safe, secure and speedy travel along the main intersection viz. Park Tower and A.T. Naqvi chowk,
besides upgrading and modernizing the infrastructure facilities of the fast growing section by
identifying the bottlenecks and removing the constraints to smooth flow of traffic.

Table of ContentsEnvironmental
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TABLE OF CONTENTS
SECTION 01: INTRODUCTION ..............................................................1 OF 10
1.1 The Project ................................................................................................................................. 1 of 10
1.1.1 Name of the Project .....................................................................................................1 of 10
1.1.2 Location of Project........................................................................................................1 of 10
1.1.3 Brief Description of Project...........................................................................................1 of 10
1.2 Project Proponent ..................................................................................................................... 1 of 10
1.2.1 Contact Person............................................................................................................................................1 of 10
1.3 Objectives of the Project.......................................................................................................... 1 of 10
1.4 Justification of Project ............................................................................................................. 2 of 10
1.5 Project Background .................................................................................................................. 4 of 10
1.6 The EIA Study............................................................................................................................. 6 of 10
1.6.1 Purpose of EIA.............................................................................................................................................6 of 10
1.6.2 Categorization of Project........................................................................................................................7 of 10
1.7 Methodology for Environmental Assessment ...................................................................... 8 of 10
1.7.1 Site Visits .......................................................................................................................................................8 of 10
1.7.2 Literature Review/Baseline.....................................................................................................................8 of 10
1.7.3 Project Specific Data.................................................................................................................................9 of 10
1.7.4 Impact Identification and Assessment ..............................................................................................9 of 10
1.7.5 Mitigation Measures & Environmental Management Plan.......................................................9 of 10
1.7.6 Documentation...........................................................................................................................................9 of 10
1.7.7 Environmental Standards and Guidelines........................................................................................9 of 10
1.8 Structure of EIA Report .......................................................................................................... 10 of 10
1.9 EIA Study Team........................................................................................................................ 10 of 10
SECTION 02: POLICY, STATUTORY & INSTITUTIONAL
FRAMEWORK............................................................................................1 OF 23
2.0 Introduction ............................................................................................................................... 1 of 23
2.1 Policy Framework...................................................................................................................... 1 of 23
2.2 Statutory Framework................................................................................................................ 3 of 23
2.3 Sindh Environmental Protection Act, 2014 ........................................................................... 4 of 23
2.4 Environment & Alternate Energy Department ..................................................................... 6 of 23
2.5 National Environmental Quality Standards......................................................................... 11 of 23
2.6 Pak-EPA Review of IEE and EIA Regulations 2000 ............................................................. 14 of 23

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2.7 Pakistan Environmental Assessment Procedures ............................................................... 15 of 23
2.8 Cutting of Trees Act, 1992 ..................................................................................................... 18 of 23
2.9 Building Control and Town Planning Regulations............................................................. 18 of 23
2.10 Sindh High Density Development Act 2010........................................................................ 19 of 23
2.11 Archaeological Relics.............................................................................................................. 19 of 23
SECTION 03: DESCRIPTION OF THE PROJECT...............................1 OF 23
3.1 Project Background .................................................................................................................. 1 of 23
3.2 The Project ................................................................................................................................. 3 of 23
3.3 Current Situation....................................................................................................................... 4 of 23
3.4 Technical Details of Project ................................................................................................... 13 of 23
3.4.1 Geometric Design ....................................................................................................................................13 of 23
3.4.2 Design Standards.....................................................................................................................................13 of 23
3.4.3 Vertical Alignment...................................................................................................................................13 of 23
3.4.4 Combination of Horizontal and Vertical Alignment .................................................................13 of 23
3.4.5 Bus Stop/Bays............................................................................................................................................14 of 23
3.4.6 Pedestrian Crossings ..............................................................................................................................14 of 23
3.4.7 Drainage ......................................................................................................................................................14 of 23
3.4.8 Appurtenances/Furniture......................................................................................................................14 of 23
3.4.9 Pavement Design.....................................................................................................................................14 of 23
3.4.10 Traffic Capacity of Road in terms of Passenger Car Unit per day.........................................15 of 23
3.4.11 Design Provisions.....................................................................................................................................15 of 23
3.4.12 Design Loadings.......................................................................................................................................15 of 23
3.4.13 Pre-Stressing for Bridge........................................................................................................................17 of 23
3.4.14 Controlling Stress Values......................................................................................................................17 of 23
3.4.15 Ramp Configuration ...............................................................................................................................17 of 23
3.5 Manpower requirements........................................................................................................ 17 of 23
3.6 Amount of material required for construction................................................................... 18 of 23
3.7 Utilities...................................................................................................................................... 18 of 23
SECTION 04: DESCRIPTION OF ENVIRONMENT............................1 OF 60
4.1 General........................................................................................................................................ 1 of 60
4.2 Physical Environment ............................................................................................................... 6 of 60
4.2.1 Meteorology and Climate.......................................................................................................................6 of 60
4.2.2 Temperature ................................................................................................................................................6 of 60
4.2.3 Precipitation.................................................................................................................................................8 of 60
4.2.4 Humidity......................................................................................................................................................10 of 60
4.2.5 Wind Speed & Direction.......................................................................................................................12 of 60

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4.2.6 Ambient Air Quality & Noise ..............................................................................................................13 of 60
4.2.7 Recent Changes in Monsoon Pattern..............................................................................................17 of 60
4.2.8 Terrestrial Environment: Geology Geomorphology & Seismotectonics............................18 of 60
4.2.9 Liquefaction Features Caused by Earthquake ..............................................................................27 of 60
4.2.10 Tsunamis......................................................................................................................................................27 of 60
4.2.11 Storms ..........................................................................................................................................................28 of 60
4.2.12 Hydrology ...................................................................................................................................................28 of 60
4.3 Biological Environment of Karachi City District ................................................................. 33 of 60
4.3.1 Vegetation of Karachi City District....................................................................................................33 of 60
4.3.2 Fauna of Karachi City District ..............................................................................................................35 of 60
4.3.3 Fisheries and Aquatic Ecology............................................................................................................37 of 60
4.3.4 Biodiversity.................................................................................................................................................37 of 60
4.3.5 Fauna, Endangered Species, Protected Areas ..............................................................................38 of 60
4.4 Karachi Transportation System............................................................................................. 38 of 60
4.4.1 Traffic Demand Forecast Studies.......................................................................................................41 of 60
4.4.2 Future Travel Demand ...........................................................................................................................43 of 60
4.5 Degradation of Karachi City Environment by Transportation System .......................... 45 of 60
4.5.1 Air and Noise Quality Deterioration.................................................................................................45 of 60
4.5.2 Noise Pollution from Transportation ...............................................................................................46 of 60
4.5.3 Total Emissions from Different Fuel Usage....................................................................................46 of 60
4.6 Road Network in and around Project Area............................................................................. 47 of 60
4.6.1 Existing Traffic Situation on Major Roads ......................................................................................51 of 60
4.7 Socio-Economic Considerations in Macro environment of Project Area ...................... 57 of 60
4.7.1 Education ....................................................................................................................................................57 of 60
4.7.2 Water Supply .............................................................................................................................................57 of 60
4.7.3 Surface Drainage and Sewerage System........................................................................................58 of 60
4.7.4 Electricity Supply......................................................................................................................................58 of 60
4.7.5 Commercial and Residential Buildings............................................................................................58 of 60
4.7.6 Health ...........................................................................................................................................................59 of 60
4.7.7 Employment...............................................................................................................................................59 of 60
4.7.8 Landscaping...............................................................................................................................................59 of 60
4.7.9 Shrines, Temples & Heritage...............................................................................................................59 of 60
4.7.10 Archaeological Sites................................................................................................................................59 of 60
4.7.11 Economy......................................................................................................................................................60 of 60
4.7.12 Shopping Centres ....................................................................................................................................60 of 60
SECTION 05: STAKEHOLDER CONSULTATION..............................1 OF 17
5.1 Objectives of Stakeholders Consultation .................................................................................. 1 of 17
5.2 Identification of Stakeholders..................................................................................................... 1 of 17
5.3 Consultation Process .................................................................................................................... 2 of 17

