EIA EXECUTIVE SUMMARY

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Executive Summary i of vii
Environmental Impact Assessment of Exploration Activities in Sujawal Block-Sindh 2014
EXECUTIVE SUMMARY
Mari Petroleum Company Ltd (MPCL) was granted exploration license for the Sujawal Block
(EL-2467-11) Sindh in June 2006 with 100% working interest. In order to carryout Exploration &
Production activities, MPCL conducted an IEE study in August 2007 for a proposed area and
was granted NOC/approval from SEPA in November 2007. Subsequently, MPCL carried out
Seismic data acquisition in the year 2008.
Now, MPCL intends to further amplify the exploration activities including 2D/3D seismic
survey and drilling activities at Sujawal Block (EL-2467-11), after fulfilling the associated
environmental regulations. MPCL has contracted SGS Pakistan (Private) Limited (SGS) to carry
out environmental assessment of the proposed activities in order to assess the environmental
viability of the same. This report has been prepared in accordance with the requirements set-
forth in Sindh Environmental Protection Act 2014 (SEPA), the Pakistan Environmental
Protection Agency (Review of IEE ad EIA) Regulations, 2000 and the guidelines provided in the
Pakistan Environmental Assessment Procedures, 1997. Section-17 of SEPA 2014 which 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 the agency approval in this respect thereof”.
The Pakistan Environmental Protection Agency (Review of EIA/IEE) Regulations 2000 clearly
defines the categories of projects requiring an Initial Environmental Examination (IEE) or
Environmental Impact Assessment (EIA) referred to in Schedules I & II respectively. According
to Schedule II, Category I (Environmentally Sensitive Areas), defines that the projects situated
in environmentally sensitive area require an EIA. The EIA study has been carried out in
consideration of:
• Major concerns on the microenvironment in which the project is proposed to be sited;
• Construction and operational phase impacts being confined to and localized into the
microenvironment;
• Sujawal block encompasses number of wildlife protected and reserve forest areas including
Mirpursakro (Game Reserve), Cut Munarki Wildlife Sanctuary, Bijora Chach Wildlife
Sanctuary, Gullel Kohri Wildlife Sanctuary, Munarki Wildlife Sanctuary and Sadnani
Wildlife Sanctuary and most of the protected areas are located along Indus River including
Reserve forests.
Mari Petroleum Company Limited is one of Pakistan’s largest E&P companies operating the
country’s 2nd largest gas reservoir at Mari Field, District Ghotki, Sindh. The Company is
primarily engaged in exploration, development and production of hydrocarbon potentials
(Natural gas, Crude oil, Condensate & LPG) in the country. MPCL is also exploring
opportunities of expanding its business to become a significant player in the International
hydrocarbon Market. At present, in addition to Mari Gas Field, MPCL operates nine exploration
blocks (Ziarat, Hanna, Harnai, Sukkur, Sujawal, Karak, Ghauri, Peshawar East and Khetwaro)

Executive Summary ii of vii
and one D&P Lease (Zarghun South). The Company is also a non-operating joint venture
partner in six exploration blocks (Kohlu, Kalchas, Kohat, Bannu West, Zindan and Hala).
Moreover, the Company is also joint venture partner in block 43B with 25% working interest in
Oman with MOL.
MPCL is planning to conduct further exploration work including seismic (2D/3D) and drilling
activities in Sujawal Block. The Block is located in district Thatta and Sujawal of Sindh, having a
total area of about 2,416.43 square kilometres (km2), whereas, reserve forest areas of the block
comprises of about approximately 570.23 km2. MPCL is planning to acquire 2D seismic data in
approximately 320 Line km (L. Km) and 900 sq. km for 3D data, followed by drilling activity. It
is envisaged that one well will be drilled on the basis of seismic survey data, most probably at
eastern part of the block.
The project duration for construction and operation for drilling well is expected to take 5-6
months. The drilling schedule for well operation is expected to be as under:
Seismic Activities: 24 weeks
Construction Work: 12-16 weeks
Mobilization: 3-4 weeks
Drilling and Testing: 12-16 weeks
Demobilization: 2-3 weeks
The project shall require approximately 1700 gallons of water per day and 2,500 litres of fuel per
day during construction phase and seismic activities respectively and approximately 50,000 to
60,000 gallons of water per day & 8,000-12,000 litres of fuel per day during Operation/Drilling
Phase.
The project area falls in the district Thatta and Sujawal of Sindh province. The district is
bounded in the north by Dadu district, in the south by Runn of Katch area, in the east by
Hyderabad and Badin Districts and in the West by Karachi Division. Total area of both districts
is 17,355 km2 and comprises of 9 talukas, out of which six are coastal and three are non coastal
talukas; and 53 Union Councils. District Sujawal consists of Taluka Mirpur Bathoro, Shah
Bander, Kharochan, Jati and Sujawal, while, District Thatta consists of Taluka Mirpur Sakhro,
Ghorabari, Keti Bandar and Thatta. Among these talukas, EIA study area spreads over in
Mirpur Sakhro, Mirpur Bathoro, Jati Sujawal, Thatta and Ghorabari. Talukas of the districts.
The macro-environment of the project area i.e. district Thatta and Sujawal have varied features
in its physical aspects, which range from coastal swamps to fresh water marshes and lakes and
from river islands to coastal deltas. The current terrain of the districts consists of the Makli Hills
in the vicinity of Thatta town. These hills are 32 km in length and are well known on account of
the ancient tombs which are located here. The north western part of the district consists of hilly
tracts known as Kohistan. Between Sir and Khori Creeks lie the great Sirganda salt deposits

Executive Summary iii of vii
The Lower Indus Platform Basin is bounded to the north by the Central Indus Basin, to the
northwest by the Sulaiman Foldbelt Basin and the Kirthar Fold Belt Basin in the south west.
The climate of the Thatta, Sujawal district is moderate. The mean maximum and minimum
temperature recorded about 40°C and 25°C respectively. The sea breeze blows for eight months
of the year, from March to October, making the hot weather comparatively cool. January is
recorded as the coldest month of the year. The annual average rainfall of the district is recorded
as approximately 200 mm.
Besides Indus, the district Thatta/ Sujawal has numerous water courses which drain from the
hills and are known as Nais. The important Nais is the district is Gagar and Ranpathani. There
are many lakes in the district. The famous are Kalri and Haleji. Kalri is a picturesque lake,
situated about 19 Km south of Thatta. It was formed by joining of two lakes Kinjhar and
Sonehri, and takes its present name from the main canal Kair-Bagha feeder, from which it is
currently fed. This lake acts as a great reservoir for feeding canals of Thatta sub-division. In
project area natural and manmade wetlands exist in which rain or flood and irrigated waste
water is stored. These wetlands are commonly called Dhands. Wetlands have mechanism to
provide shelter to different animals, reptiles, fish and bird’s species & preservation of bio-
diversity. Ground water is available in the project area for domestic and drinking purposes.
Main source of recharging groundwater is Indus River while, ground water table in project area
varies from 20 ft to 60 ft.
The air quality in the area is generally good, with negligible sources of pollution like emissions
from vehicular traffic that causes smoke and dust emissions with localized effect. Elevated noise
is viably absent in project proximities due to absence of noise causing equipments in the project
corridors.
The block has been occupied by agricultural settlements comprising of sugarcane, cotton,
wheat, tomato banana plantations & seasonal vegetables. The macro-environment along the
north east and north west part of the project area is occupied, mainly by agricultural fields and
human settlements. The agricultural lands are spread over both sides of the road leading to
major and minor settlements in the area.
The project area is located in the eastern and western side of the Indus River, where there is a
number of Reserve Forests. The one major forest type that falls within the study area is Riverine
forest along the banks of the Indus. Major species of the Riverine forest are Babul or Kiker
(Acacia nilotica), Kandi (Prosopis cineraria) Bahun ( Prosopis euphartica) and Lai (Tamarix
Spp.). Acacia nilotica is the most common species in the project area, while Prosopis Spp. is also
fast growing in the project area.
The common and widespread species of birds includes: Common Myna, Bank Myna, Common
Kite, House Crow, House Sparrow, White-cheeked Bulbul, Ring Dove and Little Brown Dove.
During our field visit 18 mammals, 41 birds and 14 reptiles’ species were reported/observed
within the project area. A small number of migrant species of birds was also recorded in the
area. About 08 species of migratory birds were observed in the project area which is, Common

Executive Summary iv of vii
Kestrel, Common Sandpiper, Pale Crag Martin, Common Swallow, Common Chiffchaff, Black
Redstart, White Wagtail and Yellow Wagtail.
According to the census of 1998 the population of Thatta district was recorded at 1.113 million.
The population of project area distributed among urban and rural areas. According to 1998
Cenus report, 11 percent population is characterized as urban and remaining 89 percent is rural.
Current population (2014) of the both the districts is estimated to be 1.6 million. The estimated
population density is 92 person sq. km. The recent (2013-14) literacy rate for both the districts is
36 percent, among them 48 percent are males and 23 percent are females.
People of different castes dwell in the project area. It includes Shora, Khaskheli, Panhwar,
Khuwaja, Baloch, Chandia, Alwani, Otha, Awan, Lashari, Kalmati, Jokhia, Dul, Sayyed, Jat,
Samo, Mallah, Mirbahar, Soho, Rind, Khalifa, Lothya, Halayo, Burfat, Memon, Shaikh, Nahiyo,
Zangiani, Gaho, Sheedi, Palari and Solangi. Majority are Muslims and Sindhi speaking; while a
few are non- Muslims specially scheduled castes of Hindus.
The western boundary of Sajawal block falls inside the declared protected area i.e. Marho
Kotri Wilde life Sanctuary.
The proposed study has been carried out to take into an account likely positive and negative
impacts of exploration activities on the physical, biological and social environment. The
assessment was primarily focused on the impact of activities due to construction at camp site,
well site seismic and drilling operation on the physical, biological and social environment. The
major areas covered in the impact analysis include wastewater, solid waste, biodiversity, water
resources and socioeconomic factors as well as occupational health safety.
A detailed assessment of the environmental issues due to each impact has been carried out.
After assessment of potential impacts, if the predicted impact is classified as significant, suitable
mitigation measures will be suggested to reduce the consequences or likelihood of occurrence
of that particular impact. There is a range of mitigation measures that will be applied during the
different phases of proposed project which can reduce adverse environmental, biological and
social impacts.
Potential impacts of the project are identified by utilizing different means and ways including
desktop screening exercise, using checklist during field visit for collection of baseline data,
professional judgment, published literature on environmental impact of similar projects and
environmental guidelines. It is identified the project activities may involve the clearing of land
for campsite and access track which can cause dust emissions, erosion of land, and generation
of construction waste, noise and damage to the surrounding structures. This may be avoided by
proper management and planned as suggested in Environmental Management Plan. The
seismic and drilling activities generate waste and noise which may affect the water resources,
soil, air biodiversity and the local community settled in the vicinity of the project. Therefore it is
suggested that work may be avoided or kept to minimum at night to avoid community and
wildlife disturbances with reference to noise. To keep the disturbance level at minimum it is
advised to maintain a fair distance from community and water bodies as much as possible.

