IEE Water Sector - Mar 29, 2008

Karachi Water and Sewerage Board
City District Government Karachi
Karachi Mega City Sustainable Development Program
Initial Environmental Examination

Water Sector Subprojects
Water Treatment Plants and Water
Distribution Mains
Document Stage: Final Report

Document Date: March 29 2008
The initial environmental examination is a document of the

borrower. The views expressed herein do not necessarily
represent those of ADB’s Board of Directors, Management, or
staff, and may be preliminary in nature.
Karachi Mega City Sustainable Development Program MFF Tranche 1
IEE Report for Water Treatment Plants and Water Distribution Mains Subprojects
CONTENTS
I. INTRODUCTION.......................................................................................6
II. DESCRIPTION OF WATER SECTOR SUBPROJECTS.........................9

Water Supply to Karachi......................................................... ........................9
Water Distribution................................................................. ..........................9
Operational Issues............................................................................. ...........10
Water Quality.............................................................................. ..................10
Filtration Plant Extensions ...................................................................... ......11
Pipeline Route........................................................................................... ....11
Filtration Plant Extensions at COD and NEK Plants........................... ...........11
New Transmission Mains from Pipri to Korangi and Malir Town....................12
Distribution Network Improvement Programs............................................. ...12
III. DESCRIPTION OF ENVIRONMENT....................................................14

Physical Environment.......................................................... .........................14
Biological Environment....................................................... ..........................15
Social and Cultural Environment............................................................ .......16
COD Filtration Plant.......................................................................... ............18
NEK Filtration Plant........................................................ ..............................18
Pipri-Landhi Pipeline......................................................................... ............21
Pipri-Malir Pipeline............................................................................. ...........21
IV. ENVIRONMENTAL IMPACTS AND MITIGATION................................25

Planning the Construction Works........................................................ ..........27
Replacement of Trees............................................................................. ......29
Dust Impacts during Construction................................................... ..............29
Noise During Construction............................................................ ................30
Asbestos Management............................................................. ....................31
Other Issues Related to Pipeline Construction.......................................... ....31
Public Safety.......................................................................................... .......32
V. STAKEHOLDERS CONSULTATION.....................................................35
Meetings with Residential Consumers........................................ ..................35
Landhi Association of Trade and Industry............................ .........................35
Korangi Association of Trade and Industry............................................ ........36
Urban Resource Centre.................................................................. ..............36
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VI. INSTITUTIONAL REQUIREMENTS AND

ENVIRONMENTAL MANAGEMENT PLAN.......................................48
VII. FINDINGS AND RECOMMENDATIONS.............................................56
VIII. CONCLUSIONS.................................................................................58
Asbestos cement pipes shall be carefully excavated, lifted on to plastic
sheets, wrapped in polythene and sealed with duct tape to be
transported to the designated storage area or landfill.........................74
The procedure shall follow the measures indicated below:...........................74
1)The CONTRACTOR shall implement all the procedures in Appendix 2 of
the AMF and make available all the materials in Appendix 3 of the AMF.
74
2)The CONTRACTOR shall agree to remove and transport all the wrapped
asbestos (ACP) from the sites to secure temporary buffer store(s)
designated by DOE - CDGK to await disposal........................ ............74
3)The CONTRACTOR shall provide approved protective clothing to all
workers and DOE – CDGK inspector as and when requested............74
4)Workers handling the asbestos cement pipes shall wear the personal
protective clothing provided.............................................. ..................74
5)The DOE - CDGK Asbestos Specialist inspector shall visually inspect the
preparation before instructing the Contractor to proceed....................74
6)The DOE - CDGK Asbestos Specialist inspector shall monitor the works
and carry out a visual inspection to certify that all the ACP have been
removed to a satisfactory standard in line with Appendix 2 of the AMF.
74
7)The DOE - CDGK Asbestos Specialist inspector will check and record the
number of packs of waste transferred to the lorries are the same as
those that arrive at the temporary buffer or landfill using a trip ticket
system............................................................................... .................74
8)The DOE - CDGK Asbestos Specialist inspector will monitor and
periodically audit the buffer store and landfill security to ensure no
pilfering or theft of the stockpiled waste. The Asbestos Specialist
inspector will report on the progress of all the asbestos abatement
works under the MFF twice per year to ADB.................................. .....74
Stage 87
Task / Progress.............................................................................. ...............87
Yes / no (comment).............................................................................. .........87
Date 87
1. Minimizing Asbestos Liabilities.......................................................... ........88
2. Preparation of Detailed Design............................................. ....................88
3. Preparation of Construction Contracts................................... ...................89
4 Monitoring During the Construction Period.................... ............................89
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FIGURES
Figure 1: Water Sector Subprojects.......................................................13
Figure 2: COD Filtration Plant.................................................................19
Figure 3: NEK Filtration Plant.................................................................20
Figure 4: Pipri to Landhi Pipeline...........................................................23
Figure 5: Pipri to Malir Pipeline..............................................................24
Figure 6: Location of Public Consultations...........................................37
TABLES
Table 1: Ambient Air Quality in Karachi (µg/m3)...................................15
Table 2: Population of Karachi................................................................18
Table 3: Land Use Distribution for Filtration Plants.............................21
Table 4: Land Use Distribution for Pipelines.........................................22
Table 5: Summary of Public Consultation.............................................38
Table 6: Environmental Monitoring Plan for Tranche 1 Water Sector

Subprojects.......................................................................................54
Table 7: Summary of Estimated Costs for EMP Implementation.........54
Table 8: Operations Phase Environmental Monitoring Plan................55
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LIST OF ABBREVIATIONS
ADB Asian Development Bank
AMF Asbestos Management Framework
CDGK City District Government Karachi
CSC Construction Supervisory Consultant
DCO District Coordination Officer
DDC Detailed Design Consultants
DOE District Officer Environment
EARF Environmental Assessment and Review Framework
EDO Executive District Officer
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EPA Environmental Protection Agency
GER Gross Enrolment Rate
GoP Government of the Islamic Republic of Pakistan
IEE Initial Environmental Examination
KMCSDP Karachi Mega City Sustainable Development Program
KMP Karachi Master Plan
KWSB Karachi Water and Sewerage Board
MFF Multi-tranche Financing Facility
MMP Materials Management Plan
NEQS National Environmental Quality Standards
NOX Oxides of Nitrogen
Pak-EPA Pakistan Environmental Protection Agency
REA Rapid Environmental Assessment
RoW Right-of-Way
RRP Report and Recommendations to the President
SEPA Sindh Environmental Protection Agency
SO2 Sulphur Dioxide
SR Sensitive Receiver
TA Technical Assistance
WEIGHTS AND MEASURES

dB(A) Decibel (A-weighted)
ft Feet/Foot
km kilometre
km/h kilometre per hour
m meter
m3 cubic meter
m2 square meter
mgd million [imperial] gallons per day
s seconds
LAWS AND REGULATIONS

IEE-EIA Regulations 2000 Pakistan Environmental Protection Agency Review
of Initial Environmental Examination and
Environmental impact Assessment Regulations
2000
PEPA 1997 Pakistan Environmental Protection Act 1997
SLGO 2001 Sindh Local Government Ordinance 2001
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I. INTRODUCTION
1.Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to
provide a multi-tranche financing facility (MFF) to facilitate investments to support the
proposed Karachi Mega City Sustainable Development Program (KMCSDP, the
Program). The KMCSDP will implement a number of subprojects within seven
components including: support to institutional reform and development; waste supply
and wastewater management; urban roads, traffic and transportation; improvement of
katchi abadi (squatter settlements) and assistance in housing for the poor; public
awareness and outreach; investment program management and engineering support.
2.This Initial Environmental Examination (IEE) presents the environmental assessments
of the water sector subprojects in Tranche 1 of the MFF. This IEE has been carried out to
ensure that the potential adverse environmental impacts are appropriately addressed in
line with ADB’s Environmental Policy (2002) and Environmental Assessment Guidelines
(2003). This IEE has also been prepared to meet the requirements of the GoP for
environmental assessment.
3.This IEE is submitted to ADB by the Government of Sindh on behalf of City District
Government Karachi (CDGK) and this report will be submitted for review and approval
by the Sindh Environmental Protection Agency (SEPA) as required by the Pakistan
Environmental Protection Act, 1997, as regulated.
A Overview
4.The ultimate objective of the water sector subprojects of the KMCSDP MFF is to
improve the supply of potable water to the residents of Karachi. It is intended that by
supporting the development goals defined in the Karachi Master Plan 2020, the quality
of water supplied will be improved and additional supplies will be provided.
5.To achieve these objectives, an integrated, long-term package of investments and
support programs have been developed. These initiatives include governance, financial,
and institutional reforms; developing new sources of water; improved transmission and
distribution systems and minimizing system losses. Tranche 1 subprojects include
expansions of NEK and COD Hills filtration plants, and construction of two water
transmission mains from Pipri to Korangi and Pipri to Malir Town. If there are more water
sector distribution line projects included in later Tranches the KMCSDP MFF it they may
have a similar conceptual design to Tranche 1 subprojects or sector may involve more
complex environmental assessments. and therefore the potential of the later stages of
the MFF to adversely affect the environment. The construction of Tranche 1 subprojects
project within the existing rights-of-way (RoWs) for water supply infrastructure is unlikely
to have any major significant impacts but will create some disruption in the construction
stages. An IEE is required for all MFF subprojects under ADB and the EMP of the IEE
aims to mitigate all the reasonably foreseeable impacts. The EMP must be updated later
before construction starts and reviewed periodically as the project proceeds in order to
take account of any unanticipated impacts for the Tranche 1 subprojects. A detailed
environmental assessment and review framework (EARF) procedure has been prepared
that must be followed as required by ADB for all the subprojects in future tranches.
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B Environmental Regulatory Compliance

6.Section 12(1) of the Pakistan Environmental Protection Act 1997 requires that “No
proponent of a project1 shall commence construction or operation unless he has filed
with the Federal Agency2 an initial environmental examination or, where the project is
likely to cause an adverse environmental effect, an environmental impact assessment,
and has obtained from the Federal Agency approval in respect thereof.”
7.The Pakistan Environmental Protection Agency Review of Initial Environmental
Examination and Environmental Impact Assessment Regulations, 2000 (IEE-EIA
Regulations 2000) provide the necessary details on the preparation, submission, and
review of the IEE and the environmental impact assessment (EIA). The regulation
categorizes the projects on the basis of anticipated degree of environmental impact.
Project types that are likely to have significant adverse impact are listed in Schedule II of
the regulations and require an EIA. Projects that are not likely to have significant
adverse impact, are listed in Schedule I and require an IEE, provided that the project is
not located in an environmentally sensitive area3. Water supply schemes and treatment
plants are included in both schedules, those with investment smaller than PKR 25 million
(about US$ 0.4 million) require an IEE and larger projects require EIA. As the cost of
individual subprojects exceeds PKR 25 million, an EIA should be required to meet the
regulatory requirement of GoP.
8.The National Environmental Quality Standards is applicable to any process emission
or effluent from the site. Whereas no such emission or effluent is envisaged from the
water transmission pipes some emissions and effluents ca result from the operation of
the water treatment facilities.
C Environmental Category of Water Sector Subproject

9.Under ADB’s Environmental Assessment Guidelines (2003) the Tranche 1 subprojects
are Category “B” and require IEE.
D Objectives and Scope of IEE