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5.4 Proceedings of Consultation Meetings ..................................................................................... 2 of 17
5.4.1 Observations/views expressed by the residents............................................................................2 of 17
5.4.2 Observations/views expressed by business operators ...............................................................3 of 17
5.4.3 Observations/views expressed by Ratneshwar Mahadev Mandir Management............11 of 17
5.4.4 Observations/views expressed by the Stakeholders..................................................................12 of 17
SECTION 06: SCREENING OF POTENTIAL ENVIRONMENTAL
IMPACTS & MITIGATION MEASURES...............................................1 OF 30
6.1 Screening Process...................................................................................................................... 1 of 30
6.2 Checklist for Screening of Likely Impacts.............................................................................. 6 of 30
6.3 Screening of Potential Environmental Impacts at Designing Stage ................................. 8 of 30
6.4 Potential Environmental Impacts due to Siting of Project............................................... 12 of 30
6.5 Screening of Potential Environmental Impacts at Construction Stage .......................... 14 of 30
6.6 Screening of Potential Environmental Impacts at Operation Stage ............................... 25 of 30
6.7 Checklist of Actions Affecting Environment & Significance of Their Impact................ 27 of 30
SECTION 07: ENVIRONMENTAL MANAGEMENT & MONITORING
PLAN (EMMP) ............................................................................................1 OF 12
7.1 Functions and Responsibilities................................................................................................ 1 of 12
7.2 Environmental Management Plan .......................................................................................... 4 of 12
7.3 Environmental Monitoring Plan.............................................................................................. 4 of 12
7.4 Grievance Redress Mechanism................................................................................................ 5 of 12
7.4.1 Framework for Grievance Redress Mechanism..............................................................................5 of 12
7.4.2 Environmental Regulations....................................................................................................................5 of 12
7.4.3 Outline of Mechanism for Grievance Redress................................................................................5 of 12
SECTION 08: CONCLUSION AND RECOMMENDATION .................1 OF 1
APPENDICES
Appendix I : Traffic Impact Assessment (TIA) Study
Appendix II : Sindh Environmental Protection Act 2014

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Section 01: Introduction
1.1 The Project
1.1.1 Name of the Project
Grade Separated Traffic Improvement Plan from Park Tower Intersection to A.T. Naqvi Roundabout.
1.1.2 Location of Project
Land area enclosed by Sharah-e-Firdousi, Shahrah-e-Iran, Clifton road, 26th
street, Khayaban-e-Sadi,
Khayaban-e-Ghalib and Khayaban-e-Sahil as shown in figure 1.1.
1.1.3 Brief Description of Project
The proposed Traffic Improvement Plan comprises: i) Flyover along 26th
Street/Shahrah-e-Firdausi
providing for uninterrupted traffic movements along Shahrah-e-Firdausi from DHA/Khayaban-e-
Ittehad side towards A.T.Naqvi Chowk (Intersecton) and onwards to Bin Qasim Park along with a
direct access to the Bahria Town Icon Tower by means of an exclusive down ramp, ii) Improved traffic
management at A.T. Naqvi Chowk under the above Flyover, iii) Underpasses for entry/exit movements
to/from Bahria Town Icon Tower and Clifton Funland without any interruption to the through
movements on main Shahrah-e-Firdausi, iv) Interchange between Shahrah-e-Iran and Shahrah-e-
Firdausi near Park Towers Intersection leading to 2-Talwar Intersection, v) Other at-grade
improvements for better traffic management in the entire area, and vi) Provision of a number of
grade-separated pedestrian crossings at important locations.
1.2 Project Proponent
The project proponent is Karachi Metropolitan Corporation (KMC).
1.2.1 Contact Person
Director General (Technical)
Karachi Metropolitan Corporation (KMC)
1.3 Objectives of the Project
The main objective of the project is to provide a master plan for management of traffic in the project
area and propose flyover and underpasses wherever necessary to de-congest the traffic taking due
consideration of the centripetal forces that are likely to be dominant in the foreseeable future.
The other objectives include:

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 Facilitating safe, secure and speedy travel along the main intersection viz. Park Tower and A.T.
Naqvi chowk;
 Upgrading and modernizing the infrastructure facilities of the fast growing section by identifying
the bottlenecks and removing the constraints to smooth flow of traffic;
 Reducing traffic noise and air pollution due to idling of vehicles at the signalized intersections.
1.4 Justification of Project
The project responds to the need of traffic management that has emerged consequent upon and
subsequent to the continuous densification of the residential areas and commercialization of major
roads. Clifton area, with relatively much higher car ownership ratio compared with other parts of the
city, and with little public transport facilities on too inadequate infrastructure is facing significant
congestion along many of the street corridors. Of particular concern is the restraint on easy access
from two swords roundabout, Bilawal House and other directions and to Abdullah Shah Ghazi’s
shrine, Bahria Town Icon building, Kothari Parade, Bagh Ibne Qasim and Clifton Funland, and to the
sandy beach.
The Project is justified in view of i) the mismatch between volume of vehicular traffic that has
increased in consonance with densification, and provision of corresponding infrastructure facilities, &
ii) the extra burden on the existing transport infrastructure by the traffic operating on the major
accesses to Karachi and DHA through Clifton.
In view of the need to address the growing transport infrastructure problems of Clifton area a Review
of the Traffic Profile of Clifton Area was carried out in 2012 to assess the issues and propose solutions.
The options considered as solution to the problem included conversion of two-way streets into one-
way and grade separation. The option of making existing two-way streets into one-way was not
recommended, while options for grade separating the existing at-grade intersections were modeled.