Executive Summary v of vii
The effect of vegetation clearing and loss of habitat is less significant for development activities
because campsite will be constructed at existing cleared land wherever possible, dense patches
of vegetation will not be removed and new tracks will be avoided as much as possible. Loss of
vegetation will be observed mainly for the development of access track. However, mitigation
measures recommended will ensure that the impacts are kept to the minimum possible.
Improper waste management practices will favour waste accumulation in nearby environment
and may deteriorate aesthetical and environmental conditions of the project site and requires
serious consideration. Surface water quality may deteriorate if pollutants are mixed with
surface runoff during rain and carried to water resources in the vicinity.
The sources of emissions during construction and drilling will not be significantly enough to
alter the ambient air quality. The existing air quality in the area is generally good, with very few
sources of pollution and dust emissions with localised impact.
Emissions in the form of oxides of carbon, nitrogen and sulphur will be produced during
flaring. Flaring is a much better environmental option than venting. As the flare will be kept
downwind of the well site and at least 300 m away from any community no impacts on
communities or workers will occur.
Vehicular movement is not a continuous activity which could cause continuous impacts on
wildlife and local community. As the project facilities will maintain appropriate distances from
human settlements, disturbance to local community due to dust, noise and accident because of
vehicular movement will be insignificant.
The impacts on community due to proposed project are negligible as compared to the potential
improvement of social status of the community as a result of generation of new employment
opportunities. There will be positive impact on sanitation, transportation, communication and
community health due to development in the project area.
Failure to maintain the appropriate project activity distance from the local communities may
possibly create disturbance due to noise, dust, vehicular movement, and improper disposal of
waste generated due to project activities. Access track passing close to the settlement may also
result in disturbance to the locals. Moreover, sharing of local resources may be the point of
conflict between project proponent i.e. MPCL, and local community. All these impacts due to
seismic, construction and drilling activities would be of variable significance that would be
minimized through MPCL Cooperate Social Responsibility (CRS) Policy and through applicable
laws and regulation.
Mitigation measures have been proposed to minimize the environmental & social impacts.
MPCL shall watch over all activities and shall adopt mitigation measures so that the activities
are performed in an environmentally sound manner.
In addition to the impact assessment and mitigation measures suggested, the implementation of
environmental Management Plan (EMP) will be sufficient to mitigate potential environmental
impacts therefore, an EMP has been produced and compiled for the assistance of MPCL which

Executive Summary vi of vii
shall supervise and monitor all the mitigation measures and their effectiveness. The overall
responsibility for compliance with the environmental guidelines and mitigation measures will
rest with MPCL. The contractor will have liabilities under the environmental laws and under
the contract with MPCL to follow the EMP and environmental guidelines.
Based on the environmental baseline and assessment of potential impacts, it has been concluded
that if the activities are undertaken as per suggested mitigation measures and Environmental
Management & Monitoring Plan is effectively implemented, the project activity will not cause
any significant impact on the natural environment, wildlife and local community of the Sujawal
Block.

Executive Summary vii of vii
Figure ES-I: Location Map of Sujawal Block along

Chapter 02 1 of 4
TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
1. INTRODUCTION 1
1.1. Preamble 1
1.2. The Sujawal Block 1
1.3. Project Title 1
1.4. Project Proponent 1
1.5. Project Overview 2
1.6. Environmental Consultant 2
1.7. EIA Requirement 3
1.8. Project Categorization 3
1.9. Organization of the Report 4
1.10. Contact Details 5
2. SCOPE AND METHODOLOGY 1
2.1 EIA Process 1
2.1.1 Overview of EIA 1
2.1.2 Objective of EIA 1
2.1.3 Scope of EIA 1
2.2 EIA Methodology 2
2.2.1 Understanding of the Proposed Project 2
2.2.2 Legislative Review 2
2.2.3 Secondary Resources/ Baseline Review 2
2.2.4 Scoping Sessions 2
2.2.5 Approval for Field Visit 3
2.2.6 Site Visit and Primary Data Collection 3
2.2.7 Evaluation of Alternatives 3
2.2.8 Identification, Screening and Assessment of Impacts 3

Chapter 02 2 of 4
2.2.9 Impacts Assessment and Mitigation Measures 4
2.2.10 Environmental Management Plan 4
2.2.11 Reporting/Documentation 4
3. LEGAL FRAMEWORK 1
3.1 Constitutional Provision 1
3.2 Framework of Environment and Wildlife Institution in Pakistan 1
3.3 National Environmental Policies 2
3.3.1 National Environmental Policy, 2005 2
3.3.2 National Conservation Strategy 3
3.3.3 National Environmental Action Plan-Support Programme (NEAP-SP) 3
3.3.4 Policy & Procedures for the Filing, Review and Approval of Environmental Assessments 3
3.3.5 Petroleum Exploration & Production Policy 2012 3
3.4 National Environmental Legislation 4
3.4.1 Sindh Environmental Protection Act 2014 5
3.4.2 Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2000 6
3.4.3 The National Environmental Quality Standards (NEQS) 6
3.4.4 Self-Monitoring & Reporting Rules 6
3.5 The Forest Act 1927 6
3.6 Sindh Wildlife Protection Ordinance, 1972 (SWPO) and Amendments 2001 7
3.7 Sindh Fisheries Ordinance, 1980 7
3.8 Petroleum Act 1934 8
3.9 The Mines Act 1923 8
3.10 Regulation of Mines and Oil Fields and Mineral Development (Government Control)
Act, 1948 9
3.11 Exploration and Production Rules, 1986 9
3.12 The Oil and Gas (Safety in Drilling and Production) Regulations, 1974 9
3.13 Antiquities Act 1975 and the Sindh Cultural Heritage (Preservation) Act, 1994 9
3.14 Land Acquisition Act, 1894 10
3.15 Pakistan Penal Code (1860) 10

Chapter 02 3 of 4
3.16 Explosive Substances Act 1908 10
3.17 Explosives Act 1884 11
3.18 National Environmental Guidelines 11
3.18.1 The Pakistan Environmental Assessment Procedures, 199 11
3.18.2 Guidelines for Operational Safety, Health and Environmental Management, December 199612
3.18.3 Guidelines for Public Consultation 12
3.18.4 Sectoral Guidelines for Environmental Reports Oil & Gas Exploration and Production 12
3.19 International Guidelines 12
3.19.1 World Bank Guidelines on Environment 12
3.19.2 IFC Performance Standards 13
3.19.3 IFC Environmental, Health & Safety Guidelines 13
3.20 International Conventions & Treaties 14
3.20.1 International Convention on Biodiversity 14
3.20.2 The Convention on Conservation of Migratory Species of Wild Animals, 1979 14
3.20.3 The Convention on Wetlands of International Importance, Ramsar 1971 14
3.20.4 Convention on International Trade in Endangered Species of Wild Fauna and Flora (Cites) 15
3.20.5 International Union for Conservation of Nature and Natural Resources (IUCN) Red List 15
3.21 International and National Environment and Conservation Organization 16
3.22 MPCL Corporate Requirements 16
4 PROJECT DESCRIPTION 1
4.1 Introduction 1
4.2 Project Need 1
4.3 Project Objective 2
4.4 Project Area 2
4.5 Proposed Project 2
4.6 Seismic Operations 3
4.7 Methodology for Seismic Survey 3
4.7.1 Camp Site Selection and Access Track 4
4.7.2 Camp Establishment and Mobilization 4

Chapter 02 4 of 4
4.7.3 Land Permitting: 4
4.7.4 Line Survey and Preparation: 4
4.7.5 Data Acquisition: 7
4.7.6 Restoration and Rehabilitation: 9
4.7.7 Accommodation and Suites: 10
4.8 Drilling Operation 10
4.8.1 Sujawal block EL Construction Phase 10
4.8.2 Civil Work Activities 10
4.9 Well Drilling Operation Phase 12
4.9.1 Rig Mobilization 12
4.9.2 Drilling Operation 12
4.9.3 Drilling Mud 13
4.9.4 Disposal of Drilling Wastes 16
4.9.5 Well Completion 16
4.9.6 Well Evaluation and Testing 16
4.9.7 Well Control and Blow Out Prevention 16
4.9.8 Accommodation and Supplies: 17
4.10 Decommissioning/ Restoration Phase 17
4.10.1 Demobilization 17
4.10.2 Restoration 17
4.11 Project Schedule 18
4.12 Resource Usage and Requirement 18
4.12.1 Recruitment 18
4.12.2 Water Requirement 19
4.12.3 Electricity Requirement 19
4.12.4 Fuel Requirements 19
4.12.5 Vehicle Requirements 19
4.13 Waste Generation and Disposal 20
4.13.1 Solid Waste 20

Chapter 02 5 of 4
4.13.2 Wastewater 20
4.13.3 Drill Cutting and Mud Waste 20
4.14 Fire and Emergency Preparedness Plan 21
4.15 Health, Safety and Environmental Management 21
5 PROJECT ALTERNATIVES 1
5.1 Project Alternatives 1
5.1.1 No Project Option 1
5.1.2 Drilling Technologies 1
5.1.3 Drilling Mud System 4
6. ENVIRONEMNTAL AND SOCIAL BASELINE 1
6.1. Physical Environment 1
6.1.1. Geography 1
6.1.2. Topography 2
6.1.3. Geology 3
6.1.4. Climatology and Meteorology 6
6.1.5 Water Resources 12
6.1.6. Air Quality 15
6.1.7. Noise 15
6.2. Vulnerability to Natural Disaster/ Cyclones and Floods 19
6.3. Biological Environment 23
6.3.1 Methodology 23
6.3.2 Ecology of Microenvironment of Project Area 23
6.3.3 Protected Areas 26
6.3.4 Flora 26
6.3.5 Fauna 33
6.4. Socio-Economic Environment 45
6.4.1 Data Collection Strategy 45
6.5. Description of the Project Area 45
6.6. Socio-Cultural Aspects 46