10.The objectives of this IEE were to:
i) Assess the existing environmental conditions in the areas where the water
sector subprojects are located including the identification of environmentally
sensitive areas;
ii) Assess the proposed activities, identify and evaluate the potential impacts and
determine their significance;
iii) Propose appropriate mitigation measures that can be incorporated into the
proposed activities to minimize any adverse impacts, ensure that residual im-
1 Defined as “any activity, plan, scheme, proposal or undertaking involving any change in the environment
and includes-(a) construction or use of buildings or other works; (b) construction or use of roads or other
transport systems; (c) construction or operation of factories or other installations; (d) mineral prospecting,
mining, quarrying, stone-crushing, drilling and the like; (e) any change of land use or water use; and (f)
alteration, expansion, repair, decommissioning or abandonment of existing buildings or other work roads
or other transport systems, factories or other installations.
2 The Ministry of Environment, Government of Pakistan has delegated the power of the Federal
Agency for EIA and IEE reviews for projects falling in different provinces to the environmental protection
agencies of the respective provinces. Federal Agency in this case is the sindh Environmental Protection
Agency.
3 Sensitive areas are listed on the Federal EPA website and periodically updated.
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pacts are acceptable and propose monitoring and planning of future projects
in this sector in Karachi.
11.This IEE is based mainly on secondary sources of information and field
reconnaissance surveys. Public consultation was also undertaken.
E Report Structure
12.Following this introduction this report contains seven more sections including (ii)
description of water sector subprojects; (iii) description of the environment; (iv)
environmental impacts and mitigation; (v) public consultation; (vi) institutional
requirements and environmental management plan; (vii) findings and recommendations;
and (viii) conclusions.
13.Photographs of the project area are in Appendix A. The environmental management
plan matrix is presented in Appendix B. The Asbestos Management Framework is
included as Appendix C.
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II. DESCRIPTION OF WATER SECTOR SUBPROJECTS
A Background
14.The National Water Policy provides the overall context for the development of water
supply schemes. The vision of the national water policy is that: “By the year 2025,
Pakistan should have adequate quantity as well as quality of water, equitably distributed
to meet the needs of all users through an efficient management, institutional and legal
system that would ensure sustainable utilization of its water resources. Water has to
support economic and social development with due consideration to the environment,
quality of life, economic value of resources, ability to pay and the participation of all
stakeholders.”
15.The National Drinking Water Policy aims at ensuring “safe drinking water to the entire
population at an affordable cost in an equitable, efficient, and sustainable manner”, and
“reduction in the incidence of mortality and morbidity caused by water borne diseases”.
Water Supply to Karachi

16.According to the Karachi Master Plan 2020 (KMP), the current water supply for
Karachi comes from two sources: 646 million gallons per day (mgd) from Indus River
and 60 mgd from Hub River.
17.The supply is not sufficient to meet the requirements of the city which is estimated at
820 mgd4. It is therefore not possible to have water supplied for 24-hours, 7-days a
week, at a pressure that is sufficient to raise water to taps at a normal height at the
ground level of a building. Due to this shortfall, water is supplied to various localities on
‘schedule’ for a fixed duration every day.
18.The filtration plants in Karachi have the capacity to filter only about 60% of the total
supply. The existing filtration plants and their capacities are as follows:
i) COD Filter Plant (115 mgd)
ii) Pipri (New) Filter Plant (50 mgd)
iii) Pipri (Old) Filter Plant (50 mgd)
iv) NEK (Old) Filter Plant (25 mgd)
v) NEK (New) Filter Plant (100 mgd)
vi) Hub Filter Plant (80 mgd)
vii) Gharo Filter Plant (25 mgd)
19.The 100 mgd additional water from K-III project which was commissioned in March
2006 is not being filtered; it is only chlorinated and disinfected. Thus there is a 184 mgd
shortfall in treatment capacity.
Water Distribution
20.According to the KMP, Karachi has a water distribution system that is on average
40years old. A large part of it is in an advance state of disrepair due to corrosion,
leaking, blockages, and breaking down of distribution pipes. As the system is in many
places buried several feet below the ground surface due to repeated construction of
4 Calculated from the data provided in the KMP
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roads and streets, repairing the dilapidated system is not possible or at least technically
very difficult.
21.The piped delivery system is buried and often located near underground sewers. The
system is pressurized for short periods (not more than few hours) every day. The
repeated pressurization and depressurization creates stress on the pipes and
accelerates the wear and tear. It also draws contamination into the pipeline system from
the surrounding ground.
22.The losses in the water supply and distribution system are estimated to be 40% by
the KMP. This includes 25% technical losses and 15% unaccounted water loss. Some
sources have estimated the losses to be even much higher.
23.Water is also distributed in Karachi from water tankers, operated by private owners
and government agencies. These tankers obtain water from hydrants operated by
Karachi Water and Sewerage Board (KWSB) and from groundwater supplies.
Operational Issues
24.KWSB is an integral department of CDGK responsible for providing water to Karachi.
KWSB operates a large water supply system that lags behind, similar systems in other
modern world-class cites, in every respect. It is therefore relevant to appreciate the key
issues in water supply management for Karachi.
25.There is no metering of water at the source or at the consumer. This has resulted in a
severe lack of reliable data for planning purposes. The figures for water supply,
distribution, and losses are based on indirect estimates. Thus there are numerous
inconsistencies that make it difficult to undertake an accurate assessment.
26.There is a large gap between the water that is supplied to the city and the water for
which consumers pay. The gap is explained to a large extent by:
i) Operational losses (leakages, evaporation, seepages);
ii) Theft and pilferage through illegal connections;
iii) Inaccurate estimates of water supply and distribution; and
iv) Inefficient billing and collection (collection represents only 60% of the billing).
27.As the paying consumers, make payment on a flat rate irrespective of the actual
consumption of water there is no incentive for water conservation.
28.There is no concerted effort or program to recycle water. Even in the few places
where it is recycled, there are no guidelines on the quality of water that can be used for
various purposes. E.g. the safety of vegetables grown on the treated water from the
SITE wastewater treatment plant has been questioned on many occasions.
Water Quality
29.Many studies have been undertaken on the quality of water provided to the citizens of
Karachi. Studies repeatedly conclude that the quality of water does not meet the water
quality standards of the World Health Organization. In one such study undertaken by the
Aga Khan University, faecal contamination, as indicated by coliform bacteria, was found
in 335 out of 338 samples5.
5 Reported in the KMP.
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B Criteria for Site and Route Selection
Filtration Plant Extensions

30.There are obvious operational and financial advantages in locating the new filtration
plants within the boundaries of the existing plants. Apart from convenience in inter-
connection with the existing system, the availability of land at these sites that has been
designated for this purpose is a major advantage.
Pipeline Route
31.In selecting routes for the water transmission mains the overall aim was to identify the
shortest route that avoids land acquisition and resettlement. Internationally recognized
criteria were used to guide the selection of the pipeline route.
i) Government agencies and local communities were consulted.
ii) The route was selected that follows existing pipeline corridors and conduits of
KWSB or passes under government-owned and maintained roads that are not
occupied by the community for any other purpose.
32.The selected locations of the filtration plants and transmission main’s pipeline route
are shown in Figure 1.
C Description of Components
33.The water sector subprojects include the following components:
i) Filtration Plant Extensions at COD Plant.
ii) Filtration Plant Extensions at NEK Plant.
iii) New Transmission Mains from Pipri to Korangi.
iv) New Transmission Mains from Pipri to Malir Town
v) Development of a rolling program of Network Improvement Programs in spe-
cific supply zones to provide 24/7 (24-hours-a-day, 7-days-a-week) supply.
34.The four water sector subprojects are described in the following sections. Selected
photographs of the project area are included as Appendix A.
Filtration Plant Extensions at COD and NEK Plants

35.The subprojects address the problems of the lack of treatment capacity which means
that currently water supplied through the K-III raw water delivery system enters the
distribution network untreated. Increased treatment plant capacity is an immediate
investment need and the subprojects will (a) assist the KWSB to build a new 100 mgd
filtration plant at the Old NEK site, and (b) to expand the capacity of the existing COD
Hills filtration plant by 84 MGD.
36.The proposed treatment systems at both locations will involve the construction of
clarifiers and rapid sand filtration units. Treatment processes include:
i) Water clarifying
ii) Rapid gravity filtration with inline coagulation, and
iii) Disinfection by chlorination.
37.The filters will be accommodated in two blocks of 90 m x 40 m in the case of both the
COD plant and NEK plants, with a central galley of 6 m width housing a control building.
The arrangements and design will be similar to those of the existing plants. Following
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chlorination the treated water will gravitate to treated water reservoirs and from there via
transmission mains to the distribution network.
New Transmission Mains from Pipri to Korangi and Malir Town

38.In order to provide more equitable distribution of treated water from the Pipri
treatment plant to areas of the city which are currently poorly served, it is proposed to
provide transmission mains from Pipri to (i) Korangi Industrial Estate and (ii) Malir Town.
The proposed investments are:
i) Provision of approximately 20 km of water transmission main from Pipri Treat-
ment Plant to Korangi Industrial Area.
ii) Provision of approximately 25 km of 36" diameter water transmission main
from Pipri Treatment Plant to Malir Town.
Distribution Network Improvement Programs

39.Investment in Distribution Network Improvement Programs will initially involve data
gathering and pilot implementation of technical solutions, replacement and rehabilitation
of distribution mains and service connections, implementation of District Metering Areas
(DMAs), and customer metering to monitor the situation. The first tranche “distribution
network improvement program” (DNIP) subproject will identify and isolate a zone where
the water supply can progressively be improved by zonal and individual metering
combined with distribution network optimization and targeted leak detection and
correction, progressively raising the pressure in the system and thus improving the
quality and reliability of service offered.
D Projects Implementation Schedule