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Figure 1.1: Location of Grade Separated Traffic Improvement Plan from Park Tower Intersection to A.T. Naqvi Roundabout

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1.5 Project Background
The City of Karachi has overgrown its capacity to manage and provide good quality of life to its
citizens with the result that its Transport and Communication system remains deficient and far
exceeds vehicle:capacity (v/c ratio). Construction of flyovers, underpasses and interchanges has only
partly addressed the grave concern. The process of continuous review, identification of deficiencies
and suggested maintenance as well as expansion is usually carried out through a master plan.
However such a process has never been successfully carried out. The environmental and social
concerns with respect to operation of traffic on road have therefore remained unsustainable.
The network of arteries and link roads was consequently neither restructured nor reorganized to suit
to the changing demand of users and services. The shortcomings that emerged from ad-hoc
planning in transport management together with the lack of vision to control movement of vehicular
traffic and congestion of roads, have spelled on the pace of growth and also in visible degeneration
of transport sector in and environmental degradation of the roadways of the ever growing
Metropolis.
The existing road network of Karachi caters to the movement of traffic from the Port area/Central
Business District (CBD) to the east. It has however only marginally addressed the situation presented
by the centrifugal forces representing population pressure and economic development which has
expanded in all directions including the Clifton area. On the other hand the centripetal forces
comprising safety, security risk and deficiencies in the governance system including traffic
management have induced reversal in trend inwards to the environs of the Port and CBD. Accordingly
all approach roads heading towards low risk areas have assumed tremendous importance. The traffic
movement from the Port and outskirts of CBD are taking low risk routes. It is this type of force that
has induced and promoted development of residential and commercial centres on Sharah-e-Firdousi,
Shahra-e-Iran, Clifton road, 26th
street, Khayaban-e-Sadi, Khayaban-e-Ghalib, Khayaban-e-Sahil and
other arterials. The result is that the said arterials are bearing the brunt of heavy congestion which in
turn has been on an increase during the past decade.
It may be reiterated that stimulation of the economy of the country lies in the housing sector and
hence in the building industry. Other sectors are not likely to help the economy as much as would the
housing sector. Moreover the centrifugal force that has been driving the population resident in the
core areas is also being followed by the centripetal force in that there are scores of people who are
seeking residence in the core areas. Building of high risers in the form of residential and commercial
buildings responds just to sustain the equilibrium between the centrifugal and centripetal forces.
The Project responds to the need of the segment of population that is seeking safety, security and
improvement in quality of life. Availability of infrastructure facilities for establishment of residential
cum commercial complexes and their location on low risk area ideally suits the building industry.
Advantage of this aspect has already been taken by other builders and developers (e.g. Dolmen City,
Park Tower, Bahria Icon Tower, COM-3, Riviera 70) who have gone ahead with the construction of
residential and commercial ventures these arterials.

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According to a study carried out by CDGK and now KMC, the capacity of roads in Karachi City during
day time had in the year 2007 exceeded by 6 to 29 times; on major corridors. The present position
with regard to traffic on the arterials of concern in the project area namely: Korangi Road –Submarine
Chowk–Schon Circle–Boat Basin–Mai Kolachi–Do Talwar Roundabout–Bilawal House Chowrangi–
Shirin Jinnah Colony–Park Tower–26th
Street–Clifton Seashore Promenadeis that with six fold increase
in traffic volume the capacity of roads has been far exceeded.
There has been an addition of about 800 mini-trucks, 4000 vans and pick up, 30,000 rickshaws, 52,000
private vehicles and 190,000 motorcycles on the already congested roads of Karachi during the year
2011as shown in the Table 1.1. The distance which can be covered within 10 to 15 minutes takes six
times as much, or one hour to one and a half hour during day time. Such traffic conditions have
raised the economic cost of operating vehicular traffic by a factor of 1.5-2.0 for cars and 2.0-2.2 for
buses. That raises the environmental cost as well because with idling running engines there is an
increase in the volume of air pollutants from the vehicles. This critical situation has besides raising the
environmental/social cost turned the traffic volume : road capacity towards non-sustainability. The
emerging situation identifies an urgent need to have a master plan for the areas of concern. Karachi
roads/arterials need to be decongested at all critical traffic intersections to facilitate vehicular
movement at reasonable speed.
Table 1.1: Total Number of Vehicles Registered / On Road in Karachi – 2011
S. No. Type of Vehicle
TotalRegistered
onRoadupto31-
12-2010
Newly Registered During the Year
2011
TotalRegistered
onRoad2011(Col.
4+5+6+7)
TotalRegistered
onRoadupto31-
12-2011(Col.3+*)
January-
March
April-June
July–
September
October-
December
1 Mini Bus 15,452 101 99 65 90 355 15,807
2 Buses 6,458 7 47 13 101 48 6,506
3 Mini Truck 11,876 284 221 138 105 748 12,624
4 Truck 14,759 436 203 59 131 829 15,588
5 Van/Pickup 99,077 2,018 2,239 1,361 1,402 7,020 104,097
6 Taxi 47,170 16 2 1 20 5 47,165
7 Rickshaw 74,334 6,981 6,088 10,102 8,179 31,350 105,684
8 Lifter 2,812 12 17 43 17 89 2,901
9 Tractor 3,364 54 49 40 28 171 3,535
10 Oil Tanker 2,663 76 46 68 23 213 2,876
11 Pvt. Vehicles 946,733 14,073 14,209 12,228 11,677 52,187 998,920
12 Motor Cycles 1,105,232 69,309 45,601 40,090 36,249 191,249 1,296,481
13 Ambulance 1,728 9 34 38 23 104 1,832
14 Coffin Carrier 69 - - - 2 2 71
15 Disable Person 98 1 - - - - 99

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16 Catholic Trust 113 1 - - 1 - 113
17 School Bus 244 1 3 1 1 3 246
18 Church 38 2 2 - 1 3 35
Grand
Total
2,330,220 2,614,580
1.6 The EIA Study
1.6.1 Purpose of EIA
The EIA study provides a review of the environmental conditions and evaluates the current status of
the physical environment and ecology, along with the prevailing socioeconomic conditions. The main
purpose of this EIA study is to ensure that:
 Any major adverse impact on the environment and social conditions during its different stages
viz. pre-construction construction and operations are identified.
 Appropriate and adequate mitigation measures are suggested to minimize the severity of adverse
impacts, and
 Environment Management Plan for sustainable operation of the Project is proposed
The EIA study responds to:
 Orders of the Honorable High Court of Sindh which has taken congnizance of a petition and
issued an order to stop the work forthwith and resubmit an environmental report in the form of
EIA for consideration by Sindh EPA;
 Section 17 of Sindh Environmental Protection Act 2014 which requires that every new
development project in Pakistan has to be preceded by an Initial Environmental Examination (IEE)
or Environmental Impact Assessment (EIA) depending on the nature and severity of impacts
anticipated on commissioning of the project.
 PEPA 1997, requires the Project Proponents to follow the procedures set out in Pakistan
Environmental Protection Agency (Review of IEE and EIA) Regulations 2000.