Chapter 02 6 of 4
6.6.1 Demography/Community Structure 47
6.6.2 Ethnicity/Tribes 47
6.6.3 Energy Supplies 47
6.6.4 Infrastructure 47
6.6.5 Transportation & Communication 48
6.7. Community Wellbeing 48
6.7.1 Livelihood 49
6.7.2 Agriculture & Livestock 49
6.7.3 Fishing 49
6.7.4 Other Occupations: 50
6.7.5 Health 50
6.7.6 Education 51
6.7.7 Water 52
6.8. Women Status & Gender Equity 52
6.9. Local Community Institutions 52
6.10. Archeological Sites 53
7. STAKEHOLDER CONSULTATION 1
7.1 Objective of Stakeholder Consultation 1
7.2 Identification of Stakeholders 2
7.3 Classification of Stakeholders 2
7.4 Methodology for Stakeholder Consultation 4
7.5 Consultation with Communities 5
7.5.1 Community Issues and Expectations 7
7.6 Consultation with other Stakeholder 7
7.6.1 Chief Conservator Sindh Forest Department 8
7.6.2 Director Sindh Fisheries Department 8
7.6.3 Conservator Sindh Wildlife Department 9
7.6.4 Sindh Environmental Protection Agency 9
7.6.5 Assistant Commissioner (AC) Sujawal 10

Chapter 02 7 of 4
7.6.6 Municipal Committee Thatta, District Thatta 10
7.6.7 Technical Advisor -WWF Pakistan 11
7.6.8 Health Department 11
7.6.9 Education Department 12
7.6.10 Social Welfare Department 13
7.6.11 Archaeology Department 13
7.6.12 National Rural Support Program 13
7.6.13 Coastal Community Development Department 13
7.6.14 SAFWCO 14
7.6.15 Care Takers of Pir Patho Dargah 14
8 IMPACT PREDICTION, EVALUATION AND MITIGATION MEASURES 1
8.1 Identification of Potential Impacts 1
8.2 Impact Assessment Criteria 2
8.3 Impact Assessment Methodology 2
8.4 Impacts Assessment for Design Phase 6
8.4.1 Project Designing 6
8.5 Impacts Assessment for Seismic and Drilling Phase 6
8.6 Impacts on Physical Environment 7
8.6.1 Topography & Soil 7
8.6.2 Water Resources 10
8.6.3 Ambient Air Quality 13
8.6.4 Noise Pollution and Vibration 15
8.6.5 Waste Generation 16
8.6.6 Vehicular Movement 20
8.7 Impacts on Biological Environment 22
8.7.1 Vegetation 22
8.7.2 Wildlife and Habitats 24
8.8 Socio Economic Impacts 27
8.8.1 Land Acquisition and Compensation 28

Chapter 02 8 of 4
8.8.2 Community Disturbance 28
8.8.3 Restricted Mobility 29
8.8.4 Community Grievances/Complaints 29
8.8.5 Archeological, Cultural and Religious Sites 30
8.8.6 Community Safety 30
8.8.7 Safety of Workers 31
8.8.8 Emergencies and Accidents 31
8.8.9 Employment 32
8.8.10 Local Economy 32
9 ENVIRONMENTAL MANAGEMENT PLAN 1
9.1 Introduction 1
9.2 Scope of the EMP 1
9.3 Purpose and Objectives of the EMP 1
9.4 Methodology 2
9.5 Components of the EMP 2
9.6 Legislation and Guidelines 3
9.7 Organizational Structure and Responsibilities 3
9.7.1 Project Proponent 3
9.7.2 Contractors 4
9.7.3 Regulators 4
9.7.4 Independent Monitoring Consultant (IMC) 4
9.8 Implementation Stages of EMP 4
9.8.1 Planning and Design Stage 4
9.8.2 Operational Stage 5
9.9 Change Management Plan 7
9.9.1 Changes to the EMP 8
9.9.2 Changes to the Operation 8
9.10 Waste Management Plan 9
9.11 Environmental Monitoring Plan 9

Chapter 02 9 of 4
9.12 Impacts Mitigation Plan 10
10 CONCLUSION 1
11 REFERENCE 1
ANNEXURES
Annexure I MPCL IMS Policy and Vision Mission Statement
Annexure II Sindh EPA Act 2014
Annexure III Pakistan Environmental Protection Agency (Review of IEE and EIA Regulation 2000)
Annexure IV National Environmental Quality Standard (NEQS)
Annexure V MPCL Waste Management Plan
Annexure VI MPCL Restoration Plan
Annexure VII Socio Economic Matrix

Chapter 02 10 of 4
LIST OF TABLES
Table 1.1. Project Study Team
Table 3.1 Relevant Environmental Laws and their Applicability
Table 4.1 Geological Co-Ordinates of Seismic Lines
Table 4.2: Project Schedule
Table 4.3 Workforce Required for Proposed Seismic & Drilling Activity
Table 4.4 Water Requirements during Project Activities
Table 4.5 Electricity Requirements for Camp & Rig Sites During Operations
Table 4.6 Fuel Requirements during Proposed Activities
Table 4.7 Vehicle Requirements during Proposed Activities
Table 7.1 List of Stakeholders
Table 7.2 List of Consulted Villages
Table 6.1 Soil Analysis Results
Table 6.2 Annual Rainfall Data
Table 6.3 Monthly Minimum Temperature Data
Table 6.4 Monthly Maximum Temperature
Table 6.5 Mean Monthly Wind Speed Data
Table 6.6 Mean Monthly Relative Humidity
Table 6.7 Summary of the Water Analysis Results
Table 6.8 Ambient Air Quality Monitoring Results
Table 6.9 Noise Level Monitoring Results

Chapter 02 11 of 4
Table 6.10 Major Disaster History
Table 6.11 List of Wettest Cyclones/ Depressions in the Coastal Areas of Pakistan
Table 6.12 Cover Area Of Protected/ Reserve Area Of Project Area
Table 6.13 List of Floral Species of Project Area
Table 6.14 The List of Mammal Species
Table 6.15 List of Bird Species
Table 6.16 List of Reptiles
Table 6.17 List of Fish and Shrimps
Table 6.18 List of Heath Facility in Project Area
Table 6.19 List of Education Facility
Table 7.1 List of Stakeholders
Table 7.2 List of Villages Visited for Consultation
Table 8.1 Definitions for Consequence and Likelihood of Impacts
Table 8.2 Impact Significant Matrix
Table 8.3 Impact Assessment Criteria
Table 8.4 Impact Assessment Matrix
Table 9.1 Minimum Distance from Environmental Receptors
Table 9.2 Suggested Environmental Training
Table 9.3 Environmental Monitoring Plan
Table 9.4 Impact Mitigation Plan For Seismic, Construction And Drilling Phase

Chapter 02 12 of 4
LIST OF FIGURES
Figure 1.1 Location Map of Sujawal Block along
Figure 1.2 Proposed Seismic Survey
Figure 4.1 Pakistan Primary Energy Mix
Figure 4.2 Location of Seismic Lines within Sujawal EL Block
Figure 4.3 Shot Hole Drilling Operation
Figure 4.4 A Pictorial View of Geophones and Lying of Cables
Figure 4.5 Vibroseis Truck in Operation
Figure 4.6 Typical Drilling Site Layout (not to scale)
Figure 4.7 Pictorial View of Rotary Drilling Rig
Figure 4.8 Schematic Diagram of Mud Recycling System
Figure 6.1 Graphical Summary of Annual Rainfall Data of Last Six Year
Figure 6.2 Graphical Summary of Mean Annual Minimum & Maximum Temperature.
Figure 6.3 Graphical Summary of Mean Annual Wind Speed.
Figure 6.4 Graphical Summary of Mean Annual Relative Humidity.
Figure 6.5 Environmental Monitoring Location Map
Figure 6.6A to 66 E Forest Maps Provided by Sindh Forest Department
Figure 6.7 Biological Survey Map
Figure 6.8 Social Survey Map

Chapter 01 1 of 7
1. INTRODUCTION
1.1. PREAMBLE
This report presents the findings of an Environmental Impact Assessment (EIA) for the
Exploration Activities in Sujawal (2467-11) located in Sindh Province. The project proponent,
Mari Petroleum Company Limited (hereinafter referred as MPCL) has appointed SGS to
undertake this EIA.
The Mari Petroleum Company Ltd was granted exploration license for the Sujawal Block (EL-
2467-11) Sindh in June 2006 with 100% working interest. In order to carryout Exploration &
Production activities, MPCL conducted EIA study in August 2007 for a proposed area and was
granted NOC/approval from SEPA in November 2007. Subsequently, MPCL carried out Seismic
data acquisition in the year 2008.
MPCL intends to carry out further Exploration activities which include 2D/3D Seismic, drilling
and associated activities in the remaining part of the Block after fulfilling environmental
regulations.
1.2. THE SUJAWAL BLOCK
Sujawal Block lies in the South Western part of Sindh Province covering an area of 2416.43 sq.
km and fall in Sujawal and Thatta districts of Sindh province Pakistan (Figure-1.1).
1.3. PROJECT TITLE
This study is titled as “Environmental Impact Assessment of Exploration Activities in Sujawal
Block-Sindh”.
1.4. PROJECT PROPONENT
Mari Petroleum Company Limited is one of Pakistan’s largest E&P companies operating the
country’s 2nd largest gas reservoir at Mari Field, District Ghotki, Sindh. The Company is
primarily engaged in Exploration, development and Production of hydrocarbon potentials
(Natural gas, Crude oil, Condensate & LPG) in the country. MPCL is also exploring
opportunities of expanding its business to become a player in the International hydrocarbon
market.
Starting with just the production and sale of natural gas from a single field, the Company has
expanded its scope of business over the years. It now offers full spectrum exploration,
production and sale of oil, gas and other petroleum products in various concession areas, a feat
which required a change of name reflecting the extended scope of business.
Mari Gas Company Limited was incorporated in mid 80's by Fauji Foundation, Govt. of
Pakistan and Oil & Gas Development Corporation (now Oil & Gas Development Company
Limited) to take over the assets, liabilities and operation of Fauji Foundation (Mari Gas) and