40.The planning, design and construction of the filtration plants is scheduled to be
completed within 36 months.
41.The distribution main from Pipri to Korangi will be completed within 12 months. This
period includes project planning, design and construction.
42.The preparation and approval of PC-1 for new distribution main from Pipri to Malir
Town is in progress. The pipeline will take 12 months to install after approval of the
PC-1.
43.Improving the water distribution system is an immediate investment need. Distribution
System Data Gathering and Pilot Improvements projects would lay the basis for future
distribution improvement projects. This project could be implemented as an extension of
the current “System Strengthening Project” and would commence immediately after the
commencement of Tranche 1 subprojects.
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Figure 1: Water Sector Subprojects
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III. DESCRIPTION OF ENVIRONMENT
A Environmental Profile of Karachi
Physical Environment
44.Topographically ridges, plains, and the coastal belt are the dominant topographic
features of the Karachi. The main features include ridge and runnel upland in Sindh
Kohistan, piedmont colluvial fans and peneplains, north of Karachi, moidan and Gadap
Plains, plains and Plateau of Malir-Lyari Interflous, plains and Hills of the Coastal Belt.
45.Pakistan has 15 seismo-tectonic regions.6 The proposed project is located in the
seismo-tectonic region of the Southern Kirthar Ranges, where a moderate level of
activity is believed to exist, but large magnitude earthquakes are rare. The Building Code
of Pakistan7 places Karachi in Zone 2 corresponding approximately to Intensity VII of the
Modified Mercalli Scale of 1931.8 The peak ground acceleration values in the Zone 2
according to the Building Code of Pakistan ranges from 0.08 to 0.16 g. Thus every
construction in this zone should be designed to withstand the load corresponding to
ground acceleration value of about 0.2 g.
46.There are no significant natural freshwater sources in Karachi. Almost the entire
freshwater needs are met by surface waste sources located outside Karachi, i.e. the
Indus River (about 120 km to the east of the city) and the Hub River (a perennial stream
that originates in Balochistan) that marks the boundary between Karachi and
Balochistan.
47.The Lyari and Malir Rivers that pass through the city do not have any natural flow,
except during the monsoons. Lyari River that passes through the western Karachi, rises
in the northeastern part of the Karachi district and is joined by smaller natural drains
within the city limits. The Malir River rises in the northeast of the city and flows through
the eastern part of the city. Outside the monsoon season flows in these rivers are more
or less completely formed by municipal sewage and industrial effluent discharges that
flow into the rivers and tributaries as they traverse the city.
48.Groundwater resources in the Karachi area are limited. The aquifers close to the
coastal belt are mostly saline and unusable for domestic purposes. The aquifers near
the Hub River bed, estimated to lie at depths of 50-100 m, are well developed and are
source of water for agriculture and other domestic purposes. The main potential sources
of groundwater pollution in Karachi are the unlined drains carrying contaminated waste
from the industries. Similarly, the drains and the domestic and industrial waste in the
Malir and Lyari rivers can also potentially seep through the river beds and reach the
groundwater aquifers.
6 Quittmeyer, R. C. 1979. The Seismicity of Pakistan and Its Relation to Surface Faults in Geodynamics of
Pakistan. Quetta: Geological Survey of Pakistan.
7 Government of Pakistan. 1986. Building Code of Pakistan. Islamabad: Ministry of Housing and Works,
Environment and Urban Affairs Division. A revised version of this document is under development and is
likely to be available soon, however, a draft could not be reviewed at the time of writing of this report.
8 Unlike earthquake magnitude, which indicates the energy a quake expends, the Modified Mercalli
Intensity Scale of 1931 is designed to describe the effects of an earthquake, at a given place, on natural
features, on installations and on human beings. It has 12 divisions, using Roman numerals from I to XII.
I is the mildest—described as: ‘Not felt except by a very few under especially favorable circumstances’—
and XII is the most severe—‘Damage total. Waves seen on ground surfaces. Lines of sight and level
distorted. Objects thrown upward into the air.
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49.The climate of the Karachi can be broadly classified as moderate and which lies in
‘Subtropical Double Season Coastland zone’9. The characteristic features of this climatic
zone are moderate temperatures, afternoon sea breezes in the hot season, and higher
temperatures in the period from July to January than January to July, in spite of the
monsoon-rain.
50.At present, monitoring of urban air pollution in Pakistan is limited to isolated studies
and instances where air pollutants are measured for brief periods at selected locations.
Urban locality, city, region, or countrywide continuous or repeated air quality monitoring
data has not been collected. Similarly, there is no formal system of air quality data
storage and reporting. Whatever air quality data is available is with the public and private
organizations and agencies that conducted the studies. The integrity of air quality as well
as the availability of ambient air quality data are important concerns.
51.A study on emissions of vehicular traffic was conducted by Transport and
Communication Department (TCD), of the CDGK to evaluate the impact of operation of
vehicular traffic on physical, living and social environment of Karachi10. The study was
based on sampling undertaken at 28 different locations throughout Karachi. The results
are presented in Table 1.
Table 1: Ambient Air Quality in Karachi (µg/m3)
Maximum Minimum Average WHO Guidelines and

Targets11
Sulfur Dioxide 110 16 57 500 (10-minute)
20-125 (annual)
Nitrogen Oxides 489 17 199 40 annual
200 1-hr
Particulate Matter Less 490 40 243 20-70 annual
than 10 micron 50-150 24-hr mean
Ozone 92 10 35 100-250 8-hr mean
Source: TCD CDGK All units ugm-3
52.The air quality study also included measurement of roadside noise. The study
suggested that the average noise level at the 28 locations was 77dB(A). The maximum
was recorded as high as 99dB(A), the minimum level was 52dB(A). By comparison with
the World Bank Guidelines the measured levels are much above guideline acceptable
limits of 55dB(A) during the day for residential areas and 70dB(A) for industrial and
commercial areas.
Biological Environment
53.Pakistan can be divided into four phytogeographical regions based on similarity of
floral diversity. Karachi falls in the Saharo-Sindian region. This region covers almost 80%
9 Shamshad, K.M. 1988. The Meteorology of Pakistan. Karachi: Royal Book Company.
10 Feasibility Study and Development of Transportation Control Plan of Karachi. Prepared by Pakistnn
Space and Upper Atmosphere Research Commission for Transport and Communication Department,
City District Government Karachi. 2007.
11 For severla parameters, WHO now sets guidelines and also interim targets. Wherever a range is
provided, the first number is the guideline value whereas the second is first interim target value.
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of the country including all of Sindh, central and southern Punjab, most of Balochistan
and the plains of Northwest Frontier Province. Floristically the Saharo-Sindian region is
considered very poor because despite the large area only 9.1% of the known 5,640 floral
species of Pakistan are found in this region12. The natural flora is sparse and mostly
xerophytes in the west and northwest areas of the city. However, marine phytoplankton
and mangrove forests are in relative abundance at the coast.
54.Several species of reptiles, birds, and terrestrial mammals are found in the city,
wherever suitable refuges and habitats are found. The beaches and coast of Karachi are
home to an abundance of marine fauna, such as birds, rare reptiles, fish, and marine
mammals. Karachi also falls in the Indus Flyway, one of the major migration routes for
birds. Karachi coast becomes the winter home and even breeding ground for many
species of birds. There are 26 mammal species reported from the region, in which 2
species musk shrew and pigmy shrew are considered to be the rare species.
55.The reptiles and amphibians found in the Karachi include 4 species of land snake, 8
species of marine snake, 10 species of gecko, the Indian sand swimmer, the Indian
monitor lizard and 5 species of frogs. All these species are widely distributed across the
region13.
Social and Cultural Environment

56.Karachi is the capital of the province of Sindh, and the largest city in Pakistan. The
metropolitan area along with its suburbs comprises one of the world's most populated
areas that spreads over 1,000 square kilometers14. The city credits its growth to the
mixed populations of economic and political migrants and refugees with different
national, provincial, linguistic and religious origins, many of whom have come to settle
permanently.
57.The population of Karachi in the 1998 census was reported as 9.86 million, an
increase of 80% from the 1981 census (see Table 2). The present estimate of Karachi
population in the Master Plan is 16.4 million.15 This demonstrates that the population
growth rate has increased from 3.6% per annum in the 1981-98 period to 5.8% since
1998. Part of this phenomenal growth can be explained if the population of Karachi was
under-reported in 1998. The Master Plan estimates that the population in 1998 was
actually 11.335 million. This gives an annual growth rate of 4.42% in the 1981-1998
period and 4.2% since then. According to the Karachi Master Plan, the population of the
city is expected to reach 27.6 million by 2020, almost double that of 2005.
58.The female-to-male ratio in the Karachi population 100:117, as compared to the
national figure of 100:109. Of the total population 37.6% are under the age of 15 years
and 58% are between 15 to 50 years of age. In comparison, the national figures are
42.4% and 44.6%, respectively. These numbers are reflective of the high migrant
population in the city who come here often leaving their families behind in order to earn
their living.
59.Approximately 22% of the present day population consists of migrants. The ethnic
configuration of the metropolis shows that 48% people are Urdu speaking. 14% of
12 Nasir, Y. J. and A.R. Rubina. 1995. Wild Flowers of Pakistan. Karachi: Oxford University Press.
13 Hafiz Ur Rehman and I. Fehmida. 1997. A Revised checklist of Reptiles of Pakistan. Records
Zool. Sur. of Pak. Vol. XIII. Zoological Survey Department of Pakistan.
14 The Karachi is divided into 18 towns. The total areas of these towns is 3,530 square kilometers.
This includes the urban areas, as well as the rural areas.
15 The estimates of current population of Karachi vary by a large margin. Even the website of CDGK,
report three different figures ranging from 14.7 million to 20 million.
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Karachites are Punjabi speaking, 11% speak Pashto, 7.2% speak Sindhi, 4.3% speak
Balochi and Seraiki is spoken by 2.11% of the population.
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Table 2: Population of Karachi
Source Year Population (‘000) Annual Growth Rate

Population Census Organization 1981 5,438 4.96%
1998 9,856 3.56%
Karachi Master Plan 1998 11,335 4.42%
2007 16,401 4.19%
Sources: 1981 District Census Report of Karachi Division, 1981 District Census Reports of five
districts of Karachi, Karachi Master Plan 2020
60.Literacy rates have constantly increased in Karachi, with substantial reduction in

male-female literacy gap. The overall literacy rate in 1998 was 67.4%, including 62.3%
literacy for women. The Pakistan Economic Survey 2005-06 reports that the gross
enrolment rate (GER) in Karachi for the primary schools (age 5-9) is almost 100%.
Furthermore, the GER at the metric level in Karachi is at 79% during the period 2004-05,
and the overall literacy rate of the population (10 years and above) in 2004-05 was 78%.
There will thus be a large population ready to enter the work force in a decade or so
requiring employment opportunities.
B Environmental Conditions of Proposed Sites
COD Filtration Plant

61.The COD Filtration Plant site is located on a low hill within 1km of the National
Stadium. The proposed site is located within the existing plant boundary of COD Hill
filtration plant. No new land will be required. The COD plant boundary is surrounded by
the residential area. The site can be accessed from three different main roads and is
shown in Figure 2.
NEK Filtration Plant

62.The NEK Filtration plant is located in suburbs of Karachi, about 5km from the newly
built bulk fruit and vegetable market on the Karachi-Hyderabad Highway (the Super
Highway). The proposed site for the new plan is located within the existing plant
boundary of NEK filtration plant. No new land will be acquired. There are no residential
settlements within 1km of the existing plant. The site can be accessed from the Karachi-
Hyderabad Highway and Karachi Northern Bypass. There are a few farm houses and
human settlements along the access road to the proposed site which is shown in
Figure 3.
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Figure 2: COD Filtration Plant
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Figure 3: NEK Filtration Plant
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Pipri-Landhi Pipeline
63.The proposed main will be laid parallel to the existing KWSB main distribution main a
and installed in the existing RoW. No new land will be acquired. The RoW from the Pipri
plant to the National Highway passes through sparsely occupied agricultural farms in
otherwise barren land. After crossing the National Highway (the crossing will be via
horizontal boring (trenchless technology) to avoid damage to the road surface and
interference with the traffic flow). The proposed route will then run parallel to the highway
towards Quidabad. Leaving the highway at Nagaria Chowrangi, it will be routed towards
Landhi industrial area. Here it will be laid under the existing road due to non availability
of space on either side of the road and the absence of a median. The last few hundred
meters of the pipeline will pass underneath a narrow street. The proposed pipeline route
is shown in Figure 4.
Pipri-Malir Pipeline
64.The proposed main will be laid parallel to KWSB’s existing pipeline route therefore
there will be no new land acquired. Most of the proposed RoW is located away from
residential areas. After crossing the Malir River the main will be laid under the existing
roads through Damlotte, and Khokhrapar to the Saudabad pumping station. The
proposed pipeline route is shown in Figure 5.
C Land Use around the Proposed Filtration Plant Sites and Pipeline Routes
65.The land use bordering the WTP sites within a 200 m circle around the centre of the
filtration plant facilities is shown in Table 3. All the lands nearby the NEK plant are not
occupied. The majority of the nearby land uses to the COD plant are occupied and are
potentially noise sensitive receivers or have human population that could be at risk from
chlorine release.
Table 3: Land Use Distribution for Filtration Plants

Land Use COD Plant NEK Plant
Residential and Commercial 62%
CDGK Facilities 30%
Public Buildings 3%
Parks 3%
Roads, tracks, others 2%
Empty plots 100%
66.The land use bordering the distribution mains is shown in Table 4. The land nearby
the Pipri Malir distribution main is mainly agricultural, river bed or empty lots and
therefore not occupied by a human population. About 20% of the land has residential
and commercial occupants along the existing roads through Damlotte, and Khokhrapar
to the Saudabad pumping station along which the new WDM will be installed. This area
is therefore potentially sensitive.
67.The land nearby the Pipri Landhi distribution main is more mixed with mainly
industrial uses, open land or empty lots that would not be considered sensitive. The
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remaining 20% of land uses are mixed industrial/residential or residential/commercial

and those areas are also therefore potentially sensitive.
Table 4: Land Use Distribution for Pipelines