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Figure 1.2: EIA/IEE Process in Pakistan
1.6 .2 Categorization of Project
Pakistan Environmental Protection Agency (Review of EIA/IEE) Regulation 2000 define Schedules (I &
II) of projects in terms of requirement of EIA or IEE. As per Schedule I (List of projects requiring an IEE),
Category I (3) Urban Development Projects, the subject Project: “Grade Separated Traffic
Improvement Plan from Park Tower Intersection to A.T. Naqvi Roundabout”, falls in the category of
projects that requires Initial Environmental Examination (IEE). An IEE was duly submitted in fulfilment
of the requirement of the above regulation and it was also approved by the competent authority
(Sindh EPA). Work was started after obtaining the approval and had to be restrained when a petition
was filed against the categorization of project. The petition had taken the plea that this Project came

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within paragraph D:2 of Schedule II and hence an EIA was necessary. This reads as follows: “Federal or
Provincial highways or major roads (except maintenance, rebuilding or reconstruction of existing
roads) with total cost of Rs. 50 million and above.” Accordingly the Honorable High Court considered
it necessary to reexamine the status of categorization by conducting an EIA. This report has therefore
reconsidered the status of the project and its severity in terms of negative and positive impact.
Mitigation measures will have to be provided to contain the emissions and other negative impacts
that may arise during the course of construction and subsequent operation.
1.7 Methodology for Environmental Assessment
This study has covered all major areas of concern as per regulatory requirements. Scope of the EIA
study included collection of data from different sources, development of baseline of the current
physical, ecological and social baseline of the area through surveys. In general, the study has been
conducted in accordance with the Pakistan Environmental Protection Agency Review of EIA and IEE
Regulations, 2000 and guidelines provided therein. Following screening of potential environmental
impacts, the requirement for mitigation measures to address the adverse impacts is presented. The
Report includes the Monitoring Program that will be implemented during the construction and
operation phase.
Preparation of this Report has adopted the following methodology:
1.7 .1 Site Visits
EMC’s team visited the project site(s) and its vicinity for conducting site survey to collect primary
baseline data with respect to social and environmental aspects.
1.7.2 Literature Review/Baseline
Available published literature and previous EIAs/IEEs on the subject have been reviewed along with
the legislation relevant to this project in order to compile relevant information with special reference
to the physical features, ongoing social and commercial aspects, and operation of vehicular traffic at
the said intersections.

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1.7 .3 Project Specific Data
Information related to design, construction & operation activities was provided by Karachi
Metropolitan Corporation (KMC).
1.7 .4 Impact Identification and Assessment
The environmental aspects emerging due to different activities during the pre-construction,
construction and operation phases were identified and their impact on the microenvironment and
macroenvironment critically examined.
1.7.5 Mitigation Measures & Environmental Management
Plan
Impact assessment was supplemented by incorporating the mitigation measures required to reduce
the severity of impacts and to manage different activities within the framework of environmental
legislation and management plan. Environmental Management Plan (EMP) has been prepared to
guide KMC through the lifecycle of the project, and to enable maintenance of the environmental,
social and work place conditions and for conforming to the legislations in vogue. The management
plan outlines the details required to manage environmental, safety and occupational risks arising
from the project activities as well as social issues.
1.7 .6 Documentation
Finally, the report has been prepared according to the guidelines of the Pakistan Environmental
Protection Agency. The report includes description of the Project, description of microenvironment
and macroenvironment and screening of potential environmental impact of activities during the pre-
construction, construction and operation phases.
1.7 .7 Environmental Standards and Guidelines
Environmental issues concerning protection and control are governed by Sindh Environmental
Protection Act 2014. Guidelines and procedures for preparing Environmental Assessment reports
have been published by Federal EPA in the form of “Pakistan Environmental Assessment Package”
which includes:
 Legal Requirements in Pakistan for Environmental Assessment for New Projects under the
Environmental Protection Agency Sindh (SEPA)
 Pakistan EPA Guidelines and Procedures (2000) for Environmental Assessment of New Projects
 Pakistan National Environmental Quality Standards (NEQS) gaseous including vehicular exhaust
emissions; noise emissions, and liquid effluents, ambient air and
 Sectoral Guidelines for Environmental Report

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1.8 Structure of EIA Report
The EIA report has been structured on the standard format, prescribed by the Pakistan Environmental
Protection Agency. The Report has been presented in the following sections:
Section 1 – Introduction and brief description of Project and EIA Processes
Section 2 – Overview of National and International Legislation and Guidelines relevant to the
proposed project and to this EIA
Section 3 – Description of Project
Section 4 – Description of Environment
Section 5 – Screening of Potential Environmental Impacts and Mitigation Measures
Section 6 – Environmental Management and Monitoring Plan (EMP)
Section 7 – Conclusions and Recommendations
1.9 EIA Study Team
EMC organized the following team to carry out the study:
Table 1.2: EIA Study Team
S. No. Name Position
1 Syed Nadeem Arif Project Manager
2 Mr. Saquib Ejaz Hussain Environmental Assessment Specialist
3 Dr. Mirza Arshad Ali Beg Senior Environmentalist, Project Team Leader
4 Dr. M. Mansha Air Quality Monitoring (SUPARCO)
5 Ms. Tasneem Bhatti Sociologist
6 Mr. S.M. Zaman Geologist
7 Masood ur Rehman Environmental Engineer