Chapter 01 2 of 7
Pak Stanvac Petroleum Project. The Company commenced business in its own name in
December 1984.
The Company was renamed Mari Petroleum Company Limited in November 2012. At present,
in addition to Mari Gas Field, MPCL operates nine exploration blocks (Ziarat, Hanna, Harnai,
Sukkur, Sujawal, Karak, Ghauri, Peshawar East and Khetwaro) and one D&P Lease (Zarghun
South). The Company is also a non-operating joint venture partner in six exploration blocks
(Kohlu, Kalchas, Kohat, Bannu West, Zindan and Hala). Moreover, the Company is also joint
venture partner in block 43B with 25% working interest in Oman with MOL.
Mari Petroleum Company Limited (MPCL) has made a gas/ condensate discovery at Sujawal X-
1 in the Sujawal Block located in Sindh Province. This success of the Sujawal X-1 is an addition
to the indigenous reserve base of the nation, which would ultimately result in saving of foreign
exchange. The first exploratory well in the block was spud-in on February 6, 2010 and was
drilled down to a depth of 3,000 meters in Lower Goru Formation of Cretaceous age. MPCL
IMS policy and vision mission statement given in Annexure 1.
Success Ratio of MPCL as Compared to Other E&P Companies
Name of Company
No. of Exploratory
Wells Drilled
No. of
Discoveries
Success Ratio (%)
MPCL 13 9 1: 1.44 (69.23%)
*Other E&P
Companies
757 228 1: 3.3 (30.1%)
*Source: Pakistan Energy Yearbook 2010 (Ministry of P & NR - HDIP)
1.5. PROJECT OVERVIEW
MPCL is planning to perform further exploration work in Sujawal block which includes both
seismic (2D/3D) and drilling activities (hereinafter referred as exploration activities). The Block
lies in Thatta & Sujawal districts of Sindh having a total area of about 2416.43 km2 whereas
reserves forest area of the block comprises of about approximately 570.23 km2. MPCL is
planning to acquire 2D seismic data in approximately 320L. Km and about 900 Sq. for 3D
followed by drilling of a deep well.
The EIA report covers approximately 320 Line Km (L. Km) of 2D and about 900 Sq. Km 3D
seismic operation and a drilling of deep well in Eastern part of the block. Location and vicinity
map of Sujawal block along with district boundaries is attached as Figure 1.1 while Figure 1.2
shows proposed seismic activities to be undertaken.
1.6. ENVIRONMENTAL CONSULTANT
MPCL has appointed SGS to carry out the Environmental Impact Assessment (EIA) study of the
proposed project activities in order to assess the environmental aspects of the project. SGS put

Chapter 01 3 of 7
together a team of consultants to complete the EIA project. The EIA project team comprises of
Ecologist, Environmentalist, Wildlife Expert, Environmental Chemist, Sociologist and Impact
Assessment Experts having diversified experience on local and international assignments. The
project team involved in this study are presented in Table 1.1.
Table 1.1: EIA Study Team
S. No. Name Responsibility in EIA Team
1. Ms. Tasneem Ilyas Project Director
2. Mr. Syed Faseeh Project Manager
3. Mr. Rafi ul Haq Lead Consultant-Senior Ecologist
4. Mr. Athar Khan Project Coordinator
5. Mr. Abdul Rehman Technical Report Writer
6. Dr. Ali Ghalib Wildlife Expert
7. Miss Fiza Qureshi Sociologist
8. Mr. Mumtaz Hassan Water Pollution Expert
9. Mr. Fahad Saleem Subject Expert/Technical Report Writer
10. Mr. Aamir Aziz Environmentalist/Technical Report Writer
11. Mr. Sajid Nazir Field Monitoring Team Leader
1.7. EIA REQUIREMENT
Sujawal block encompass number of wildlife protected areas including Mirpursakro (Game
Reserve), Cut Munarki Wildlife Sanctuary, Bijora Chach Wildlife Sanctuary, Gullel Kohri
Wildlife Sanctuary, Munarki Wildlife Sanctuary and Sadnani Wildlife Sanctuary and most of
the protected areas are located along Indus River including Reserve forests.
The EIA has been prepared to conform to the requirements of the Sindh Environmental
Protection Act 2014 (SEPA), the Pakistan Environmental Protection Agency (Review of IEE ad
EIA) Regulations, 2000 and the guidelines provided in the Pakistan Environmental Assessment
Procedures, 1997.
Section-17 of SEPA 2014 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 the agency approval in this respect thereof.
1.8. PROJECT CATEGORIZATION
The Pakistan Environmental Protection Agency (Review of EIA/IEE) Regulations 2000 evidently
define the categories of projects requiring an Initial Environmental Examination (IEE) or
Environmental Impact Assessment (EIA) in Schedules I & II respectively. As per IEE / EIA

Chapter 01 4 of 7
Regulations, 2000, all projects located in environmentally sensitive or critical areas- including
Wildlife Sanctuaries, National Parks or Game Reserves- require an EIA.
Therefore an EIA study has been conducted for proposed project activities and the report will
be submitted to Sindh EPA for review and approval.
1.9. ORGANIZATION OF THE REPORT
This report has been structured in the following manner:
Executive Summary provides a synopsis of the EIA study.
Chapter 1 (Introduction) gives an overview of the project.
Chapter 2 (EIA Process and Methodology) gives an overview of the EIA process and
methodology.
Chapter 3 (Legal Framework) gives an overview of applicable national policies, and legislations
with international guidelines relevant to EIA of proposed project.
Chapter 4 (Project Description) provides the description of the proposed project, its layout plan
and associated activities, raw material details and utility requirement and project alternatives.
Chapter 5 (Project Alternatives) provides a discussion of the different alternatives considered
for the project.
Chapter 6 (Description of Baseline Environment) provides a description of the micro-
environment and macro-environment of the proposed project site. This chapter describes the
physical, ecological and socioeconomic resources of project area and surroundings.
Chapter 7 (Stakeholder Consultation) provide the details of stakeholder consultation
methodology and its findings.
Chapter 8 (Impact Assessment and Mitigation Measures) describes the potential
environmental and social impacts of proposed project on the different features of the micro and
macro-environment.
Chapter 9 (Environmental Management Plan) explains the mitigation measures proposed for
the project in order to minimize the impacts to acceptable limits. It also describes
implementation of mitigation measures on ground and monitoring of environmental
parameters against likely environmental impacts.
Chapter 10 (Conclusion) presents conclusion of EIA study.
Chapter 11 (References) provides references for the secondary data source.
The last Chapter is followed by series of Annexes that provide supporting information.

Chapter 01 5 of 7
1.10.CONTACT DETAILS
Client Consultant
Mari Petroleum Company Limited SGS Pakistan (Private) Limited.
Mr. Syed Faseeh
Manager-Operation & Business Development
21, Mauve Area, 3rd Road, G-10/4, H-3/3, Sector 5, Korangi Industrial Area
Islamabad, Pakistan Karachi, Pakistan.
Tel: +92 51-111-410-410 Tel: +92-21-35121388-95
Fax: +92 51-2352859 Fax: +92-21-35121329

Chapter 01 6 of 7
Figure 1.1: Location Map of Sujawal Block

Chapter 01 7 of 7
Figure 1.2: Proposed Seismic Survey Location

Chapter 02 1 of 4
2. SCOPE AND METHODOLOGY
2.1. EIA PROCESS
2.1.1 OVERVIEW OF EIA
EIA is a systematic process to identify, predict and evaluate the environmental impacts of
proposed actions and projects. This study suggests mitigation measures with practical approach
of implementation of these measures in the form Environmental Management Plan (EMP). The
process is applied prior to major decisions and commitments being made. Wherever
appropriate, environmental, social and safety impacts are also considered as an integral part of
EIA. Particular attention is given to practical implementation of EIA to prevent and mitigate
significant adverse effects of proposed undertakings.
2.1.2 OBJECTIVE OF EIA
The overall objective of this EIA study includes:
• To explicate the anticipated impacts of proposed intervention;
• Identification of potential environmental impacts;
• Screening of potential impacts to identify significant environmental impacts;
• Evaluation of significant environmental impacts;
• To find out environmentally viable project alternatives;
• To propose appropriate mitigation measures. Discussing appropriate mitigating methods;
2.1.3 SCOPE OF EIA
The scope of EIA is to examine the impacts that will possibly arise from the proposed
exploration activities which include seismic survey and drilling of deep well. This EIA covers
only this segment of the exploration programme and any further activities planned by MPCL
would be the question of separate EIA. This comprehensive EIA study would be carried out in
accordance with the requirements mentioned in the EPA Guidelines and includes:
• Assessment of physical, biological and socio-economic impacts of different stages of
proposed project activities.
• Contemplation of adverse environmental and socio-economic impacts, if any and
suggesting adequate mitigation measures.
• Development of Environmental Management Plan (EMP) which will provide practical
approach in order to manage adverse environmental and socioeconomic impacts, if any.

Chapter 02 2 of 4
2.2. EIA METHODOLOGY
The EIA project undergoes a series of stages prior to report preparation. The process and
approach followed for the proposed project is defined in the subsequence:
2.2.1 UNDERSTANDING OF THE PROPOSED PROJECT
This step requires collection of information from the proponent on the proposed project,
understanding of the project flow and identification of potential impacts associated with the
proposed activities. A sufficient amount of information regarding the proposed project and its
related activities was collected from MPCL.
2.2.2 LEGISLATIVE REVIEW
SGS team carried out the legislative review of applicable laws, regulations, guidelines and
standards which includes national legislation, international agreements, and environmental
guidelines. In addition, best industry practices were recommended consistent with the
environmental standards that the proponent will require to adhere to, during the different
stages of project.
2.2.3 SECONDARY RESOURCES/ BASELINE REVIEW
Environmental impacts are measured through changes in environment, resulting from a
designated action or activity. In order to identify such changes, it is essential to have as
complete understanding of the nature of existing environment, prior to its interaction with the
proposed activity. This translates into the need to characterize the existing baseline
environmental condition, including establishing prevailing conditions for a range of
environmental media, notably air, water, soil and groundwater, flora and fauna and the human
environment.
This was achieved through a detailed review of available secondary literature, the undertaking
of project specific baseline studies and surveys on physical, biological and socio-economic
environment of the project area. All data sources were reviewed to collect information relevant
to the physical, biological and socio-economic environment within the project area.
2.2.4 SCOPING SESSIONS
Scoping is a vital early step, which identifies the issues that are likely to be important during the
environmental assessment, and eliminates those that are not. Scoping is a process of interaction
between the interested public, government agencies and the proponent. Scoping refers to the
process of identifying the appropriate boundaries of the environmental assessment, the
important issues and concerns, the information necessary for decision making and the
significant impacts and factors to be considered. For scoping process, stakeholders were
carefully selected. The stakeholders included regulators, government representatives and
prominent Non Government Organizations (NGOs).