Land Use Pipri-Landhi Pipeline Pipri-Malir Pipeline
Residential and Commercial 6% 19%
Agricultural 44%
Industrial 39%
Open plots/mix use 20%
Residential/industrial 14%
River bed or banks 19%
Empty plots 21% 18%
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Figure 4: Pipri to Landhi Pipeline
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Figure 5: Pipri to Malir Pipeline
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IV. ENVIRONMENTAL IMPACTS AND MITIGATION
68.This section discusses the potential environmental impacts of the proposed

subprojects and identifies mitigation measures to minimize the impacts in the design,
construction and operational phases. The main issues relate to impacts such as noise
dust and traffic during construction and operation.
A Design Related Impacts and Design Principles

69.The proposed filtration plants at the two sites are expected to adopt a standard
design. However the detailed layout for the sites is not yet available therefore a review of
this IEE must be undertaken at the detailed design stage. As described in Section II, the
sites have been selected within the boundaries of existing water treatment plants thus
avoiding any land acquisition.
70.For the transmission mains, the key design-related environmental impact relates to
the selection of the pipeline route and the removal and disposal of the old transmission
pipes.
71.As described in Section II, the alignments will adopt the routes used by the existing
water mains that will be replaced. This route selection will avoid land acquisition and
resettlement.
72.The following design principles will be presented to the design engineers by CDGK at
the commencement of their design commission.
73.The specific design mitigation measures for the treatment plants are as follows:
i) Wherever possible the design concept shall permit the maximum use of prefab-
ricated materials in order to minimize construction impacts.
ii) The ground surfaces within the perimeter of the filtration plants will be sealed or
landscaped and planted in order to minimize dust emissions.
iii) The design will be reviewed by the DOE and environmental cell prior to the fi-
nalization of the design to ensure that all environmental requirements are being
met and the layout option will allow mitigation of environmental impacts to an
acceptable level. This will include sufficient set backs from the potentially noisy
or hazardous installations to the nearest sensitive receivers.
iv) Create and retain an adequate buffer zone of non development around the
pumping and treatment plants as needed to alleviate noise and other possible
nuisances to neighboring properties and to protect the water treatment facilities
from damage by outsiders.
v) Create and an adequate buffer zone of non development around the pumping
and treatment plants and design all facilities to accommodate requirements of
best practice design standards and codes of practice to protect against acci-
dental leakage of chlorine gas. The design of the chlorine storage and distribu-
tion system which must meet international standards in line with ADB policy on
should follow strict design standards and codes of practice.
vi) The IEE and EMP (Appendix B) will be revised and updated at implementation
to take account of any new, modified, increased or unexpected impacts.
vii) Noise and dust mitigation measures will be reviewed once the detailed layout
has been finalized and the mitigation measures will be revised and the EMP
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updated to take account of any new, modified, increased or unexpected im-

pacts.
viii) Trees will be planted along the boundaries of the filtration plant outside the
perimeter wall to create an enhancement and minimize the visual impact of the
facilities.
74.The specific design mitigation measures for the pipelines are as follows:
i) The pipeline route will adhere to existing pipeline RoW. If the RoW of existing
water transmission pipe lines cannot be followed for some unforeseen reason
this IEE and the accompanying EMP (Appendix B) and mitigation measures will
be reviewed and revised accordingly to take account of any unforeseen im-
pacts and minimize them to acceptable levels.
ii) A survey of all existing services and other utilities — power, gas, telephone,
sewerage, and fiber optic cables — will be undertaken during the detailed
design stage for the pipelines and if there is a conflict, the pipeline will be
rerouted and appropriate revisions to the IEE and EMP will be made.
iii) The detailed designs and costing will make provisions for the realignment and
re-provisioning of other utilities where necessary and work together with and
obtain approval from the authority for all utilities on the routing and construction
methods for the new pipelines. The aim will be to reduce disruption of services
to the absolute minimum.
iv) Where water supply has to be interrupted, for justifiable technical reasons, pro-
visions will be made for temporary supply by tanker or other suitable means.
The alternative supply shall be substantial and regular and sufficient to provide
for the population it must serve for the duration of the loss of piped supply. The
contractor will be required to reinstate the water supply as soon as practicable.
v) Wherever possible the design should be conceptualized to permit the maxim-
um use of prefabricated materials in order to minimize construction impacts
and speed up the installation and re-commissioning process. Non-asbestos ce-
ment pipes shall be installed for the new water distribution main and old asbes-
tos cement pipes shall be removed and disposed of under controlled conditions
in line with asbestos management framework (Appendix C).
vi) The ground surfaces excavated for the installation shall be resealed in order to
minimize dust emission. Surplus excavated earth will be stockpiled and reused
for landscaping or disposed of as required by the construction supervision con-
sultant.
vii) The design will be reviewed by the DOE and environmental cell prior to the fi-
nalization of the design and disclosed to SEPA to ensure that all environmental
requirements are being met and the layout option will allow mitigation of envir-
onmental impacts to an acceptable level. The IEE and EMP will be revised and
updated to take account of any new, modified, increased or unexpected im-
pacts.
viii) Noise, dust and odor mitigation measures will be reviewed once the detailed
layout has been finalized and the mitigation measures will be revised and up-
dated to take account of any new, modified, increased or unexpected impacts.
75.A key design issue for the transmission mains is that the old asbestos cement pipes
(ACP, that are estimated to be present in more than 35% of the distribution system) may
in some cases need to be repaired in which case they shall be replaced with non-
asbestos materials such as UPVC or other synthetic non-asbestos materials. Retaining
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or replacing the old ACP with new ACP would not be an environmentally responsible
procurement option and not be consistent with ADB Environmental Policy 2002. As a
special feature of this MFF an asbestos management framework (Appendix C) has been
developed in tandem with this IEE to provide guidance to CDGK and KWSB on how to
manage the excavation, handling, transport, storage and disposal of ACP from the water
subprojects and any other subprojects in Tranche 1 and future tranches which may
involve asbestos containing materials.
76.In some jurisdictions it has been noted that contractors may seek to pay money for
nuisances rather than control impacts at source. This practice should not be allowed and
financial compensation shall not be allowed as mitigation for environmental impacts or
environmental nuisance.
77.Based on professional experience and the linear nature and likely narrow working
spaces that will be available in some areas for the WDM it can be expected that the
contractor(s) will claim that there is insufficient space to set up mitigation measures
anywhere along the working construction route. Based upon observation it is not credible
that there is no space for any mitigation on the whole of Tranche 1 WDMs. It is not
acceptable that there are no opportunities to use the recommended forms of mitigation,
albeit that there may be some places where modifications to the mitigation measures
proposed in the EMP may be needed to minimize impacts within the available space.
78.During the preparation for the WTP and WDM construction phase the future
contractors must be prepared and primed to co-operate with the implementing agency,
project management, supervising consultants and local population in the mitigation of
impacts. Furthermore the contractor must be primed by including the EMP and
environmental assessments in the tenders and contract documentation. The
requirements must fully implement the EMP and the contractor must be ready to engage
capable and trained environmental management staff to audit the effectiveness and
review mitigation measures as the project proceeds. The effective implementation of the
EMP should be audited as part of the loan and payment conditions and the executing
agency must be prepared for this. In this regard the CDGK (the Implementing Agency)
must also prepare resources to fulfill the requirements of the law and guidance prepared
by federal and provincial EPAs on the environmental aspects of water sector project16
B Construction Related Impacts
Planning the Construction Works

79.Contractual clauses should be included to require each contractor to produce draft
management plans at least one month before construction commences. Contractors
tenders shall be required to separate clearly the resources and funds to be applied to the
mitigation measures for environmental impacts and to have written plan. Contractors
tenders shall identify named staff to supervise and plan the following:
i) Drainage and utilities re-provisioning;
ii) Temporary traffic management;
iii) Noise and dust control;
iv) Waste management;
v) Tree removal and compensatory planting; and
vi) Compliance with asbestos management framework.
16 Pakistan Environmental Assessment Procedures: Sectoral Guidelines Water Supply Schemes,

1997.
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80.Contractual clauses shall be included to tie the implementation of environmental

mitigation measures in the above plans to milestone payments. Contractual clauses
shall also require Contractors to conduct special induction briefing and / or on-site
training for the contractors management, contractors staff, subcontractors and workers
to cover the environmental requirement of the project. Contractors shall record and
report regularly on attendance and achievement for all staff and managers.
81.Contractual clauses shall be included to require contractors to employ dedicated
environmental management staff to conduct/oversee the environmental orientation
sessions and the implementation of environmental mitigation measures so as to facilitate
checking for milestone payments.
82.Contractual clauses shall emphasize that financial compensation shall not be allowed
as mitigation for environmental impacts or environmental nuisance without written and
environmentally justifiable agreement from the relevant environmental authorities.
83.Engineering controls shall be proposed in the firat place by the construction
contractors and shall be designed as mitigation measures to control the impacts at
source in the first place. The CSC shall be responsible to approve the measures and
report the update of EMP.
Cut and Fill

84.The completion of the WDP will require extensive shallow cutting and filling all along
the RoW to excavate the trenches in which to lay the distribution mains. At this stage the
removal of about 1m deep trenches will require at least 40,000 m3 to be cut. A reuse
plan for these materials needs to be identified in the detailed design phases and
included in the amended EMP in due course.
85.Balancing cut and fill requirements can be a major contribution to the minimization of
impacts. If surplus materials arise from the removal of the existing surfaces these may
be used elsewhere on the project for fill before additional rock, gravel or sand extraction
is considered. The use of this immediately available material will minimize the need for
additional rock based materials extraction and this also needs to be identified in the
detailed design phases and included in the amended EMP in due course.
86.The detailed designers will need to estimate the additional materials that will be
required. Works should be planned and scheduled to facilitate the timely production of
rock, gravel and sand materials for construction and to avoid the need for excessive
stockpiling and importing from elsewhere in the districts that will be affected by this
subproject.
87.The detailed design engineers should produce a materials management plan for the
materials needed for the construction works. The mass haulage requirements can later
be modified to good effect by the contractor to produce a materials management plan
(MMP) including mitigation for the extraction of materials, to specify (i) the methods to be
employed prior to and during construction, (ii) all other measures to be employed to
mitigate nuisances to local residents, and (iii) any additional measures such as
compensatory planting; if trees have to be removed. The MMP should be updated
regularly and reported monthly as a contract requirement for each contractor to monitor
the production and use of materials. The construction supervising consultant (CSC) shall
be made responsible for updating and reporting the cut and fill estimates in the MMP.
The MMP can then be used to plan for bitumen and aggregates management and to
facilitate materials exchange between the subcontractors in different areas along the
WDM routes, and to provide an overall balance for bitumen and cut and filled materials
and also to minimize impacts on other local resources outside the RoW.
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Replacement of Trees
88.Trees should be retained and maintained wherever possible, but there are several
locations where trees may need to be removed or roots trimmed. Wherever possible the
detailed designs should position the works to avoid and keep these trees in place and
intact. The detailed designers should conduct a detailed tree survey in order to identify
tree locations and position the new distribution mains well away from trees. There may
be a need to remove some trees but only as a last resort, which should be justified in
writing and sanctioned by the CRC before felling. Where trees have to be felled,
mitigation will be required in the form of reinstatement and compensatory planting. Soft
landscaping should be installed to improve the appearance of the completed works.
Other opportunity spaces should be sought by CDGK to plant trees as near the locations
of the WTP and as near the felled tree as possible. The contracts drawn up by CDGK for
the WTP and WDM should require that wherever possible the trees are transplanted for
use elsewhere in the project (e.g. amenity areas / parks). After removing the existing
trees and top soil (down to 0.5 m), the topsoil shall be retained for elsewhere in the
project. The cut wood shall not be burned on site. All stumps and surplus vegetation
shall be disposed of at landfill via routes or other destinations as designated and
instructed by CDGK or the CSC.
89.Recent international practice suggests that replacement at a minimum rate of 3:1 for
trees would be appropriate given possible difficulties with establishing trees and low
survival rate of young trees. This would probably be affordable. However most recent
international guidelines indicate a replacement rate of at least 7:1. Also in some
countries that rely on forestry resources for livelihood replacements rates have recently
been increased to 25:1. Therefore it is important to recognize that some significant part
of the replacement ratio should allow for a high mortality rate among the newly planted
trees based on observation, international expectations, and advice from the CDGK parks
authority.
Dust Impacts during Construction