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Section 02: Policy, Statutory & Institutional
Framework
2.0 Introduction
This section describes the current legal responsibilities of the Project proponent in the context of the
environment and sustainable development, and identifies the National as well as Provincial
Institutions that govern one or the other aspect of environmental management of the proposed
Project. Karachi Metropolitan Corporation, the proponent of this project will comprehensively follow
the relevant requirements of policy documents, legislative framework and recommendations
described in national and international guidelines. Mitigation measures that have been proposed in
the light of relevant guidelines will be integrated in the EMP which has been formulated for the better
management of environmental as well as social aspects and residual aspects, if any.
2.1 Policy Framework
The Pakistan National Conservation Strategy (NCS), which was approved by the Federal Cabinet in
March 1992, is the principal policy document for environmental issues in the country. The NCS
signifies 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 to the
proposed project are biodiversity conservation, restoration of rangelands, pollution prevention and
abatement, and the preservation of cultural heritage.
Pakistan is a signatory to the Convention on Biological Diversity, and is thereby obligated to develop
a national strategy for the conservation of biodiversity. The Government of Pakistan constituted a
Biodiversity Working Group, under the auspices of the Ministry of Environment, to develop a
Biodiversity Action Plan for the country, which was completed after an extensive consultative exercise.
The plan, which has been designed to complement the NCS and the proposed provincial
conservation strategies, identifies the causes of biodiversity loss in Pakistan and suggests a series of
proposals for action to conserve biodiversity in the country. The Pakistan Environmental Protection
Council (PEPC) has approved the action plan and steering committees at the federal and provincial
levels have been formed to implement it.
Mid-term Review of NCS: Key Findings
An overview of the key environmental issues facing Pakistan is as follows:
 Per capita water availability in Pakistan has been decreasing at an alarming rate. In 1951, the per
capita availability was 5300 cubic meter which has now decreased to 1105 cubic meter just
touching water scarcity level of 1000 cubic meter.

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 Almost all fresh water resources are severely polluted due to discharge of untreated industrial and
municipal wastes. Pollution of coastal waters due to waste discharges and oil spills coupled with
reduced freshwater flows is resulting in declining fish yields.
 About 55 percent of population has access to a relatively safe drinking water source. Potable
water quality, assessed against WHO standards, fails to meet all the specified criteria, confirming
evidence of extremely high pollutant loads.
 Approximately 35 percent of population has access to adequate sanitation facilities.
 Air pollution is on the rise, especially in urban areas. Recent surveys conducted by Pakistan
Environmental Protection Agency revealed presence of very high levels of suspended particulate
matter (about 6 times higher than the World Health Organization's guidelines). 'Smog' also
seriously affects almost entire Punjab during December and January every year.
 Noise pollution has become a serious issue in major urban centers.
 Of about 54,850 tons of solid waste generated daily in urban areas, less than 60 per cent is
collected. No city in Pakistan has proper waste collection and disposal system for municipal,
hazardous or healthcare wastes.
 The deforestation rate has been estimated at 0.2-0.5 percent per annum. Forest cover, which was
4.8 percent of total land area in 1992, could hardly be increased substantially despite all efforts.
 Degradation and encroachment of natural forests, rangelands and freshwater and marine
ecosystems are resulting in loss of biodiversity. At least four mammal species, including tiger,
swamp deer, lion and Indian one-horned rhinoceros, are known to have become extinct from
Pakistan while at least 10 ecosystems of particular value for the species richness and uniqueness
of their floral and faunal communities are considered to be critically threatened.
 Desertification affects over 43 million hectares of land annually.
 Pakistan is a highly energy in-efficient country. It uses approximately same amount of energy to
generate 1 dollar of GNP as the USA.
The situation just mentioned is the result of a number of constraining factors including high
population growth rate, prevailing poverty, unplanned urban and industrial expansion, insufficient
emphasis on environmental protection in the government policies, lack of public awareness and
education and above all the ailing economy which has caused deficiencies in institutional capacity
and resources for effective environmental management.
The mid-term review of the NCS led the Government of Pakistan (GOP) and United Nations
Development Program (UNDP) to jointly initiate an umbrella support program called the National
Environmental Action Plan-Support Program (NEAP-SP) that was signed in October 2001 and
implemented in 2002. The development objective supported by NEAP-SP is environmental
sustainability and poverty reduction in the context of economic growth. The primary objective of
NEAP is to initiate actions and programs for achieving a state of environment that safeguards public

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health, promotes sustainable livelihood, and enhances the quality of life of the people in Pakistan. The
NEAP identifies four primary areas, (1) Clean air (2) Clean water (3) Management of solid waste (4)
Ecosystem management. The plan also presents five additional areas of concern (i) Management of
fresh water resources (ii) Marine pollution (iii) Toxic and hazardous substances handling and disposal
(iv) Energy conservation and management (v) Compliance with international treaties and protocol.
Studies conducted by GOP and Donor Agencies in Pakistan have identified a number of
environmental concerns with regard to energy, water and air pollution, waste management, irrigated
agriculture, and biodiversity. These studies suggest an overall degradation in the quality and
impoverishment of renewable natural resources such as water, forests, hydrocarbon and other flora as
well as key biological habitats. The GOP, private sector and civil society have, with few exceptions, not
responded positively to meet the challenges from these concerns.
The Mid-Term Development Framework: 2005-2010 (MTDF 2005-10) of the Planning Commission
has been developed in line with the National Environment Action Plan (NEAP) objectives, and focuses
on four core areas i.e., clean air, clean water; solid waste management, and Ecosystem management.
The Plan has been prepared keeping in mind Pakistan’s experience with such initiatives in the last
decade; the current capacity to undertake planning, implementation and oversight and the identified
needs for improvement in such capacity. The MTDF clearly specifies issues in environment which
need to be addressed.
2.2 Statutory Framework
The constitution of Pakistan contains provision for environmental protection and resource
conservation. The constitution mentions environmental pollution and the ecology as a subject in the
concurrent legislative list, meaning that both the provincial and federal government may initiate and
make legislation for the purpose. Article 9 of the Constitution defines the right to life as a
“fundamental right” in these words “No person shall be deprived of life or liberty save in accordance
with law”. The Supreme Court of Pakistan in its judgment in the case Shehla Zia and others vs WAPDA
(1994) declared that the right to a clean environment is part of the fundamental constitutional right to
life.
Several laws exist for the protection of the environment. Some of these laws are Federal and the rest
Provincial in character. The promulgation of the Environmental Protection Ordinance 1983 was the
first codifying legislation on the issue of environmental protection. This was indeed a consolidated
enactment to plug the gaps and remove defects/deficiencies in the legislation. The promulgation of
this ordinance was followed, in 1984, by the establishment of the Pakistan Environmental Protection
Agency, the primary government institution dealing with environmental issues. Significant work on
developing environmental policy was carried out in the late 1980s, which culminated in the drafting
of the Pakistan National Conservation Strategy. Provincial environmental protection agencies were
also established at about the same time. The National Environmental Quality Standards were
established in 1993.