Chapter 02 3 of 4
Meetings were held with the officials of Sindh EPA, Sindh Wildlife Department, Sindh Forest
Department, Sindh Fisheries Department, Archaeological Department, Assistant Commissioner
and Municipal officers, NGOs: WWF Pakistan, National Rural Support Program (NRSP), to
obtain a better understanding of the project area and its relevant features. All these
organizations provided assistance to the SGS team while conducting this EIA.
2.2.5 APPROVAL FOR FIELD VISIT
SGS team met with Chief Conservator Forest, Sindh Forest Department (SFD) and Conservator
Wildlife, Sindh Wildlife Department (SWD) Conservator Forest Department to obtain a better
understanding of the project area and its relevant features, as mentioned above. In addition,
SGS team obtained formal approval from these departments for baseline data collection within
riverine forest areas and wildlife protected areas. SGS team also requested for their
representatives to accompany SGS team during field visit.
2.2.6 SITE VISIT AND PRIMARY DATA COLLECTION
SGS team visited the project area and its vicinity from October 17 to 22, 2014 to conduct baseline
environmental survey. The team comprised of, ecologist, wildlife expert, environmental experts
and sociologist. During the site visit, primary information on the physical, biological and socio-
economic background conditions of the project area were collected. In addition, discussions
were held with the members of the community resident in the area to collect area-specific
primary information along with their views and concerns regarding the project and its
activities.
2.2.7 EVALUATION OF ALTERNATIVES
To ascertain an environmentally sound preferred option for achieving the objectives of the
proposed project, alternatives were studied in collaboration with the project proponent. All
alternatives which include no project option, alternative site, timing, and alternative
technologies were reviewed and discussed to establish the environmental soundness of the
operations. Technology selection was accomplished by considering options which were
environmentally, economically and socially suitable. A detail of alternatives has been provided
in section 7 of the report.
2.2.8 IDENTIFICATION, SCREENING AND ASSESSMENT OF IMPACTS
The information collected in the previous phases was used to assess and identify the major
issues of environmental concerns and indicate their relative importance to the design of the
project. Potential impacts arising from each phase of the proposed seismic, construction and
drilling activities were identified. The issues studied during impact assessment include
potential impacts on:
• Physical environment of the area
• Biological environment of the area

Chapter 02 4 of 4
• Socio-economic environment of the area
Screening and assessment of anticipated impacts, and those that are cumulative, unavoidable or
irreversible were also carried out. Impacts were identified particularly in the wildlife reserve
and assessed on the basis of field data collected from project area, secondary data and expert’s
opinion on the same.
2.2.9 IMPACTS ASSESSMENT AND MITIGATION MEASURES
One of the main tasks of impact assessment is to predict unacceptable adverse effects and their
prevention through the implementation of appropriate project modifications, also known as
mitigation measures. Mitigation measures are helpful to prevent or minimize all potential
adverse environmental impacts of proposed intervention.
Impacts are identified keeping in view the baseline condition of the project area and any change
due to proposed operations on the baseline environmental condition. Considering identified
impacts, appropriate and practicable mitigation measures have been recommended to
eliminate, minimize or compensate for the potential environmental and social impacts on the
project zone of influence.
2.2.10ENVIRONMENTAL MANAGEMENT PLAN
Environmental Management Plan (EMP) has been developed in order to assist and enable
MPCL for effective management and implementation of mitigation measures. EMP will guide
them throughout the project lifecycle how to maintain environmental and social conditions and
implement occupational safety measures. This plan also delineates the information required to
manage environmental and occupational safety risks arising from proposed project activities as
well as social issues.
EMP will also include environmental monitoring plans in order to comply with local legislative
requirements.
2.2.11REPORTING/DOCUMENTATION
The EIA report has been prepared under the guidelines issued by the Sindh Environmental
Protection Agency (SEPA) Act 2014 and submitted to SEPA. The organization of the report is
described in the preceding chapter.

Chapter 03 1 of 16
3. LEGAL FRAMEWORK
This chapter provides an overview of the environmental policies, legislation, and guidelines
that may have relevance to the proposed project. These include national environmental policy,
legislation and guidelines; and international conventions and guidelines. MPCL will be
required to adhere to the relevant requirements of the policies and legislation during the
construction and operation of the proposed activities; which has also been incorporated in the
mitigation measures and the EMP provided in the EIA.
3.1 CONSTITUTIONAL PROVISION
According to the Constitution of Pakistan, the legislative powers lie with the federal parliament
and the legislative assemblies of the four provinces of Pakistan. The Fourth Schedule of the
constitution provides two lists of issues. One list, the Federal Legislative List, includes issues on
which only the federal government has legislative powers. The second list, the Concurrent
Legislative List includes issues on which both the federal and the provincial governments have
legislative powers. If a particular legislation passed by a provincial assembly comes into conflict
with a law enacted by the national assembly, then according to the constitution, the federal
legislation will prevail over the provincial legislation to the extent of the inconsistency. The
subject of ‘environmental pollution and ecology’ is included in the concurrent list of the
constitution. Thus, allowing both the federal and provincial governments to enact laws on the
subject. To date, only the federal government has enacted laws on environment, and the
provincial environmental institutions derive their power from federal law. 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”.
3.2 FRAMEWORK OF ENVIRONMENT AND WILDLIFE INSTITUTION
IN PAKISTAN
The Federal Ministry of Environment was the main government organization responsible for
the protection of environment and resource conservation. It was headed by a federal minister.
The Ministry worked with PEPC, and the Federal and Provincial EPAs formed under the PEPA
1997. The roles, responsibilities and authorities of PEPC and the EPA’s have been defined in the
PEPA 1997. However, after 18th constitutional amendment, the said ministry has been
devolved into provinces and Pakistan Environmental Protection Agency is working under the
umbrella of Climate Change Division.
Now, Pakistan Environmental Protection Agency is an attached department of the Climate
Change Division and responsible to implement the Pakistan Environmental Protection Act 1997,
in the country, an Act to provide for the protection, conservation, rehabilitation and
improvement of environment, for the prevention and control of pollution, and promotion of

Chapter 03 2 of 16
sustainable development. Pakistan Environmental Protection Agency also provides all kind of
technical assistance to the Climate Change Division.
The National Council for Conservation of Wildlife (NCCW) is responsible for formulation of
national wildlife policies, co-ordination with provincial wildlife department on the
implementation of these policies and co-ordination with international organisations on matters
related to international treaties/conventions. The NCCW works under the Ministry of Climate
Change and is headed by the Inspector General Forests. NCCW comprises of an advisory
council, which is chaired by the Minister of Climate Change and includes representatives from
all Provinces, AJK and Northern Areas, NGOs, members of civil society and other federal
ministries. A small NCCW secretariat is based in Islamabad handles the day-to-day affairs and
the implementation of policies and recommendations of the advisory council. At provincial
level almost each province has a wildlife department and a wildlife protection act.
3.3 NATIONAL ENVIRONMENTAL POLICIES
3.3.1 NATIONAL ENVIRONMENTAL POLICY, 2005
The National Environmental Policy (NEP) was approved by the Pakistan Environmental
Protection Council (PEPC) in its 10th meeting on 27th December, 2004 under the chairmanship
of the Prime Minister of Pakistan and thereafter approved by the Cabinet on 29th June 2005.
NEP is the primary policy of Government of Pakistan that addresses the environmental issues
of the country. The broad Goal of NEP is, “To protect, conserve and restore Pakistan’s
environment in order to improve the quality of life of the citizens through sustainable
development”. The NEP identifies the following set of sectoral and cross-sectoral guidelines to
achieve its Goal of sustainable development.
Sectoral Guidelines:
Water and sanitation, Air quality and noise, Waste management, Forestry, Biodiversity and
Protected areas, Climate change and Ozone depletion, Energy efficiency and renewable,
agriculture and livestock, and Multilateral environmental agreements.
Cross Sectoral Guidelines:
The NEP suggests the following policy instruments to overcome the environmental problems
throughout the country:
• Integration of environment into development planning,
• Legislation and regulatory framework,
• Capacity development,
• Economic and market based instrument,
• Public awareness and education, and
• Public private civil society partnership.

Chapter 03 3 of 16
3.3.2 NATIONAL CONSERVATION STRATEGY
Before the approval of National Environmental Policy (NEP) the National Conservation
Strategy (NCS) was considered as the Government’s primary policy document on national
environmental issues. The Strategy approved by the Federal Cabinet in March 1992 and was
also recognized by International Financial Institutions, principally the World Bank At the
moment this strategy just exists as a national conservation program. The NCS identifies 14 core
areas including conservation of biodiversity; pollution prevention and abatement; soil and
water conservation; and preservation of cultural heritage, and recommends immediate
attention to these core areas in order to preserve the country’s environment.
NCS does not directly apply to projects. However, MPCL should ensure that the project should
not add to the aggravation of the 14 core environmental issues identified in the NCS and
mitigation measures should be adopted to minimise or avoid any contribution of the project in
these areas.
3.3.3 NATIONAL ENVIRONMENTAL ACTION PLAN-SUPPORT PROGRAMME
(NEAP-SP)
The Government of Pakistan and United Nations Development Programme (UNDP) have
jointly initiated an umbrella support programme called the “National Environmental Action
Plan-Support Programme (NEAP-SP)” 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.
3.3.4 POLICY & PROCEDURES FOR THE FILING, REVIEW AND APPROVAL OF
ENVIRONMENTAL ASSESSMENTS
The Policy & Procedures for the Filing, Review and Approval of Environmental Assessments,
prepared by the PEPA under the powers conferred upon it by the Pakistan Environmental
Protection Act, provide the necessary details on the preparation, submission, and review of the
Initial Environmental Examination (IEE) and the Environmental Impact Assessment (EIA). It
provides schedules of proposals that require either an Initial Environmental Examination (IEE)
or an Environmental Impact Assessment (EIA).
3.3.5 PETROLEUM EXPLORATION & PRODUCTION POLICY 2012
Government of Pakistan introduced the first petroleum Policy document in 1991.This was then
followed by new Petroleum Policies of 1993, 1994, 1997, 2001, 2007 and 2009.
Policy 2009 had to be amended by new Petroleum Policy 2012 as the new market conditions
warranted urgent changes required for investment promotion in view of increasing
international energy prices. It also reflects the resolve of Government of Pakistan to accelerate
exploitation of indigenous natural resources by attracting foreign investment with technology
as well as promoting local companies to participate in E&P activities on a level playing field.