90.Among the variety of options to control dust emissions from construction sites the
most effective is wet suppression. Sprinkling water on exposed surfaces and soil with
adequate frequency to keep soil moist at all times can reduce the total dust emission
from the project by as much as 75%. 17 The following mitigation measures will be
implemented at each site during construction to control emission of particulate matter:
i) Water will be sprinkled daily on all exposed surfaces sufficient to suppress
emissions of dust. The frequency of sprinkling will be increased as necessary
but controlled such that the surface remains just moist at all times, particularly
when wind is blowing towards any nearby sensitive receivers.
ii) Dust emission from soil and aggregate storage stockpiles will be reduced by ap-
propriate measures. These will include: (a) covering the pile with tarpaulin or
thick plastic sheets when not in use and at the end of the working day; (b) erect-
ing windshields / walls on three sides of the piles such that the walls project 0.5m
above the top of the pile and (c) keeping the material moist by sprinkling of water
at appropriate intervals, to prevent emissions.
iii) All roads within the pipeline routes that are to be excavated will be reinstated and
repaved as early as possible after the completion of construction work. Until the
roads are paved, they will be sprinkled regularly to prevent dust emission.
17 El Dorado County Air Pollution Control District. 2002. Guide to Air Quality Assessment:
Determining Significance of Air Quality Impacts Under the California Environmental Quality Act. First
Edition.
http://co.el-dorado.ca.us/emd/apcd
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iv) The construction vehicles will maintain a speed limit of 20km/h or less on all un-
paved areas within the construction route and the access route for the duration of
the construction. Speed limit signposts will be erected in highly visible positions
along the access road and within the route and maintained for the duration of the
construction.
v) Construction materials will be transported to the route and around the route in
trucks securely covered with tarpaulins or equivalent to prevent dust emission
during transportation.
Noise During Construction

91.Noise nuisances can be minimized by various measures. Outside schools or
hospitals construction timetable shall be discussed with the occupiers and work should
be avoided at sensitive times. As fall back option to control noise hoardings using heavy
thick ply-board or corrugated metal sheet to achieve a mass of >10kg/m2. Design and
works layout must allow pedestrians to cross roads or pass around or over sites and
avoid community severance. The installation of such measures should be discussed with
the local population and serve as a means for further public consultation during
implementation and assist in public relations.
92. All heavy equipment and machinery shall be well maintained and fitted in full
compliance with the national and local regulations. As a rule, the operation of heavy
equipment shall be conducted in daylight hours unless agreed otherwise with local
residents.
93.Construction equipment, which generates excessive noise, such as compressors,
jack-hammers shall be enclosed to prevent noise release. Well-maintained haulage
trucks will be used. The contractor shall also maintain and service all equipment to
minimize noise levels.
94.Performance criteria during nighttime (10 pm to 7 am) shall be the measured impact
noise at the residential or hospital sensitive receiver shall not be more than 3dB above
background noise levels measured at the nearest sensitive receiver (Leq15minutes) two
weeks prior to the commencement of works. The contractor shall also maintain and
service all equipment to minimize noise levels.
95.Near places of worship and schools the contractor shall discuss with the CSC and the
school and mosque principals the agreed time for operating the noisy machines and
completely avoid machine use near schools during examination times and near
mosques during religiously sensitive times. Large concrete building components shall be
prefabricated near the concrete batching plants or in controlled dedicated areas away
from SRs to minimize impacts.
96.Noise will be reduced in the construction by a) preventing as far as possible
construction work during night time 21:00hrs to 06:00hrs within 300m of sensitive
receivers; b) prevention of blowing of horns by the project vehicles except in
emergencies; c) use of powered mechanical equipment that is acoustically insulated to
reduce noise impacts; d) tuning and proper maintenance of construction equipment and
vehicles.
97.The contractor shall be allowed to take other acoustic measures to minimize noise
nuisance in the vicinity of construction sites to achieved the necessary noise attenuation
to keep within the noise criteria. The contractor may obtain guidelines for noise reduction
from ISO/TR11688-1:1995(e), which enumerates methods by which air-borne, ground–
borne and structure-borne noise sources may be curtailed with suitable design criteria.
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Asbestos Management
98.The old pipelines will be exposed during the detailed design phase and samples
taken to determine if they contain asbestos cement sections. If the old pipeline material
or parts of it are made from asbestos containing cement, the waste materials will be
handled under controlled conditions removed and prepared for disposal as required
under the asbestos management framework (Appendix C) in conformance to the ADB’s
Environmental Policy (2003) and the Environmental Guidelines (2003). The AMF
(Appendix C) is a special feature of this MFF. The AMF will guide CDGK in the
preparation of the asbestos abatement practices that will mitigate environmental
liabilities associated with asbestos. The AMF is an integral part of the IEE and EMP that
will facilitate contractor’s compliance of asbestos-related measures in the
implementation stage. CDGK will employ and Asbestos Specialist to supervise the
selection of capable contractors and prepare the necessary contractual requirements
and monitor the implementation of the asbestos abatement mitigation measures as
specified in the AMF and report to ADB for all Tranches of the MFF.
Other Issues Related to Pipeline Construction

99.The proposed pipeline will be within the existing RoW and government lands.
Therefore, no acquisition of private land is anticipated. Temporary impacts are however,
anticipated. Temporary disruption to hawkers and vendors is possible during laying of
water pipelines. However, this is not considered significant, as there is ample space at
the side of the roads where the hawkers and vendors can temporarily move back off the
construction line.
100.The potential issues of pipeline construction include traffic congestion and a
temporary traffic management plan shall be submitted by the contractor at least one
month before construction commences and approved and properly resourced by CDGK
before construction commences.
101.The WDM routes are mainly major of traffic corridors. Construction activities along
these routes are likely to cause hindrance in traffic flow if not mitigated properly. A
temporary traffic management plan will be developed and submitted by the contractor at
least one month before commencement of construction. The main objectives of the plan
shall be to maximize the safety of the workforce and the traveling public. The main
secondary objective will be to keep traffic flowing as freely as possible.
102.The Temporary Transport Management Plan will include consideration of the
following
i) Lane availability and minimize traffic flows past the works site.
ii) Establish acceptable working hours and constraints.
iii) Agree the time scale for the works and establish traffic flow/delay requirements.
iv) Programming issues including the time of year and available resources.
v) Acceptability of diversion routes where necessary.
vi) Need for road closures and the necessary Orders.
vii) Co-ordination with other planned road and street works.
viii) Discuss the CDGK inspection/monitoring role.
ix) Discuss establishment of incident management system for duration of the
works
x) Agree publicity / public consultation requirements (advance signing etc.).
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103.The plan will be reviewed by CDGK and approved, if found appropriate. Resources
from contractor, CDGK, and the traffic police will be provided as per the plan before
construction commences.
Public Safety
104. Public safety, particularly of pedestrians can be threatened by the excavation of the
trenches for pipeline construction. Project safety plan shall be submitted by the
contractor and properly resourced at least on month before construction commences
and approved by CDGK before construction commences. The plans shall include
provisions for site security, trench barriers, reflective signs and covers to other holes,
hoarding plans and any other safety measures as necessary.
105.Public safety, particularly of pedestrians can be threatened by the excavation of the
trenches for sewer construction. A safety plan will be submitted by the contractor and
properly resourced at least one month before construction commences and approved by
CDGK before construction commences. The plans will include provisions for site
security, trench barriers, reflective signs and covers to other holes, hoarding plans and
any other safety measures as necessary.
106.It is also recommended that a contingency plan shall be in place before construction
commences to cover emergencies in the case of damage to other infrastructure such as
wastewater collection and drainage system, water distribution lines, power cables etc,
especially when the works are near utilities serving hospitals.
107.With the thorough identification of all utilities and correct planning for rerouting and
re-provisioning there should be no damage to other infrastructure such as wastewater
collection and drainage system cables etc. However in order to cover any unforeseen
disruption or disaster the contractor and to see through the plans effectively it is
recommended that CDGK convene a project utility re-provisioning coordinating
committee to meet with the contractor(s), PIU and representatives of all utilities to
anticipate and plan works on a six weekly basis (twice per quarter).
C Operational Impacts
108.No major operational related environmental impacts are expected from the
subprojects. Some minor impacts may include malfunctioning of plant and pipe bursts
that might cause hardships to communities but these will be dealt with by the routine
emergency procedures and . Maintenance works causing disruption of traffic will need to
be coordinated with the traffic planning authorities.
109.Disposal of sludge and wastewater from the water treatment such as the clarifiers
and filter wash water are two waste streams of water treatment plants treating surface
water. These can contain high concentrations of organic pollutants and solid particles
entrained in raw water. It is relatively difficult and expensive to dewater the sludge
because of its high specific resistance due to alum. Alum can be recovered from sludge
while the sludge can be disposed of in large lagoons or eventually into the sanitary
landfills when they become operational.
110.The new water treatment plant is likely to use chlorine gas for disinfection of treated
raw water. Chlorine is applied for the deactivation of microorganisms. Being a cheap
process, it is one of the most commonly used methods for water disinfection. Chlorine is
stored in the water treatment plant as pressurized gas in steel cylinders.
111.Chlorine is used as a standard disinfectant in all water treatment plants in Karachi.
However, it has not been possible to identify any written operational plan for clorination
or water monitoring. It is entirely possible that due to operational and economic reasons
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the chlorination may not be very well monitored but as yet no information is available on
the specifications for chlorination.
112.Chlorine is a skin irritant and an asphyxiating toxic gas that has a very strong odor.
The odour threshold for chlorine varies between individuals but is estimated to be
between 0.2 to 0.4ppm. USEPA has established an environmental air limit of 0.5 ppm.
Exposure to higher levels could result in discomfort and irritation. The occupational
safety limit for chlorine is 1ppm for eight hours. Short-term exposure to 30 ppm or more
of chlorine gas can result in chest pain, vomiting, coughing, difficulty breathing, or
excess fluid in the lungs. Exposure to 430ppm in air for 30 minutes will cause death.
113.The chorine related risk during plant operation includes accidental release and
exposure of plant workers and, in the worse, case exposure of the community. Although
the probabilities are low, during the handling of storage cylinders and their piping
connections, the potential exists for an accidental leak and resulting release of chlorine
gas. To minimize the risk of adverse impact on the workers and communities an
operational plan will be developed for refilling and routine maintenance and emergency
plan will be developed and put in place. Regular surveillance shall be conducted to
check for chlorine leaks using grab sampling and chlorine indicator tubes.
114.KWSB has a laboratory in Karachi for testing of raw water, treated water and water
supplied to the consumers. There are facilities to test all commonly measured water
quality parameters. The consultants have not been able to identify any information on
the frequency at which water is tested or what parameters are checked. There is no
regular reporting of the water quality to public. However some testing is apparently
undertaken if there is a complaint or when there is a problem. In the absence of
complaints it is assumed that water quality is acceptable. Some independent tests
conducted by some organizations that claimed that the water supplied to the citizen is
overwhelmingly contaminated. KWSB position is that there is no contamination at the
distribution head. The contamination (mainly biological) enters the water due to
damaged distribution system. There is no independent verification of whether the
supplied water is free of contamination or not, however, the distribution system certainly
appears to be the source of contamination. To address this problem, one option is to
rehabilitate the entire distribution system. This project is the one of the first steps in this
process.
115.The water served in distribution systems may therefore be polluted or contaminated
due to (i) fluctuating pressures due usually to excessive leaks in the distribution system
causing seepage of pollutants/contaminants into pipes, (ii) inadequate operation and
maintenance (O&M) for filters and chlorinators and (iii) lack of chlorine residual
monitoring in distribution systems.
116.Raw water quality may also be unsatisfactory caused by excessive total dissolved
solids, chlorides, nitrates, fluorides, and other contaminants present at concentrations
above acceptable limits and which cannot be removed by feasible treatment processes.
There could also be excessive pathogenic pollution and excessive mineral constituents
(iron, manganese, color, hardness, and turbidity).
117.Therefore the EMP has included the need for a competent Water Quality O&M Plan
with monitoring of the relevant parameters to address these problems. KWSB must also
make operational plans to introduce 7-days-a-week, 24-hours-a-day, water supply to
prevent depressurizing of distribution system which results in ingress of contamination.
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D Beneficial Effects
118.The key benefits are the provision of treated water to the communities and the
monitoring of water quality. This will lead to improvements in hygiene, health,
environment and sanitary conditions and consequent savings due to overall
improvements in environmental health. Other enhancements can be made through tree
planting, removal of the dilapidated asbestos water pipe system and the introduction of
better management practices for construction contracts.
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V. STAKEHOLDERS CONSULTATION
119.The objectives of the stakeholder consultation process was to disseminate