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Prior to the 18th
Amendment to the Constitution of Pakistan in 2010, the legislative powers were
distributed between the federal and provincial governments through two ‘lists’ attached to the
Constitution as Schedules. The Federal list covered the subjects over which the federal government
had exclusive legislative power, while the ‘Concurrent List’ contained subjects regarding which both
the federal and provincial governments could enact laws. The subject of ‘environmental pollution and
ecology’ was included in the Concurrent List and hence allowed both the national and provincial
governments to enact laws on the subject.
However, as a result of the 18th
Amendment this subject is now in the exclusive domain of the
provincial government. The main consequences of this change are as follows: i) The Ministry of
Environment at the federal level has been abolished. Its functions related to the national
environmental management haves been transferred to the provinces. The international obligations in
the context of environment will be managed by various ministries and departments of the federal
government, ii) The Pakistan Environmental Protection Act 1997 (PEPA 1997) is technically no longer
applicable to the provinces. The provinces are required to enact their own legislation for
environmental protection.
2.3 Sindh Environmental Protection Act, 2014
Legislative assembly of Sindh province of Pakistan passed the bill on 24th
February 2014 to enact
Sindh Environmental Protection Act 2014. The Act envisages protection, improvement, conservation
and rehabilitation of environment of Sindh with the help of legal action against polluters and green
awakening of communities.
It equally lays emphasis for the preservation of the natural resources of Sindh and to adopt ways and
means for restoring the balance in its eco-system by avoiding all types of environmental hazards.
E n v i ro n m e n t a l Pro t e c t i o n C o u n c i l ( E P C ) : It has been formed consisting of
Chief Minister as Chairman with Minister in charge of Environment Protection Department, Addl.
Chief Secretary, Planning & Development Department, Government of Sindh and Secretaries of
Environment, Finance, Public Health Engineering, Irrigation, Health, Agriculture, Local Government,
Industries, Livestock & Fisheries Forest & Wildlife, Energy, Education Departments Government of
Sindh and Divisional Commissioners of Sindh. Non-official members are also included (i.e.
representatives of Chamber of Commerce & Industry and from medical or legal professions etc.)
along with DG, EPA & two Members of Provincial Assembly also form part of EPC.
The functions and powers of EPC include coordination & supervision of provisions of Act, approving
provincial environmental & sustainable development policies & SEQS, provide guidance for
protection & conservation, consider annual Sindh Environmental Report, deal with interprovincial and
federal provincial issues, provide guidance for bio safety and assist Federal Government in
implementation of various provisions of UN Convention on laws on Seas (UNCLOS).
S i n d h E n v i ro n m e n t a l P ro t e c t i o n A g e n c y ( S E PA ) : SEPA would be headed by
Director General (DG) with the aim to exercise the powers and perform the functions assigned to it

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under the provisions of this Act and the rules and regulations made there under. The Agency shall
have technical and legal staff and may form advisory committees.
The Agency shall administer and implement the provisions of this Act and rules and regulations. It
shall also prepare environmental policies, take measures for implementation of environmental
policies, prepare Sindh Environment Report and prepare or revise Sindh Environmental Quality
Standards. SEPA shall also establish systems and procedures for surveys, surveillance, monitoring,
measurement, examination, investigation research, inspection and audit to prevent and control
pollution and to estimate the costs of cleaning up pollution and rehabilitating the environment and
sustainable development. SEPA would also take measures for protection of environment such as to
promote research; issues licenses for dealing with hazardous substances, certify laboratories, identify
need for or initiate legislation, specify safeguards etc. SEPA would also encourage public awareness
and education regarding environmental issues.
SEPA would have powers to enter or inspect under a search warrant issued by Environmental
Protection Tribunal or a Court search at any time, any land or building etc. where there are reasonable
grounds to believe that an offence under this Act has been or is being or likely to be committed.
SEPA may also take samples, arrange for testing or confiscate any article in discharge of their duties.
This act has also provided for Sindh Sustainable Fund derived from various sources such as voluntary
contributions or fees generated etc. This fund is utilized for protection, conservation or improvement
of environment. It is appendices in this EIA report.
S a l i e n t F e a t u re s
S e c t i o n - 11 : No person shall discharge or emit or allow the discharge or emission of any effluent
waste, pollutant, noise or adverse environmental effects in an amount, concentration or level which is
in excess to that specified in Sindh Environmental Quality Standards.
S e c t i o n - 1 2 & 1 3 : No person shall import hazardous waste into Sindh province and handle
hazardous substances except under licenses etc.
S e c t i o n 1 4 : No person shall undertake any action which adversely affects environment or which
lead to pollute or impairment of or damage to biodiversity, ecosystem, aesthetics or any damage to
environment etc.
S e c t i o n 1 5 : This section deals with regulation of motor vehicles banning emission of air or noise
pollutants being emitted from them in excess of allowable standards.
S e c t i o n 1 7 : This section states that no proponent of a project shall commence construction or
operation unless he has filed with the Agency an initial environmental examination or environmental
impact assessment and has obtained from Agency approval in respect thereof. SEPA shall review the
IEE & EIA and accord approval subject to such terms and conditions as it may prescribe or require.
The agency shall communicate within four (04) months its approval or otherwise from the date EIA is
filed failing which the EIA shall deemed to have been approved.

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S e c t i o n 2 1 : Where agency is satisfied that the discharge or emission has occurred in violation of
any provision of this act or rules etc. then it may, after giving an opportunity to person responsible, by
order direct such person to take such measures within specified period. The agency under this
section has been empowered to immediately stop, prevent or minimize emission, disposal etc. for
remedying adverse environmental effects.
S e c t i o n 2 2 : The person who fails to comply with section 11, 17, 18 and 21 shall be punishable
with a fine which may extend to five million rupees, to the damage caused to environment and in the
case of a continuing contravention or failure, with an additional fine which may extend to one
hundred thousand rupees for every day during which such contravention or failure continues. And,
where a person convicted under sub-sections 1 & 2 had been previously convicted for any
contravention of this Act, the Environmental Protection Tribunal (EPT) may, in addition to punishment,
award imprisonment for a term that may extend up to three years, or order confiscation or closure of
facility etc.
S e c t i o n 2 3 : Where any violation of this Act has been committed by any of employee of any
corporate body, then, that employee shall be considered to be guilty of environmental pollution.
S e c t i o n 2 5 : This section allows for establishment of Environmental Protection Tribunals.
2.4 Environment & Alternate Energy Department
Environment and Alternate Energy Department is functioning as a department of the Government of
Sindh since 2002. Sindh EPA operates under this department. It is a monitoring and regulating agency
with the following main functions:
 Enforcement of PEPA 1997
 Enforcement of NEQS
 Implementation of Self-Monitoring and Reporting Tool (SMART)
 Review of EIAs and IEEs
 Providing advice to the government on issues related to environment
 Coordination of pollution prevention and abatement measures between government and non-
governmental organizations
 Assistance to provincial and local governments in implementation of schemes for proper disposal
of wastes to ensure compliance with NEQS
 Undertake measures to enhance awareness on environment among general public
 Conduct research and studies on different environmental issues
 Attend to public complaints on environmental issues.
 Carry out any other task related to environment assigned by the government.