Chapter 03 4 of 16
The purpose of Petroleum Exploration and Production Policy 2012 is to establish the policies,
procedures, tax and pricing regime in respect of petroleum exploration and production (E&P)
sector.
The Petroleum Exploration & Production Policy 2012 maintains a system based upon the two
different types of agreements to obtain E&P rights in Pakistan:
• For onshore operations, a system based upon a Petroleum Concession Agreement (PCA).
• For offshore operations, a system based upon a Production Sharing Agreement (PSA).
This Policy has incorporated the significant achievements of the Pakistani petroleum industry
with established good international oilfield practices.
3.4 NATIONAL ENVIRONMENTAL LEGISLATION
The 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.
The definition of environmental law can be derived from the legal definition of ‘environment’.
In Section 2(xii) of the Sindh Environmental Protection Act 2014 (SEPA) environment is defined
to include air, water, land and layers of the atmosphere; living organisms and inorganic matter;
the ecosystem and ecological relationships; buildings, structures, roads, facilities and works;
social and economic conditions affecting community life; and the interrelationship between
these elements. From this definition, an environmental law can be considered to include all laws
that are designed to, or that directly or indirectly affect, the management of natural resources
including the control of pollution of these natural resources.
By this definition, environmental laws include a) laws that have been specifically enacted to
protect the environment such as the SEPA 2014, and b) laws relating to subject such as forest,
water resources, wildlife, land, agriculture, health, and town planning. Table 3.1 shows key
environment, health and safety related legislative powers of federal and provincial government,
enforcing agencies and pertinent laws.
Table 3.1: Relevant Environmental Laws and their Applicability
Subject
Legislative
Power
Enforcing Agencies Pertinent Laws
Environmental
Pollution and
Ecology
Federal and
Provincial
Ministry of Climate
Change,
Pakistan
Environmental
Protection Agency,
Sindh
Sindh Environnemental
Protection Act, 2014
National Environnemental
Quality Standards (NEQS),
National Environnemental
Quality Standards (NEQS),
Environmental Laboratories

Chapter 03 5 of 16
Environmental
Protection Agency,
2000,
NEQS (Self-Monitoring and
Reporting by Industry) Rules
2005 (Amended)
Regulation of
Labour and
Safety in Mines,
Factories and Oil
Fields
Federal and
Provincial
Chief Inspector of
Mines
Chief Inspector of
Industries
Mines Act, 1923
Factories Act, 1934
Sindh Factories Rules, 1978
Hazardous Occupation
Rules 1963
Ancient and historical
Monuments and
Archaeological Sites
Federal and
Provincial
Department of
Museum
Antiquities Act, 1975
Sindh Cultural Heritage
(Preservation) Act, 1994
Wildlife
Federal and
Provincial
Sindh Wildlife
Department Sindh
Wildlife Protection
Ordinance 1972
Forestry
Federal and
Provincial
Sindh Forest
Department
Forest Act, 1927
3.4.1 SINDH ENVIRONMENTAL PROTECTION ACT 2014
The Sindh Environmental Protection Act, 2014 (SEPA) is the basic legislative tool empowering
the provincial government to frame regulations for the protection, conservation, rehabilitation
and improvement of the environment. The SEPA is broadly applicable to air, water, soil,
hazardous waste, marine and noise pollution. Penalties have been prescribed for those
contravening the provisions of the Act. The powers of the provincial Environmental Protection
Agencies (EPAs) were also considerably enhanced under this legislation and they have been
given the power to conduct inquiries into possible breaches of environmental law either of their
own accord, or upon the registration of a complaint. Sindh Environmental Protection Act, 2014
(SEPA) attached as Annexure 1I.
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.
Under section 17 of SEPA, ‘’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 it approval or
otherwise from the date EIA is filed failing which the EIA shall deemed to have been approved.

Chapter 03 6 of 16
3.4.2 PAKISTAN ENVIRONMENTAL PROTECTION AGENCY REVIEW OF IEE
AND EIA REGULATIONS, 2000
The Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2000 (the
‘Regulations’), prepared by the Pak-EPA under the powers conferred upon it by the PEPA,
provide the necessary details on the preparation, submission, and review of the initial
Environmental Examination (IEE) and the Environmental Impact Assessment (EIA).
The Regulation classifies projects on the basis of expected degree of adverse environmental
impacts and lists them in two separate schedules. The Regulations also require that all projects
located in environmentally sensitive areas require preparation of an EIA. As the proposed
project activities will be carried out in protected area i.e. Riverine forest, Game reserves,
wetlands and Ramsar site, an EIA study is therefore required. Pakistan Environmental
Protection Agency Review of IEE and EIA Regulations, 2000 is attached as Annexure III.
3.4.3 THE NATIONAL ENVIRONMENTAL QUALITY STANDARDS (NEQS)
The NEQS promulgated under the PEPA 1997 specify standards for industrial and municipal
effluents, gaseous emissions, vehicular emissions, and noise levels. The PEPA 1997 empowers
the EPA’s to impose pollution charges in case of non-compliance to the NEQS.
During the construction and post development phase of the project, NEQS will apply to all type
of effluents and emissions. NEQS for municipal and industrial effluents, motor vehicle exhaust
and noise and selected gaseous pollutants from industrial source are provided in Annexure IV.
3.4.4 SELF-MONITORING & REPORTING RULES
Pakistan Environmental Protection Council constituted an Environmental Standards Committee
in 1996 to devise realistic modalities for NEQS enforcement and simplified monitoring
procedures with the consultation of representatives of industrial interest groups, non-
governmental organizations (NGOs) and other stakeholders. Their efforts succeeded in the
bringing up of “Self-Monitoring and Reporting System for Industry”. As per the rules set by
this system, industries have to monitor effluents and emissions in compliance with the NEQS
and report it to provincial or federal EPAs. This system classifies industry into three categories
A, B and C each corresponding to a specified reporting frequency. Proposed power plant
project lies under Category A for both liquid effluent and gaseous emissions and thus reporting
frequency to SEPA required every month.
3.5 THE FOREST ACT 1927
This act is applicable to all regions of Pakistan. It includes procedures for constituting and
managing various types of forests, such as reserved forests and protected forests. The act
empowers the provincial forest departments to declare any forest area as reserved or protected.
The act empowers the provincial forest departments to prohibit the clearing of forests for
cultivation, grazing, hunting, removing forest produce; quarrying and felling, lopping and

Chapter 03 7 of 16
topping of trees, branches in reserved and protected forests. It also defines the duties of forest
related public servants, and penalties for any infringement of the rules.
Sujawal block also encompass reserved forest, which has been declared as protected forest
under this act, therefore the project will implement with any provisions of this Act. Sindh Forest
Department has been informed about development activities and ensure that all activities will
be implemented such that impacts on mangrove shall be minimized, conservation practices
shall be adopted and appropriate mitigation measures, to mitigate the impacts on mangrove
forest, have been suggested in the EIA report.
3.6 SINDH WILDLIFE PROTECTION ORDINANCE, 1972 (SWPO) AND
AMENDMENTS 2001
This ordinance provides for the preservation, protection, and conservation of wildlife by the
formation and management of protected areas and prohibition of hunting of wildlife species
declared protected under the ordinance.
The ordinance also specifies three broad classifications of the protected areas: national parks,
wildlife sanctuaries and game reserves. Activities such as hunting and breaking of land for
mining are prohibited in national parks, as are removing vegetation or polluting water flowing
through the park. Wildlife sanctuaries are areas that have been set-aside as undisturbed
breeding grounds and cultivation and grazing is prohibited in the demarcated areas. Nobody is
allowed to reside in a wildlife sanctuary and entrance for the general public is by special
dispensation. However, these restrictions may be relaxed for scientific purposes or for
betterment of the respective area on the discretion of the governing authority in exceptional
circumstances. Game reserves are designated as areas where hunting or shooting is not allowed
except under special permits.
Two amendments to the Ordinance were issued in January and June 2001 respectively
pertaining to oil and gas activities within national parks and wildlife sanctuaries. The first
amendment allowed the Government to authorize the laying of an underground pipeline
through protected areas. The second amendment allowed exploration and production activities
within national parks and wildlife sanctuaries for which an EIA study have to be prepared by
the proponent and approved by the concerned regulatory departments in accordance with the
SEPA 2014.
3.7 SINDH FISHERIES ORDINANCE, 1980
This Ordinance regulates fishing operations, and applies to inland fisheries in public waters as
well as to territorial waters. Fishing is defined broadly in section 2(d) as the “taking or catching
of fish by any means” while public waters are defined in section 2(r) to include “any waters
other than the private waters and includes territorial waters”. The law applies to “all kinds of
fish” including “molluses, crustaces and kelp-fish”.

Chapter 03 8 of 16
The provincial government has the power to issue leases or fishing licences in any public waters
(section 3(1)). Leaseholders may in turn issue permits for fishing in leased waters (section 3(2)).
The government regulates various aspects of commercial fishing including the size of mesh that
may be employed, the type of fishing equipment that may be used, and processing and
marketing operations (sections 9, 10, 11 and 27). The Ordinance allows the government to
declare “any public waters” to be a sanctuary and to prohibit the killing, capturing or taking of
fish from such waters for a specified period without a “special” permit.
Certain provision of the Ordinance nevertheless serves to protect fish species in general, along
with aquatic environments. Under section 7, for example, the use of explosives, poisons and
“noxious” materials for the purpose of “catching or destroying fish and other aquatic life” is
prohibited in “any waters”. Similarly, section 8 prohibits the discharge of untreated sewage,
“effluence” and factory waste into “any waters”; all such waste must be treated so that it is
“harmless for fish and other aquatic life”. According to the ordinance any discharge of waste
into the water bodies shall not only be prohibited but the offender shall also be punished with
imprisonment for a term which may extend to six months or a fine which may extend to ten
thousand rupees or with both.
The government may appoint fisheries inspectors (section 13) who are empowered to arrest
suspected offenders, seize equipment and fish involved in a suspected offence (section 16),
“compound” offences” (section 26), and call for police assistance (section 18).
The ordinance is relevance to the EIA due to the presence of fish fauna in several water bodies
located within the project area including Indus River and associated water bodies (Dhand) In
this connection, Sindh Fisheries Department has been informed that all project activities near
and/or within water bodies will have to be implemented such that no physical damage to the
habitat or permanent alteration in water quality occurs.
3.8 PETROLEUM ACT 1934
This act regulates the import, transport, storage, production, refining and blending of
petroleum and other flammable substances. The federal government issues licenses and may
make rules to regulate the import, transport and distribution of petroleum (Section 4). The law
requires that all containers carrying “dangerous petroleum” (highly flammable) bear a warning
(Section6). The act also contains provisions regarding the testing and quality control of
petroleum products (Section 14ff.). All powers remain with the federal government.
3.9 THE MINES ACT 1923
This act, which is largely administrative in nature, regulates mining operations and mine
management, and contains provisions regarding the health, safety and working conditions of
mine labour. The power to make rules lies with the “appropriate government” (Section 29),
defined as the federal government in the case of mines extracting radioactive material, oil, gas
and flammable substances, and the provincial government for all other mines.