information on the project and its expected long-term and short-term impacts among
primary and secondary stakeholders, and to gather information on relevant issues so
that the feedback received could be used to address these issues at an early stages of
project design. Another important objective was to determine the extent of the negative
impact of different project activities and suggest appropriate mitigation measures.
A Identification of Stakeholders
120.Stakeholders are people, groups, or institutions that may be affected by or can
significantly influence, or are important to the achievement of the stated purpose of a
proposed intervention.
121.Group meetings were held along the two pipeline routes and around the COD
Filtration Plant. There are no communities in the vicinity of the NEK Filtration Plant to
consult. A total of 62 persons were consulted. The consultation locations are shown in
Figure 6.
B Consultations
122.The results of the public consultations are summarized below. The details are
recorded in Table 5.
Meetings with Residential Consumers

123.Group meetings and individual meetings were held with various residents of Korangi
residential areas and Malir Residential Areas.
124.People complained of shortage of water and welcomed the laying of new pipeline. A
figure of Rs700 was reported as the amount that the residents are paying for water from
tankers. Water quality was also reported as a common concern. Some people have
boreholes in their houses but the water is brackish.
125.Several respondents complained of the disruption that takes place during the
construction activities on large public projects. Other than delays on the road, the
blockages also cause the public buses to take alternate routes forcing the commuters to
walk longer distances to catch the buses.
126.The dust from the construction activities and spoil banks was cited as a cause of
concern as it affects the business of the roadside vendors such as fruit sellers. The
residents were concerned about the diversion of traffic to smaller roads and streets that
increases the risks of accidents.
127.Other issues raised by the commuters included the alteration or potential blocking of
storm water run-off and disruption of utilities.
Landhi Association of Trade and Industry

128.The Association was represented by its secretary in the consultation. He highlighted
the problems that are faced by the industries when development work takes place. He
cited the example of the fly-over that is under construction in Landhi. According to him,
other than the disruption in traffic, the construction also resulted in damage to the
sewerage lines, telephones system and other utilities. He suggested that a) alternate
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routes should be provided for traffic; b) coordination between the civic agencies should
be improved; and c) the industries should be involved in monitoring and evaluation.
Korangi Association of Trade and Industry

129.Consultation was undertaken with the Secretary of the Association. He claimed that
there is acute shortage of water for the 2,500 industrial units in Korangi. Industrial units
are also purchasing water from tankers. Some units also have water bores to extract
groundwater.
Urban Resource Centre

130.Mr Arif Hassan of the Urban Resource Center gave detailed opinion on the
problems of Karachi water supplies and provided valuable suggestions. His discourse
emphasized that recovery of the losses (that according to him are of the order of 40%)
should be a priority instead of introduction of new supplies. He also suggested that
desalination of subsoil water should be considered as an option.
131.On planning and research aspects, Mr Arif Hassan suggested that detailed
documentation of existing system should be produced. He proposed that uninformed
decisions, taken in absence of research and consultations, were the main cause of
failures of projects. In his opinion, each individual project should be component of a
larger master plan and the complete component should be implemented. Further, the
planning should be based on research and mapping not on intuitions and public
demand. He also suggested decentralization of water supply and the introduction of bulk
water metering at UC levels.
132.Other problems that he mentioned included the poor institutional capacities,
constant political interference, and poorly paid staff that causes inefficiencies.
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Figure 6: Location of Public Consultations
29/03/08 Page 37 of 101

Table 5: Summary of Public Consultation
No. Town Name Participants Address Date Issues Raised/Concerns Expressed/Suggestions Action Taken/Proposed
and Requests/Measures Proposed
1 Korangi Shah June 7 Delays in project, “We do not expect any new project Institutional capacity
Jahan, will complete in less than 7 years” building, organizational and
Waliullah, management structure to
Dust during construction and due to incomplete
Sartaj Khan ensure sound project
restoration is the major problem that the community
management and prevent
and shopkeepers will face
delays, obstructions, and
Access to the shops, industries, and residential areas services utility disruption
will be blocked.
Most of the existing traffic will be diverted into the
residential areas which will result in the congestion of
traffic in the streets and may pose hazards of
accidents to the community especially to the children.
Road from Hussain Chorangi to the graveyards is
already blocked due to construction activities which
has also resulted in the blockage of sewerage
The commuters have to walk for 1 to 3 kilometers each
day to reach to the nearest bus due to this blockage.
Buses also take alternative longer routes which takes
additional time.
Telephone cables of the community are damaged
during construction activities which take months for the
relevant department to fix. There is no coordination
among the departments within the government.
The storm water drainage system is disturbed during
construction and due to incomplete restoration.
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2 Landhi Azra, Housewives Sherpao June 11, 2007 No comments -
Zaitoon, Colony
General discussion on lack of water, health facilities,
Jano,
poor sanitation, transportation problems, and
Parveen,
deteriorating road network.
Nasara,
Khari, Concerns about the existing excavations for road
Nazra, construction and the associated hazards for the
Jamala, community particularly children.
Rukhsana,
Mushtari,
Nazara,
Tasleem,
Meena Gul,
Robina,
Sahzia,
Shazia,
Mazerat,
Nishad
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3 Urban Arif Hassan A-2, 2nd 40% losses to be recovered first before introducing
Resource Floor, West new supplies. Even 20% recovery will give more
Centre Land Trade water. More planning required on each project before
Centre final decisions.
Commercial
Subsoil water desalination is one of the options. Bulk
Central Area
water metering should be introduced at UC levels.
Karachi
Administra- A detailed documentation of existing system should be
tive produced. Uninformed decisions taken in absence of
Cooperative research and consultations will lead project to the
Housing failures. Each individual project should be component
Society of a larger master plan and the complete component
Block 7&8, should be implemented. Planning should be based on
Shaheed-e- research and mapping not on intuitions and public
Millat Road, demand.
Karachi
The current project if it is done will have not problems
in becoming successful.
Decentralization of water supply. Better institutional
arrangements would be required. System is poor but
easy to rectify. Constant political interference create
hurdles in implementation. Staff is inefficient because
they are badly paid.
Contamination is not necessarily on source it might be
in the distribution system. There is contamination
proven even in treated water. Contamination happens
from sewerage and subsoil water.
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4 Landhi Mukhtair Sellers of Sherpao June 10, The excavation of the road is an obstacle to our Institutional capacity
Ashraf fried fish, Colony 2007 business building, organizational and
Shahjee salad, Tikka, management structure to
The blockage of roads compel the people to shift their
Shamso Haleem, ensure sound project
way
Khan juice, ice, management and prevent
Fayyaz burger, People stop buying from our stalls as ours is directly delays, obstructions, and
Faheem kheer, paan, affected and affects our income services utility disruption
Naeem food,
Saeed chicken
Asad meat,
Ismael biryani, and
Raj fruits (last
Mutabar two)
Shah Wali
5 Landhi Syed Homeo- June 11, 2007 If once a road excavated it takes years to carpeted Institutional capacity
Rahim pathic again building, organizational and
Shah doctor, social management structure to
The development work damages telephone lines,
activist ensure sound project
drainage system, gas line and water pipe lines
services utility disruption
6 Landhi Ismael Dry fruits Sherpao June 11, 2007 The roads repair after long interval of time Institutional capacity
and juice Colony building, organizational and
When roads had been excavated some years ago, the
seller management structure to
public hesitated in buying from us due to the dust
ensure sound project
Traffic jams were observed in the area management and prevent
Proposed pipe lines/ excavation of might resulted the services utility disruption
same what experienced in the past
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7 Landhi Moin Burger shop Sherpao June 11, 2007 The excavation of roads will affect our business Institutional capacity
Colony building, organizational and
Dust would cover everything in the area. Very few
management structure to
would like to eat in the presence of dust
ensure sound project
8 Landhi Khaista Gul Burger shop Sherpao June 11, 2007 No comments -
Colony
9 Korangi Nehal Secretary, There are 2500 industries in Korangi industrial area, Improve water quality
Hassan Korangi these industries face acute shortage of water and management (WQO&M
Association sewerage problem. There is no water in some areas. Plan)
of Trade and
Water is contaminated
Industry
Industries facing excessive bills for water charges
Association has been recording daily 15-20 complains
on water issues
Survey for water is desperately needed and important
task because industries purchasing water from tanker
suppliers. It is increasing the production cost. PKR
1800 is being paid per tanker in the Korangi industrial
area. There is a private hydrant in the Korangi
industrial area (at Chamra Chowrangi).
Underground water available at 10ft. Some industries
prefer boring instead of purchasing water from water
tanker suppliers
29/03/08 Page 42 of 101