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Sindh EPA will be responsible for the review and approval of the EIA of Traffic Improvement Plan.
The IEE of the Traffic Improvement Plan has already been approved by Sindh EPA.

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2.5 National Environmental Quality Standards
One of the functions of the Pak EPA under the provision of PEPO of 1983 was to issue NEQS for
municipal and liquid industrial effluent, industrial gaseous emissions and motor vehicle exhaust and
noise. The Pak EPA issued a statutory regulatory order (S.R.O) in 1994. It required all units coming into
production after 1st July 1994 to comply immediately with the new standards. Those already in
production at the time of S.R.O were required to comply starting 1st
July 1996. The Pak EPA was not
able to implement the NEQS effectively for many reasons, including lack of implementation capacity
and resistance from industry.
With the PEPA, 1997 the Pak EPA revised the NEQS with full consultation of the private sector,
industrialist, trade and business associations and NGOs. The municipal and liquid industrial effluent
standards cover 32 parameters. The standards for industrial gaseous emissions specify limits for 16
parameters, and the standards for motor vehicles prescribe maximum permissible limits for smoke,
carbon monoxide and noise. Revised standards cover discharges limits of effluents into inland water,
sewage treatment plant and the sea. The NEQS are primarily concentration based. Unfortunately, the
limits on industrial effluents are neither industry specific nor do they have any relationship with the
quantum of production. The NEQS prohibit dilution, but this can be easily circumvented.
KMC is committed to comply with the applicable NEQS in letter and spirit.
The chronological list of NEQS is shown in Table 2.1.
Table 2.1: National Environmental Quality Standards
Date Number Scope
1993 742(I)/1993 Liquid Industrial Effluent
Industrial Gaseous Emission
Vehicle Exhaust and Noise
1995 1023(I)/1995 Industrial Gaseous Emission from Power Plants operating on coal and
oil (added)
2000 549(I)/2000 Liquid Industrial Effluent (amended)
Industrial Gaseous Emission (amended)
2010 1062(I)/2010 Ambient Air
2010 1063(I)/2010 Drinking Water Quality
2010 1062(I)/2010 Noise
Table 2.2 shows national environmental quality standard for ambient air.
Table 2.2: National Environmental Quality Standard for Ambient Air
Pollutant Time-
weighted
average
Concentration in Ambient Air Method of measurement
Effective from
1st
Jan 2009
Effective from
1st
Jan 2012
Sulfur Dioxide
(SO2)
Annual
Average*
80μg/m3
80μgm3
Ultraviolet Fluorescence Method
24 hours** 120μg/m3
120μgm3
Oxides of Nitrogen
as (NO)
Annual
Average*
40μg/m3
40μgm3
Gas Phase Chemiluminescence

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Table 2.2: National Environmental Quality Standard for Ambient Air
24 hours** 40μgm3
40μgm3
Oxides of Nitrogen
as (NO2)
Annual
Average*
40μgm3
40μgm3
Gas Phase Chemiluminescence
24 hours** 80μgm3
80μgm3
O3 1 hour 180μgm3
130μgm3
Non dispersive UV absorption
method
Suspended
Particulate Matter
(SPM)
Annual
Average*
400μgm3
360μgm3
High volume Sampling, (Average flow
rate not less than 1.1m3
/minute)
24 hours** 550μgm3
500μgm3
Respirable
Particulate Matter
(PM10)
Annual
Average*
200μgm3
120μgm3
Β Ray absorption method
24 hours** 250μgm3
150μgm3
Respirable
Particulate Matter
(PM2.5)
Annual
Average*
25μgm3
15μgm3
Β Ray absorption method
24 hours** 40μgm3
35μgm3
1 hour 25μgm3
15μgm3
Lead (Pb) Annual
Average*
1.5μgm3
1μgm3
ASS Method after sampling using
EPM 2000 or equivalent Filter paper
24 hours** 2μgm3
1.5μgm3
Carbon Monoxide
(CO)
8hours** 5mg/m3
5mg/m3
Non Dispersive Infra Red (NDIR)
method1hours 10mg/m3
10mg/m3
*Annual arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform
interval.
**24 hourly / 8 hourly values should be met 98% of the in a year. 2% of the time, it may exceed but not on two
consecutive days.
Table 2.3 shows the standards for motor vehicle noise.
Table 2.3: The Motor Vehicle Ordinance (1965) and Roles (1969)
Parameter Standards (maximum permissible limit) Measuring method
Noise 85dB(A) Sound-meter at 7.5meter from the source
Table 2.4 shows the proposed national environmental quality standard for noise.
Table 2.4: Proposed National Environmental Quality Standard for Noise
S. No. Category of Area / Zone Effective from 1st
January, 2009 Effective from 1st
January, 2010
Limit it in dB(A) Leq*
Day Time Night Time Day Time Night Time
1 Residential area (A) 65 50 55 45
2 Commercial area (B) 70 60 65 55
3 Industrial area (C) 80 75 75 65
4 Silence Zone (D) 55 45 50 45
Note: 1 Day time hours: 6.00 a. m to 10.00 p. m
2 Night time hours: 10.00 p. m to 6.00p. m
3 Silence zone; Zone which are declared as such by competent authority. An area comprising not less
than 100 meters around hospitals, educational institutions and courts.
4 Mixed categories of areas may be declared as one of the four above-mentioned categories by the