Chapter 03 9 of 16
3.10 REGULATION OF MINES AND OIL FIELDS AND MINERAL
DEVELOPMENT (GOVERNMENT CONTROL) ACT, 1948
This act regulates the development of mines, oilfields and mineral deposits. The federal
government makes rules related to the development of mines and nuclear substances, oilfields
and gas fields, while provincial governments make rules related to other minerals and their
extraction. This Act provides for enforcement of rules related to the storage and distribution of
"mineral oils", the establishment of prices at which mineral oils may be bought or sold and any
matter ancillary and incidental to the objectives set out in the act.
3.11 EXPLORATION AND PRODUCTION RULES, 1986
The 1986 Exploration and Production Rules address environmental concerns, and require
operators to “prevent pollution, avoid accumulation of trash and prevent damage to the
environment and surroundings.”
3.12 THE OIL AND GAS (SAFETY IN DRILLING AND PRODUCTION)
REGULATIONS, 1974
These regulations outline safety in exploration and production of oil and gas companies
operating in Pakistan. Some of the safety protocols under these regulations include:
• Appointment of a Welfare and Safety Officer in all drilling operations employing more
than 250 workers;
• Safety requirements of workplaces and drilling equipment;
• Fire precautions and fire fighting equipment; personal protective equipment (including
breathing apparatus and safety belts).
3.13 ANTIQUITIES ACT 1975 AND THE SINDH CULTURAL HERITAGE
(PRESERVATION) ACT, 1994
The protection of cultural resources in Pakistan is ensured by the Antiquities Act of 1975.
Antiquities have been defined in the Act as ancient products of human activity, historical sites,
or sites of anthropological or cultural interest, national monuments etc. The act is designed to
protect antiquities from destruction, theft, negligence, unlawful excavation, trade and export.
The law prohibits new construction in the proximity of a protected antiquity and empowers the
Government of Pakistan to prohibit excavation in any area, which may contain articles of
archaeological significance.
The Sindh Cultural Heritage (Preservation) Act, 1994 is the provincial law for the protection of
cultural heritage. Its objectives are similar to those of the Antiquity Act, 1975.
The project area for the EIA contains no notified archaeological site as protected under this act.
Furthermore, the project site is unlikely to contain any buried antiquity. However, the project
staff will be instructed before ground preparation and earthworks to report any archaeological

Chapter 03 10 of 16
artifact or what may appear to be an archaeological relic to the project management. In case of
such a discovery, appropriate action will be taken.
3.14 LAND ACQUISITION ACT, 1894
The Land Acquisition act (LAA) of 1894 amended from time to time has been the policy
governing land acquisition, resettlement and compensation in the country. The LAA is the most
commonly used law for acquisition of land and other properties for development projects. It
comprises of 55 sections pertaining to area notifications and surveys, acquisition, compensation
and appointment awards and disputes resolution, penalties and exemptions. In the proposed
project there is no such kind of land acquisition or resettlement of proposed project affected
persons.
3.15 PAKISTAN PENAL CODE (1860)
The Pakistan Penal Code (1860) authorizes fines, imprisonment or both for voluntary
corruption or fouling of public spring or reservoirs so as to make them less fit for ordinary use.
The Pakistan Penal Code (PPC) 1860 deals specifically with the pollution of water in Chapter
XIV on public health and safety. Here, “fouling” or “corrupting” the water of a public spring or
reservoir is listed as an offence, punishable with up to three months in prison and/or a fine of
500 rupees (Section 277). This provision is limited in scope, since it applies only to reservoirs
and public springs, and the terms “fouling” and “corrupting” are not defined. But provisions of
PEPA 1997 (Sections 6 and 7) and the NEQS (Appendix I) may be applied to facilitate
enforcement of Section 277. Other sections of this chapter may be interpreted to include the
protection of water resources, including Section 268 on public nuisance, Section 269 on
negligence likely to spread infectious disease, and Section 284 on negligent conduct with respect
to the possession and handling of poisonous substances.
Similarly, Chapter XVII on offences against property contains certain provisions that may be
interpreted to include the protection of water resources. Sections 425–440 deal with “mischief”,
defined as damage to property resulting in destruction or loss of utility. Section 430 provides
specifically for mischief caused to irrigation works, while Section 431 deals with damage to
roads, bridges, rivers or channels. Meanwhile, Chapter XXIII, Section 511 on attempted offences
could also be interpreted to include offences related to the “fouling” or “corrupting” of water.
Under Section 278 of the PPC, the punishment for “making [the] atmosphere noxious to health”
is a maximum fine of 500 rupees. In addition, certain sections of Chapter XIV on public health
and safety concerning “public nuisance” may be interpreted to include air and noise pollution
from vehicles, as well as emissions (Sections 268, 278, 290 and 291).
3.16 EXPLOSIVE SUBSTANCES ACT 1908
This law regulates the possession and use of explosive substances, including materials for the
manufacture of explosives as well as machinery, tools and materials that can be used to cause
an explosion (Section 2). Causing an explosion is punishable with a maximum sentence of life in

Chapter 03 11 of 16
prison, whether or not the event causes any injury to persons or damage to property (Section 3).
The same maximum penalty applies to making or possessing explosives with intent to cause an
explosion (Section 4). Although the law does not specify conditions under which it is legal to
possess explosive materials, possession of such substances for a purpose that is not “lawful” is
an offence (Section 5), implying that some form of regulatory mechanism is to be put in place.
Powers under this act have been delegated to provincial governments, which may restrict or
allow the courts to proceed with the trial of suspected offenders (Section 7). The 1908 law deals
exclusively with causing explosions or intent to cause explosions.
3.17 EXPLOSIVES ACT 1884
This law deals with manufacture, possession, sale, use and transport of explosives. The
government may prohibit the manufacture, possession or import of any explosive substance,
except with a licence (Section 5), or ban outright the manufacture, import or possession of any
material deemed to be of “so dangerous character [sic]” that it is “expedient for the public
safety” to impose such restrictions (Section 6). Under this law, the maximum penalty for
illegally manufacturing, possessing or importing explosives is 5,000 rupees.
The government may declare any substance deemed particularly dangerous to life or property,
owing to its explosive properties, or any of the processes involved in its manufacture to be an
explosive within the meaning of this act (Section 17). Such materials may include a wide range
of chemical substances that are explosive in nature, although the term “dangerous” itself has
not been defined. No regulatory compliance measures are introduced for the handling of
hazardous materials.
3.18 NATIONAL ENVIRONMENTAL GUIDELINES
3.18.1 THE PAKISTAN ENVIRONMENTAL ASSESSMENT PROCEDURES, 1997
The Pakistan Environmental Protection Agency prepared the Pakistan Environmental
Assessment Procedures in 1997. They are based on much of the existing work done by
international donor agencies and Non Governmental Organisations (NGO’s). The package of
regulations prepared by PEPA includes:
• Policy and Procedures for Filing, Review and Approval of Environmental Assessments;
• Guidelines for the Preparation and Review of Environmental Reports;
• Guidelines for Public Consultation;
• Guidelines for Sensitive and Critical Areas; and
• Sectoral Guidelines for various types of projects.

Chapter 03 12 of 16
3.18.2 GUIDELINES FOR OPERATIONAL SAFETY, HEALTH AND
ENVIRONMENTAL MANAGEMENT, DECEMBER 1996
These guidelines are the outcome of a study commissioned by the Directorate General
Petroleum Blocks, Ministry of Petroleum and Natural Resources, Government of Pakistan. The
guidelines list down the relevant laws related to the operational health, safety and environment
and also recommends environmental controls and management practices to be adopted in O&G
exploration projects.
3.18.3 GUIDELINES FOR PUBLIC CONSULTATION
These guidelines are a part of a package of regulations and guidelines. It provides assistance
throughout the environmental assessment of project by involving the public which can lead to
better and more acceptable decision-making.
3.18.4 SECTORAL GUIDELINES FOR ENVIRONMENTAL REPORTS OIL & GAS
EXPLORATION AND PRODUCTION
The guideline will assist proponents to identify the key environmental issues that need to be
assessed as well as mitigation measure and alternatives that need to be considered in the actual
EIA.
This guideline deal with Oil & Gas projects which involved exploration or production of oil and
gas. The environmental issues discussed in this guideline are specific to exploration or
production activities of oil and gas and all such projects should address these issues. The degree
and relevance of the issues will vary from proposal to proposal. The matters identified in this
guideline should provide guidance for the preparation and assessment of most exploration and
production proposals.
3.19 INTERNATIONAL GUIDELINES
3.19.1 WORLD BANK GUIDELINES ON ENVIRONMENT
The principal World Bank publications that contain environmental guidelines are listed below:
• Environmental Assessment-Operational Policy 4.01. Washington, DC, USA. World Bank
1999.
• Environmental Assessment Sourcebook, Volume I: Policies, Procedures, and Cross-Sectoral
Issues. World Bank Technical Paper Number 139, Environment Department, the World
Bank, 1991,
The first two publications provide general guidelines for conducting EIAs, and address EIA
practitioners as well as project designers. While the Sourcebook in particular has been designed
with Bank projects in mind, and is especially relevant for the impact assessment of large-scale
infrastructure projects, it contains a wealth of useful information, for environmentalists and
project proponents.

Chapter 03 13 of 16
The Sourcebook identifies a number of areas of concern, which should be addressed during
impact assessment. It sets out guidelines for the determination of impacts, provides a checklist
of tools to identify possible biodiversity issues and suggests possible mitigation measures.
Possible development project impacts on different areas such as wild lands, wetlands and
forests are also identified and mitigation measures suggested.
3.19.2 IFC PERFORMANCE STANDARDS
International Finance Corporation (IFC), a member of the World Bank Group, is the largest
global development institution focused on the private sector in developing countries. IFC's
Sustainability Framework applies to all investments and advisory clients whose projects go
through IFC's credit review process.
IFC's Performance Standards define clients' roles and responsibilities for managing their
projects and the requirements for receiving and retaining IFC support. The standards include
requirements to disclose information. The Performance Standards may also be applied by other
financial institutions electing to apply them to projects in emerging markets.
The eight Performance Standards establish standards that the client is to meet throughout the
life of an investment by IFC or other relevant financial Institution.
• Performance Standard-1: Social and Environmental Assessment and Management System;
• Performance Standard-2: Labour and Working Conditions;
• Performance Standard-3: Pollution Prevention and Abatement;
• Performance Standard-4: Community Health, Safety and Security;
• Performance Standard-5: Land Acquisition and Involuntary Resettlement;
• Performance Standard-6: Biodiversity Conservation and Sustainable Natural Resource
Management;
• Performance Standard-7: Indigenous People;
• Performance Standard-8: Cultural Heritage.
3.19.3 IFC ENVIRONMENTAL, HEALTH & SAFETY GUIDELINES
IFC has also developed Environmental, Health, and Safety (EHS) Guidelines. These guidelines
are technical reference documents with general and industry specific examples of Good
International Industry Practice (GIIP).
The EHS Guidelines are required to adhere by IFC clients under Performance Standard 3 on
Pollution Prevention and Abatement.