10 Landhi Ali Sher, Factory Zorash Fresh water is available for drinking in the factory Improve water quality
Akber, workers Towel management (WQO&M
Drinking water is purchased from tanker suppliers
Shabir and Factory Plan)
Shabir Boring water is being used in the factory for industrial
purposes
There is no connection of water in the factory
11 Korangi Tasleem Bilal Colony There is no running water. Water shortage persisting -
and others for a year. We are purchasing water for PKR 700 per
tanker. If we use brackish water, it result in itching and
skin diseases. Two families (13 persons) use half
tanker of water in about a week (about 2.5 tankers per
month).
We have to boil the water to drink. We use to pay
PKR 500 for water charges to city. There was
agitation for water in which all of us participated. We
are ready to pay for water charges if good service is
available.
in this street 3-5 house using water getting from boring
but the water is brackish.
12 Tanker 5 times come to supply water to this street Improve water quality
Supplier management (WQO&M
/driver A water tanker is supply 1600 gallon water
Plan)
13 Water Water is being supplied from Gulzar colony Improve water quality
supplier management (WQO&M
A drum (container ) of water is being sold for PKR 30
(Donkey Plan)
cart driver)
14 Khalid Boring Water is available at 80ft but it is brackish. We charge Improve water quality
Mechanics PKR 60 for per ft of boring. management (WQO&M
Plan)
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15 Fatah Khan Bilal Colony There are 700-800 household in Sector A of Bilal Improve water quality
(Sector B) colony. There is a acute shortage of water in the area. management (WQO&M
Sewerage system and roads are in poor condition. Plan)
In the past water had been supplied for 2 hours on
daily bases, then it was reduced to 10 minutes. Even
this water was contaminated.
Water for sector A is being supplied form industrial
area while for sector B water is being supplied from
Awami colony
16 Korangi Mr Nehal Secretary, There are 2500 industries in Korangi industrial area, -
Hassan Korangi these industries face acute shortage of water and
Association sewerage problem. There is no water in some areas
of Trade and and where it is available it is contaminated.
Industry
Industries are facing excessive bills for water charges.
The Association records 15-20 complaints daily on
water issues alone.
Survey for water is desperately needed and important
task because industries purchasing water from tanker
suppliers. It is increasing the production cost. PKR
1800 is being paid per tanker in the Korangi industrial
area. There is a private hydrant in the Korangi
industrial area (at Chamra Chorangi).
Underground water available. Some industries prefer
boring instead of purchasing water from water tanker
suppliers
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17 Faiz Ahmed watch maker Bilal Colony There are 1000 plot in Sector A mostly occupied by -
(Sector A) industrial workers with income PKR 3,000-15,000.
The colony was established in 1972. Plots consist of
80 and 240 sq yards. There are also many illegal
constructions.
Water shortage started 3 years ago. Now the city is
also sending us water bill. Six month ago I received a
bill of 25000 for last 15 years. We ready to pay for
water but the charges should be rational.
Water is providing after a gap of 4 days 10 minutes
only. We supplement this water by brackish water that
is brought in drums by our children. Some boil the
water before use.
18 Sawar Bilal Colony Ina nearby locality, about a month ago 3 people died of Improve water quality
Khan, water disease caused by some chemicals were found management (WQO&M
Akhter Ali, in the water. Plan)
M Shafiq
19 Zafar Iqbal Bilal Colony No comment on the project.
20 Rahim Bilal Colony No comment on the project. -
Khan
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21 Landhi Mr Rashid Deputy June 2, 2007 Government do not provide any alternate route while Institutional capacity
Association Secretary development work carried out. We are facing a lot of building, organizational and
of Trade problem from the fly over build near Younaus Brother management structure to
and (YB) Textile. ensure sound project
Industry management and prevent
The sewerage system is destroyed, telephones are
dead
The industrial wastewater is not properly discharged
because the wastewater lines are blocked
Before the construction of fly over meetings were held
with authorities but in vain. Even Mohmmad Ali Tabba
(owner of YB textile) tried his best to avoid the wreck
but failed.
Work on the proposed pipe line should not begin
unless the fly over at Quaidabad and on railway line
near Younaus Brother not completed. According to
plan the Quaidabad the fly over must be completed in
June. It seems that 3-4 month more required
accomplishing the task. The fly over near YB will
required more time to complete.
We need better management and more coordination
Although we have been informed before the
development work yet we not involve in monitoring and
evaluation
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22 Gulshan Major (Rtd.) Residents Shanti Sept 13, 2007 People of the area express that they do not expect any Institutional capacity
Ali Mirza, and Nagar, adverse impact on the community because the land is building, organizational and
Qazi Business- Dalmia, UC inside the boundary of KWSB management structure to
Iftikhar, men 6, Gulsahn ensure sound project
After the completion of construction government
Abdash Block 18 and management and prevent
should ensure that no water is stolen
Deho, Nisar 19 delays, obstructions, and
Chandio, Traffic movement during construction should be services utility disruption
Abdullah managed and that heavy traffic should not add to the
existing worst condition especially during afternoon
Abdur
and evening timings in the streets. .A designated
Rasheed
route should be specified avoiding narrow streets to
Noorani
ensure the minimized risk of accidents and to minimize
the disturbance due to noise and dust
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VI. INSTITUTIONAL REQUIREMENTS AND

ENVIRONMENTAL MANAGEMENT PLAN
A Institutional Requirements
133.Environmental regulations of the GoP require proponents of projects that have
reasonably foreseeable qualitative and quantitative impacts are required to submit an
IEE for their respective projects (Schedule I). Proponents of projects that have more
adverse environmental impact (Schedule II) are required to submit an environmental
impact assessment (EIA) to the respective provincial Environmental Protection Agency
(EPA). Water supply and treatment facilities costing more than PKR 25 million require
and EIA and those costing less than 25 million require and IEE. Whereas the impacts for
these projects are very manageable no IEE has been submitted by CDGK for any other
similar water sector project. However CDGK has submitted an IEE and had approved by
EPA for one of the waste transfer stations at (Gulshan-e Iqbal) but not under this MFF.
That project would be fairly similar to the NEK and COD plant improvements. Therefore
it can be expected that the environmental assessment requirements for NEK and COD
plants may not be to exacting. However it is also noted that all four water sub-sector
projects will exceed the Rs25 million EIA threshold / trigger.
134.It has also been noted that in another ADB MFF project, Pakistan EPA has assumed
that all proponents will consult with the relevant provincial EPAs (PEPA) and follow their
advice with regards to environmental assessment requirements for all MFF subprojects.
In 2006 Punjab EPA requested disclosure of the scope and extent of each of the
subprojects in ADB Power Transmission Enhancement MFF. As such it is expected that
all the Tranche 1 and subprojects in future tranches will be disclosed to the SEPA and
the environmental assessment requirements of the statutory authority will be followed.
An Environmental Assessment and Review Framework (EARF) has also been prepared
to select, assess, monitor, and manage the potential environmental impacts of any
subprojects in future tranches.
135.Therefore prior to implementation and commencement of construction of the
treatment plants and pipelines subprojects, CDGK will need to notify the provincial EPA
(SEPA) of the location and scale of the subprojects and comply with any environmental
requirements and, if IEE is required, obtain approval “No Objection Certificates” and
PEPA clearance (under the Environmental Protection Act 1997). Whatever the SEPA
requirements, IEEs must be prepared for All components for ADB. CDGK will also need
to liaise and coordinate with SEPA. The EMP (Appendix B) was prepared taking into
account the capacity of the CDGK Municipal Services Department, as described in the
Institutional and Environmental Assessment of SEPA and City District Government of
Karachi18.
136.In September 2007, Municipal Services of CDGK had one full time environmental
staff member, the District Officer Environment (DOE). The DOE is responsible for
addressing environmental concerns for a citywide development program. The DOE took
charge of his post and department in February 2007. The DOE therefore faces
considerable challenges in implementing the terms of reference. Other problems have
been identified with the lack of capacity in SEPA but these are not the subject of this IEE.
18 Institutional Appraisal of Environmental Assessment and Management Capability within Sindh

Environment Protection Agency (SEPA) and City District Government of Karachi (CDGK), TA 4573 PAK,
Preparing the Karachi Mega City Development Project, September 2007.
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137.At present DOE is responsible for overseeing several key functions that relate to
environmental assessment and management. These were previously under the
jurisdiction of the Law Department but were transferred to the DOE. The environmental
responsibilities of CDGK are defined under the Sindh Local Government Ordinance
2001 (SLGO 2001) and there is a general requirement to raise environmental awareness
in the CDGK jurisdiction. The key elements directly relevant to the implementation of the
MFF subprojects can be summarized as follows:
i) To ensure implementation of environmental protection and preservation meas-
ures in all development projects at district level and sensitize government
agencies on environmental issues (that can be achieved by following the
EARF);
ii) To assist provincial EPA in discharge of its functions under the Pakistan Envir-
onmental Protection Act, 1997;
iii) To ensure, guide and assist proponents of new projects in the submission of
IEEs and EIAs to the Director General EPA Sindh for approval;
iv) To request the Environmental Magistrate or Environmental Tribunal to take cog-
nizance of any offence under the provisions of PEPA 1997;
v) To undertake regular monitoring of projects financed from the provincial sus-
tainable development fund and to submit progress reports to the DG FPA Sindh
for publication in its annual report.
138.At present the DOE is alone within the CDGK with sole responsibility for brining
environmental issues to the notice of corporate management (District Coordination
Officer, DCO and City District Nazim). The most significant challenge is the lack of
human and financial resources and necessary infrastructure. In 2006, the Governor of
Sindh made a call to establish a separate environment department in the face of growing
national and international environmental concerns. The DOE has made a proposal for a
separate environment department to the District Coordination Officer (DCO) but as of
September 2007 there is no change to the existing CDGM departmental structure.
139.If the terms of reference stated in the SLGO are to be realized then overcoming
environmental capacity deficit within the CDGK will need to be addressed.
Environmental assessment and coordination with SEPA are both key to CDGKs
environmental responsibilities under the SLGO. However although proposals have been
made to address this shortfall in environmental capacity by DOE, a response in terms of
adequate additional human and financial resources may not materialize for some time.
Therefore there is likely to be a period at the start of the KMCSDP MFF when DOE has
insufficient resources to carry out the environmental assessment requirements for ADB.
The lack of appropriate institutional arrangements may interfere with the KMCSDP
attempts to ensure compliance with both GoP and ADB environmental assessment
requirements. Therefore it is recommended that the KMCDSP provide an environmental
cell of at least two full time environmental specialists to support the DOE and remain in
support until such time as the proposed Environmental Department is created or
sufficient other resources are made available to DOE in CDGK and the proposed EDO
Environment is fully capable of supporting the environmental assessment portfolio of
CDGK. At such a time the appointed environmental cell professionals may be absorbed
into the EDO Environment in order to retain institutional memory.
140.The EDO will need more staff and training resources if effective quality control is to
be provided for the EMP implementation and much of the environmental assessment
work may be delegated to consultants. The aspirations of the SLGO objectives, to raise
awareness both within Municipal Services Department and more broadly in CDGK, are
sound, but at present the awareness level is not high. Specific areas for immediate
29/03/08 Page 49 of 101

attention are in environmental assessment and auditing, waste, air, water and noise
pollution management and impact mitigation. As a first step CDGK should consolidate
DEO as soon as possible and nominate additional suitable staff to work from within the
department to monitor and audit progress on environmental management for the MFF.
141.For the KMCSDP, the environmental cell staff, engaged to support the DEO for the
MFF subprojects, must be appointed at the outset of the implementation. At the detail
design stage of subproject the cell shall have at least one environmental specialist to
assist the DEO to address all environmental aspects in the detailed design and
contracting stages and the relevant statutory submissions and approvals. In addition,
there needs to be an environmental specialist to cover the implementation of
environmental mitigation measures in the construction stage of the subproject packages.
The environmental specialists should work as members of the environmental
management team with significant proportion of time spent in the field, observing and
making recommendations to improve or modify environmental mitigation measures
executed by the contractors, as the EMP evolves and the MFF subprojects proceed, to
respond to unexpected circumstances.
142.The requisite staff should be appointed prior to the commencement of the tendering
for the construction activities to ensure the inclusion of environmental requirements can
be translated into contractual works for completion of the pipeline and filtration plants
and also respond to unexpected circumstances. Both members of the cell can initially be
bolted on to the DEO or within supervising consultant’s team.
i) The environmental specialists will:
a) Work with DEO to execute any additional EIA and IEE requirements prior
to project commencement and review the EMP;
b) Work with the project management team(s) in CDGK to ensure all
environmental requirements and mitigation measures from the EIAs and
IEEs and environmental performance criteria are incorporated in the
contracts; and
c) Work with contractors to manage the implementation of the project EMP
(as revised).
ii) Overall implementation of the EMP will become CDGK’s responsibility. Other
parties to be involved in implementing the EMP are as follows:
a) Contractors: responsible for implementing all measures required to
mitigate environmental impacts during construction; and
b) Other government agencies: such as UC, Towns authorities, regional EPA
and state pollution authorities for monitoring the implementation of
environmental conditions and compliance with statutory requirements in
their respective areas.
143.Considering the number of government agencies that need to be involved in
implementing the EMP, training workshops should be conducted at every six months or
twice each year, for the first 3 years, to share experience in the implementation of the
subprojects and the monitoring report on the implementation of the EMP, to share
lessons learned in the implementation and to decide on remedial actions, if unexpected
or uncontrolled environmental impacts occur.
B Environmental Assessment of Follow-Up Subprojects