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Table 2.4: Proposed National Environmental Quality Standard for Noise
competent authority.
*dB(A)Leq Time weighted average of the level of sound in decibels on scale A which is relatable to human
hearing.
The NEQS for effluents are shown in Table 2.5.
Table 2.5: National Environmental Quality Standard for Municipal & Liquid Industrial Effluents
S. # Parameter Into Inland
Waters
Into Sewage Treatment Into Sea unit
1 Temperature or Temp. increase <3 <3 <3 o
C
2 pH value (H+
) 6-9 6-9 6-9
3 Biological Oxygen Demand (BOD)5 at 20o
C 80 250 80 mg/l
4 Chemical Oxygen Demand (COD) 150 400 400 mg/l
5 Total Suspended Solids (TSS) 200 400 200 mg/l
6 Total Dissolved Solids (TDS) 3500 3500 3500 mg/l
7 Oil and Grease 10 10 10 mg/l
8 Phenolic Compounds (as Phenol) 0.1 0.3 0.3 mg/l
9 Chloride (as Cl-
) 1000 1000 SC mg/l
10 Fluoride (as F-
) 10 10 10 mg/l
11 Cyanide (as CN-
)total 1.0 1.0 1.0 mg/l
12 An-ionic detergents (as MBAS) 20 20 20 mg/l
13 Sulphate(SO4
2-
) 600 1000 SC mg/l
14 Sulphide (S2-
) 1.0 1.0 1.0 mg/l
15 Ammonia (NH3) 40 40 40 mg/l
16 Pesticides 0.15 0.15 0.15 mg/l
17 Cadmium 0.1 0.1 0.1 mg/l
18 Chromium (trivalent and hexavalent) 1.0 1.0 1.0 mg/l
19 Copper 1.0 1.0 1.0 mg/l
20 Lead 0.5 0.5 0.5 mg/l
21 Mercury 0.01 0.01 0.01 mg/l
22 Selenium 0.5 0.5 0.5 mg/l
23 Nickel 1.0 1.0 1.0 mg/l
24 Silver 1.0 1.0 1.0 mg/l
25 Total toxic metals 2.0 2.0 2.0 mg/l
26 Zinc 5.0 5.0 5.0 mg/l
27 Arsenic 1.0 1.0 1.0 mg/l
28 Barium 1.5 1.5 1.5 mg/l
29 Iron 8.0 8.0 8.0 mg/l
30 Manganese 1.5 1.5 1.5 mg/l
31 Boron 6.0 6.0 6.0 mg/l
32 Chlorine 1.0 1.0 1.0 mg/l

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2.6 Pak-EPA Review of IEE and EIA Regulations
2000
The Pakistan Environmental Protection Agency Review of Initial Environmental Examination and
Environmental Impact Assessment Regulations, 2000 (IEE-EIA Regulations, 2000) provide the
necessary details on the preparation, submission, and review of the IEE and the EIA. The regulation
categorizes projects on the basis of anticipated degree of environmental impact.
The Regulations define Schedules (I & II) of projects falling under the requirement of EIA or IEE. This
IEE Study has, for environmental classification of the Project into Category A or B, taken account of
the requirements of the Pakistan Environmental Protection Agency (Review of EIA/IEE) Regulations
2000 which define Schedules (I & II) as follows:
Category A: Projects are categorized A if they generate significant adverse environmental impacts
that require a comprehensive management plan, or if the project is located within or passes through:
a) Areas declared by the Government of Pakistan as environmentally sensitive (National
Parks/Sanctuaries/Game Reserve), b) Areas of international significance (e.g. protected wetland as
designated by the RAMSAR Convention), or c) Areas designated by the United Nations Educational,
Scientific, and Cultural Organization (UNESCO) as cultural heritage sites.
Category B: A project falls in category ‘B’ if it is likely to have adverse environmental impacts, but of
lesser degree or significance than those for category ‘A’ and all the mitigation measures to handle the
impact is manageable. Such types of projects need IEE report including EMP.
As per Schedule I (List of projects requiring an IEE), Category I (3) Urban Development Projects, the
subject Project: “Grade Separated Traffic Improvement Plan from Park Tower Intersection to A.T.
Naqvi Roundabout”, falls in the category of projects that requires Initial Environmental Examination
(IEE). An IEE was duly submitted in fulfilment of the requirement of the above regulation and it was
also approved by the competent authority (Sindh EPA). Work was started after obtaining the approval
and had to be restrained when a petition was filed against the categorization of project. The petition
had taken the plea that this Project came within paragraph D:2 of Schedule II and hence an EIA was
necessary. This reads as follows: “Federal or Provincial highways or major roads (except maintenance,
rebuilding or reconstruction of existing roads) with total cost of Rs. 50 million and above.”
Accordingly the Honorable High Court considered it necessary to reexamine the status of
categorization by conducting an EIA. This report has therefore reconsidered the status of the project
and its severity in terms of negative and positive impact. Mitigation measures will have to be
provided to contain the emissions and other negative impacts that may arise during the course of
construction and subsequent operation.

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2.7 Pakistan Environmental Assessment Procedures
The Federal EPA has prepared a set of guidelines for conducting environmental and social
assessments. The guidelines derive from much of the existing work done by international donor
agencies and NGOs. The package of regulations, of which the environmental and social guidelines
form a part, includes the PEPA 1997 and the NEQS. These guidelines are listed below followed by
comments on their relevance to proposed project:
 Policy and Procedures for Filing, Review and Approval of Environmental Assessments, Pakistan
Environmental Protection Agency, September 1997: These guidelines define the policy context
and the administrative procedures that govern the environmental assessment process from the
project pre-feasibility stage to the approval of the environmental report. The section on
administrative procedures has been superseded by the IEE-EIA Regulations, 2000.
 Guidelines for the Preparation and Review of Environmental Reports, Pakistan Environmental
Protection Agency, 1997: The guidelines on the preparation and review of environmental reports
target project proponents and specify:
o The nature of the information to be included in environmental reports
o The minimum qualifications of the EIA conductors appointed
o The need to incorporate suitable mitigation measures at every stage of project
implementation
o The need to specify monitoring procedures.
 The terms of reference for the reports are to be prepared by the project proponents themselves.
The report must contain baseline data on the Study Area, detailed assessment thereof, and
mitigation measures.
 Guidelines for Public Consultation, Pakistan Environmental Protection Agency, May, 1997: These
guidelines support the two guidelines mentioned above. They 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 the incorporation of their concerns in any
impact assessment study.
 Sectoral Guidelines for Environmental Reports: Major Roads: This Sectoral Guideline is part of
package of regulations and Guidelines that also includes the National Environmental Quality
Standards. The Guidelines are concerned with construction of major roads and highways as well
as rehabilitation of major routes. Minor works such as maintenance, repair and improvement of

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Consultants
existing roads and the construction of small lengths of new roads of limited capacity are not
included within the scope of this Guideline.
The EIA report submission and approval procedure is summarized below:
1. Ten hardcopies of the EIA and two soft copies will be submitted together with a review fee and
form included as Schedule IV of the IEE-EIA Regulations.
2. The EPA will conduct a preliminary scrutiny and reply within 10 days of the submittal of the report
a) confirming completeness, or b) asking for additional information, if needed, or c) returning the
report requiring additional studies, if necessary.
3. If accepted, the EPA will set a date for public hearing and publish a notice in the print media.
According the law, a minimum of 30 day notice is required for the public hearing.
4. The EPA will review the EIA taking into account the any public comments received during the
hearing or otherwise.
5. The EPA is required to make every effort to complete the EIA review process within 90 days of the
issue of confirmation of completeness.
6. The approval granted at the end of the review process, is valid for three years to start
construction.
7. Once the project construction is complete, the proponent is required to submit a request to EPA
for confirmation of compliance. An environmental management plan for the operation phase is
to accompany the request.
8. The EPA is required to communicate its decision within 15 days of receipt of the request. The
project can commence operation only after it has received approval from the EPA.

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