Chapter 03 14 of 16
3.20 INTERNATIONAL CONVENTIONS & TREATIES
3.20.1 INTERNATIONAL CONVENTION ON BIODIVERSITY
The International Convention on Biodiversity was adopted during the Earth Summit of 1992 at
Rio de Janeiro. The Convention requires parties to develop national plans for the conservation
and sustainable use of biodiversity, and to integrate these plans into national development
programmes and policies. Parties are also required to identify components of biodiversity that
are important for conservation, and to develop systems to monitor the use of such components
with a view to promote their sustainable use.
3.20.2 THE CONVENTION ON CONSERVATION OF MIGRATORY SPECIES OF
WILD ANIMALS, 1979
The Convention on the Conservation of Migratory Species of Wild Animals (CMS), 1979,
requires countries to take action to avoid endangering migratory species. The term "migratory
species" refers to the species of wild animals, a significant proportion of whose members
cyclically and predictably cross one or more national jurisdictional boundaries. The parties are
also required to promote or co-operate with other countries in matters of research on migratory
species.
The Convention contains two appendices. Appendix I contain the list of migratory species that
are endangered according to the best scientific evidence available. For these species, the
member states to the Convention are required endeavour to:
• Conserve and restore their habitats;
• Prohibit their hunting, fishing, capturing, harassing and deliberate killing;
• Remove obstacles and minimize activities that seriously hinder their migration;
• Control other factors that might endanger them, including control of introduced exotic
species.
Appendix II lists the migratory species, or groups of species, that have an unfavourable
conservation status as well as those that would benefit significantly from the international co-
operation that could be achieved through intergovernmental agreements.
3.20.3 THE CONVENTION ON WETLANDS OF INTERNATIONAL
IMPORTANCE, RAMSAR 1971
Pakistan is a signatory to the said Convention. The principal obligations of contracting parties
to the Convention are:
• To designate wetlands for the List of Wetlands of International Importance.
• To formulate and implement planning so as to promote wise use of wetlands, to carry out
an EIA before transformations of wetlands, and to make national wetland inventories.

Chapter 03 15 of 16
• To establish nature reserves on wetlands and provide adequately for their wardening and
through management to increase waterfowl populations on appropriate wetlands.
• To train personnel competent in wetland research, management and wardening.
• To promote conservation of wetlands by combining far-sighted national policies with
coordinated international action, to consult with other contracting parties about
implementing obligations arising from the Convention, especially about shared wetlands
and water system.
• To promote wetland conservation concerns with development aid agencies.
• To encourage research and exchange of data.
So far 19 sites in Pakistan have been declared as wetlands of International Importance or
Ramsar Sites. One Ramsar site named as Indus Delta is located within the In EIA project area.
3.20.4 CONVENTION ON INTERNATIONAL TRADE IN ENDANGERED
SPECIES OF WILD FAUNA AND FLORA (CITES)
This convention came into effect on 03 March 1973 in Washington. In all 130 countries are
signatory to this convention with Pakistan signing the convention in 1976. The convention
requires the signatories to impose strict regulation (including penalization, confiscation of the
specimen etc.) regarding trade of all species threatened with extinction or that may become so,
in order not to endanger further their survival.
The Convention contains three appendices. Appendix I include all species threatened with
extinction which are or may be affected by trade. The Convention requires that trade in these
species should be subject to strict regulation. Appendix II include species that are not
necessarily threatened presently but may become so unless trade in specimens of these species
is subject to strict regulation. Appendix III includes species which any contracting party
identifies as subject to regulations in trade and requires other parties to cooperate in this matter.
3.20.5 INTERNATIONAL UNION FOR CONSERVATION OF NATURE AND
NATURAL RESOURCES (IUCN) RED LIST
The red list is published by IUCN and includes those species that are under potential threat of
extinction. These species have been categorized as:
• Endangered: species that are sent to be facing a very high risk of extinction in the wild in
the near future, reduction of 50% or more either in the last 10 years or over the last three
generations, survive only in small numbers, or have very small populations.
• Vulnerable in Decline: species that are seen to be facing a risk of extinction in the wild,
having apparent reductions of 20% or more in the last 10 years or three generations.
• Vulnerable: species that are seen to be facing a high risk of extinction in the wild, but not
necessarily experiencing recent reductions in population size.

Chapter 03 16 of 16
• Lower Risk: species that are seen to be facing a risk of extinction that is lesser in extent that
for any of the above categories.
• Data Deficient: species that may be at risk of extinction in the wild but at the present time
there is insufficient information available to make a firm decision about its status.
3.21 INTERNATIONAL AND NATIONAL ENVIRONMENT AND
CONSERVATION ORGANIZATIONS
International and National NGOs
International environmental and conservation organisations such as IUCN and the World Wide
Fund for nature (WWF) have been active in Pakistan for some time. Both these organisations
have worked closely with government and act in an advisory role with regard to the
formulation of environmental and conservation Policies. Since the convening of the Rio
Summit, a number of national environmental NGO’s have also been formed, and have been
engaged in advocacy, and in some cases, research. Most prominent national environmental
NGO’s, such as the Sustainable Development Policy Institute (SDPI), Strengthening
Participatory Organization (SPO), Shehri, and Shirkatgah are the members of the Pakistan
National Committee (PNC) of IUCN.
As mentioned earlier, environmental NGO’s have been particularly active in advocacy, as
proponents of sustainable development approaches. Much of the government's environmental
and conservation policy has been formulated in consultation with leading NGO’s, who have
also been involved in drafting new legislation on conservation.
3.22 MPCL CORPORATE REQUIREMENTS
Corporate HSE (Health, Safety, Environment) Policy
MPCL undertakes that Health, Safety and Environment (HSE) is a management responsibility
and is committed to give priority to health and safety of all its employees and of other
personnel effected by and involved in its activities. The company HSE policy is built on a “No
Blame” culture. More emphasis is on the recognition and elimination of risk rather than looking
for someone to blame. MPCL also confers its overriding commitment towards minimizing
impact of its activities on the natural environment.

Chapter 04 1 of 21
4 PROJECT DESCRIPTION
4.1 INTRODUCTION
In this chapter salient features of the proposed project are discussed to the extent that they
relate to potential environmental, biological and social impacts. Details of proposed actions,
which include 2D/3D seismic survey, well construction and operational activities, are also
discussed in the subsequent sections.
4.2 PROJECT NEED
Pakistan spends billions of dollars to import the crude oil and other petroleum products and as
a result total import bill is rising for every consecutive fiscal year. To reduce this loss of foreign
exchange the government is committed to maximize replacement of imported furnace oil and
diesel oil with indigenous natural gas.
The share of natural gas in primary energy supplies of the country is about 47.6% (Pakistan
Energy Yearbook, 2011), and is the primary fuel used in the fertilizer industries, in addition to
its uses in the residential, commercial sectors and in power generation.
Pakistan Primary Energy Mix 2010-11 is given as Figure 4.1. The current situation: Energy
sources in Pakistan's current energy mix include hydel, thermal (coal, gas and furnace oil), and
nuclear for electricity generation, and gasoline, diesel, and Compressed Natural Gas (CNG) for
transport applications. Pakistan's primary energy mix-2011 as derived from Pakistan Energy
Yearbook 2011 is: Oil 32.0%; Gas 47.6%; LPG; 0.5%; Coal 6.7%; Hydro, Nuclear & Imported
Electricity 13.2%.
Figure 4.1: Pakistan Primary Energy Mix
The country has an estimated 824 billion cubic meter of recoverable reserves of natural gas
(Pakistan Energy Yearbook, 2010). Gas consumption is highest in the power generation sector
(27.2% of total gas consumed), domestic use (18.7%), Commercial (3.0%), Transport (9.1%), and
in fertilizer production (18.4% of total gas consumed) (Pakistan Energy Yearbook, 2011). In view
32%
48%
-1%
7%
13%
Pakistan's Primary Energy Mix 2010-11
Oil Gas LPG Coal Hydro, Nuclear & Impoerted

Chapter 04 2 of 21
of Pakistan's current energy crisis, it has become imperative for the country to explore more
indigenous resources to meet the domestic & industrial demands. MPCL is playing a very
important role in order to explore oil and gas in the country so that dependence on import may
be reduced.
4.3 PROJECT OBJECTIVE
MPCL has two prime objectives coupled with proposed 2D/3D seismic and drilling activities.
These two prime objectives are structured as following:
Exploration of new hydrocarbon reserves through drilling of exploratory boreholes on the
basis of promising geological features which will be identified in seismic survey.
To enhance the production of fossil-fuels in order to reduce energy deficiencies of the
Pakistan.
Above mentioned objectives will further explore and develop hydrocarbon resources in the
Sujawal EL block (2467-11) of Sindh Province, and ultimately of Pakistan for the mutual benefit
of the Pakistani people and MPCL shareholders.
4.4 PROJECT AREA
The proposed 2D/3D seismic and drilling activities will be carried out in Sujawal EL block
(2467-11) occupying a total area of about 2,416 square kilometres. The block is located in
Sujawal and Thatta districts of Sindh Province Pakistan.
The EIA report covers 320 line Km of 2D and 900 sq. km for 3D seismic operation. Seismic lines
will be laid in order to acquire seismic data and drilling of well to be carried out by MPCL in
the eastern part of the project area. Location will be firmed once the G&G evaluations are
completed.
4.5 PROPOSED PROJECT
MPCL was granted exploration license of Sujawal EL block (2467-11) in June 2006 by the
Government of Pakistan. MPCL is willing to continue its exploration activities and enhance
production capacities. In this connection, MPCL is going to perform seismic (2D/3D) and
drilling activities in Sujawal EL block (2467-11) this will include seismic data acquisition within
the project area and drilling of exploratory well. All these proposed activities will be carried out
after approval of Sindh EPA.
Exploratory activities will involve three different phases both for seismic and drilling segments.
This will include Construction phase, Operational phase and Restoration phase. During
proposed exploration activities, initially seismic survey will be carried out followed by drilling
activity in the project area.
2D/3D seismic data collection occurs along a line of receivers and resulting image represents
section below the line. Seismic survey will take around five months for completion. Generally
two techniques will be used for data acquisition; vibroseis in terrain with gentle slopes and flat

EIA EXECUTIVE SUMMARY

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EIA EXECUTIVE SUMMARY