144.Other Network Improvement Programs, treatment plants, pipelines etc. may be
proposed in future Tranches in specific supply zones and the details will be prepared
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later. Based on the likely urban location it will be in similar location to the two treatment
plant and two pipeline subprojects considered above and a range of similar impacts is
likely. Other follow-up subprojects in the water management sector may involve more
complex environmental assessments. A detailed environmental assessment and review
framework (EARF) procedure has been prepared that must be followed as required by
ADB for all the subprojects in future tranches.
C Environmental Management Plan

145.This IEE concludes that the construction impacts will be manageable if the
mitigation measures are implemented thoroughly. The Environmental Management Plan
is based on the type, extent and duration of the identified environmental impacts. The
EMP has been prepared by close reference to best practices and in line with ADB’s
Environmental Policy (2002) and Environmental Guidelines (2003).
146.Implementation of construction of the treatment plants and pipelines will need to
comply with several environmental requirements and clearance will be required from
SEPA for environmental assessment. DOE will also need to confirm that contractors and
their suppliers have complied with all statutory requirements for licenses from CDGK.
DOE should check that contractors have all the necessary valid licenses and permits for
all powered mechanical equipment, permissions and licenses for use of powered
mechanical equipment if necessary and the use of local water supplies (and to construct
and operate plants such as concrete batching in line with all environmental regulations
and license conditions from EPA).
147.The effective implementation of the EMP should be audited as part of the loan
conditions and the executing agency must be prepared for this. In this regard the CDGK
(the Implementing Agency) must be prepared to guide the design engineers and
contractors on the environmental aspects and ADB has suggested that such leadership
and auditing should be undertaken by the DOE and an “environmental cell” from the
commencement of the MFF.
148.Prior to implementation of Tranche 1 and again before Tranche 2 the EMP shall be
amended and reviewed by the DOE and environmental cell in due course after detailed
designs are complete and contracting arrangements are known. Such a review shall be
based on reconfirmation and any additional information on the assumptions made at the
feasibility stage on location scale and expected operating conditions of the subprojects.
For example, in this case if there is additional land required for installation of facilities or
pipelines the designs may be amended and the environmental significance must be
reviewed. Although no major additional impacts would be anticipated based on the
information provided to date, the performance and evaluation schedules to be
implemented during project construction and operation can be reviewed, updated, and
costs estimates can be revised if necessary.
149.The EMP must be reviewed by the DOE and project management in CDGK and
approved before any construction activity is initiated on Tranche 1, to take account of
any subsequent changes and fine tuning of the proposals. It is recommended that this
takes place before the Tranche 1 contracts are worked out in detail and before pre-
qualification, so that the environmental status of the existing treatment plants and
pipelines is carried out as a baseline for benefit monitoring, using the EMP as the
performance indicator.
150.This IEE including the EMP should be used as a basis for an environmental
compliance program and an updated EMP should be included in the revised contract
documentation for All components. The updated EMP, any conditions of the
environmental clearance from the SEPA and any subsequent licenses and approvals
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from EPA should also be included in the environmental requirements for the contractors
in the compliance program. Therefore, continued monitoring of the implementation of
mitigation measures, the implementation of the environmental conditions from
environmental clearance, and monitoring of the environmental impact related to the
construction of all future works to complete the treatment plants and pipelines should be
properly carried out and reported periodically in monthly progress reports. Compliance
with all of the EMP requirements shall also be reported in other periodic project
performance reports.
151.The impacts from construction and operation of the subprojects will be manageable
and no insurmountable impacts are predicted providing that the updated EMP is
included in the contract documents and implemented to its full extent. The details of the
current summary EMP (Appendix) are in the form of the matrix and may require revision
as the project reaches detailed design. The impacts have been classified as per the
design/preparation stage, construction stage and operation and maintenance stage. The
matrix details the mitigation measures recommended for each of the identified impacts,
approximate location of the mitigation sites, time span of the implementation of
mitigation measures, an analysis of the associated costs and the responsibility of the
institution. The institutional responsibility has been specified for the purpose of the
implementation and the supervision. The matrix is supplemented with a monitoring plan
for the performance indicators. An estimation of the associated costs for the monitoring
is given with the plan. The EMP has been prepared following best practice and the ADB
Environmental Assessment Guidelines 2003.
D Monitoring
152.Monitoring activities during implementation will focus on compliance with license
conditions, recording implementation of mitigation measures, recording environmental
parameters, reviewing contractor environmental performance and proposing remedial
actions to address unexpected impacts during construction. Some of these tasks can be
assigned to the contractors and managed by the DOE and environmental cell. The
monitoring plan (Tables 6 and 7) was designed based on the likely subproject cycle.
153.During the preconstruction period, the monitoring activities will focus on (i) checking
the contractor’s bidding documents, particularly to ensure that all necessary
environmental requirements have been included; and (ii) checking that the contract
documents’ references to environmental mitigation measures requirements have been
incorporated as part of contractor’s assignment. Where detailed design is required (e.g.
for further elaboration of the recycling facilities at the treatment plants and pipelines) the
checking of updated designs must be carried out. During the construction period, the
monitoring activities will focus on ensuring that environmental mitigation measures are
implemented, and some performance indicators will need to be monitored to record the
subproject’s environmental achievements and to guide any remedial action to address
unexpected impacts.
154.Monitoring activities during project operation will focus on (i) volume of raw water
and treated water; (ii) volume of sludge and wastewater discharged from the treatment
plant; (iii) residual chlorine in certain sections of transmission mains; and (iv)
physicochemical and biological parameters of raw water supplied to the treatment plant.
The operation phase Environmental Monitoring Plan is provided in Table 8.
155.To facilitate EMP implementation, during preparation for construction the contractors
must be prepared to cooperate with the environmental cell team, DOE, and the local
population in the mitigation of impacts. However, experience suggests that contractors
may have little impetus or interest in dealing with environmental problems in the absence
of performance-linked criteria. Therefore, the required environmental mitigation must be
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clearly described in a memorandum of understanding and other contract documents at

the bidding stage; the completion of mitigation should be linked to payment milestones.
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Table 6: Environmental Monitoring Plan for Tranche 1 Water Sector Subprojects

No. Environmental Monitoring Tasks19 Implementation Implementation
Responsibility Schedule
1 Design Phase
1.1 Audit project bidding documents to ensure CDGK through Prior to issue of bidding
IEE and EMP is included. environmental officer documents.
1.2 Disclosure of subproject to SEPA
1.3 Monitor final site selection (alignment) and CDGK through Prior to CDGK approval
its environmental compliance with EMP environmental officer of detailed designs.
1.4 Monitor the performance of environmental CDGK through Ongoing, prior to and
training and briefings and of the environmental officer during implementation
environmental awareness of project staff of works and operation.
and CDGK
2 Construction Phase
2.1 Regular (monthly) monitoring and CDGK through Continuous throughout

reporting (quarterly) of contractor’s environmental officer construction period.
compliance with statutory environmental
requirements
reporting (quarterly) of contractor’s environmental officer construction period.
compliance with contractual environmental
mitigation measures
reporting (quarterly) of complaints and environmental officer construction period.
responses or environmental mitigation
measures
2.4 Monitor adjustments to the EMP and the CDGK through During all phases of
thorough implementation of detailed EMP environmental officer the subprojects
2.5 Commissioning phase monitoring of as CDGK through At commissioning.
built equipment and facilities versus environmental officer
environmental contractual performance
criteria
3 Operation and Maintenance Phase
3.1 Observations during routine maintenance CDGK through As per CDGK

inspections of facilities. Inspections will environmental officer inspection schedules
include monitoring implementation of
operational mitigation measures versus
environmental criteria specified in EMP for
operational impacts
3.2 Implement Water Quality O&M Plan. CDGK through During the life of the
environmental officer project
Include monitoring operational water
parameters from appropriate locations
based on the preliminary schedule shown
in Table 8.
Table 7: Summary of Estimated Costs for EMP Implementation

19 Monitoring of issues related to compensation of landowners for land acquisition and loss of
production, etc. are addressed in the Resettlement Action Plan.
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Item Sub Item Estimated Total Estimated Total

Costs Cost
[PKR] [USD]
Staffing, audit and 1 persons for 2 years 1,500,000 25,000
monitoring
Monitoring activities As detailed under EMP 16,000,000 266,700
Mitigation measures As prescribed under EMP and IEE 8,000,000 133,300
Transport 1 vehicle for 2 years 1,000,000 16,700
Contingency 4% contingency 500,000 8,300
Total 27,000,000 450,000
Table 8: Operations Phase Environmental Monitoring Plan

Parameters Frequency
Volume of
Raw water received Flow rate Daily
Treated water supplied Flow rate Daily
Wastewater discharged to Flow rate As and when generated
pond/tank
Water re-used Flow rate As and when used
Sludge generated Quantity/volume As and when generated
Dosing of
Chemicals used (quantity) Quantity As and when used
Quality of
Raw water Physical, chemical, and Monthly or when significant
biological parameters change in raw water quality is
suspected
Treated water at plant outlet Physical, chemical, and Monthly or when significant
biological parameters, residual change in raw water quality is
chlorine suspected
Treated water at the head of Physical, chemical, and One sample monthly drawn from
the distribution system biological parameters, residual different localities
chlorine
Treated water in taps Physical, chemical, and One sample monthly drawn from
biological parameters, residual different localities
chlorine
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VII. FINDINGS AND RECOMMENDATIONS
156.This IEE study was carried out when the MFF Tranche 1 subproject were at the
stage of conceptual design during the TA 4753 (PAK). Essentially secondary data were
used to assess the environmental impacts in a comprehensive manner and public
consultation and site reconnaissance were carried out in order complete the
environmental assessments and recommend suitable mitigation measures.
157.Several actions are required during the detailed design stage to minimize impacts to
acceptable levels and described in the EMP. The negative environmental impacts from
the treatment plant and pipeline subprojects will mostly take place during the
construction stage but there are also some potential negative impacts for the operational
stage as well as many significant beneficial impacts. The construction impacts should be
very predictable and manageable and with appropriate mitigation few residual impacts
are likely.
158.Some key actions are required after the detailed designs are developed. CDGK
should update the EMP and together with the IEE recommendations all mitigation
measures should be included as contractual requirements, accepted by all contractors
prior to signing the contract(s). Certain mitigation management plans (temporary traffic
management, utilities management, materials management master plan, waste
management etc.) should be deliverable by the contractors before construction
commences.
159.The construction is restricted to Government land and as far as can be ascertained
at this stage there is not likely to be any significant additional land required to complete
the construction. However given the stage of the treatment plant and pipeline designs it
is possible that some additional engineering requirements could be included at the
detailed design stage, that may require additional land. At this stage these requirements
are not quantifiable. If further land is needed it can be determined as the detailed
designs are worked out and to dovetail with the detailed design and minimize adverse
impacts and maximize benefits. A social impact assessment and resettlement action
plan has been completed in tandem with the environmental work stream that will apply to
All components.
160.At the detailed design stage a review should be conducted of the monitoring
activities proposed in this IEE for air quality, noise and water quality to establish the
parameters to be checked during the construction and operation. Reference should also
be made to the recommend monitoring plan for performance indicators (Table 6) from
this study. If necessary baseline monitoring should be carried out prior to the
commencement of construction to redefine the parameters and frequency of monitoring
to be checked during treatment plants and pipelines construction and operation.
Provisions should be made in the contract documentation to allow integration of the
results of the baseline review into the contract to establish performance action
thresholds, pollution limits and contingency plans for the contractor’s performance.
Impact and compliance monitoring activities will focus on compliance with license
conditions, recording implementation of mitigation measures, recording environmental
parameters, reviewing contractor environmental performance and proposing remedial
actions to address unexpected impacts and complaints.
161.The IEE, including the EMP, should be used as a basis for an environmental
compliance program and be included in the contract documentation. The EMP shall be
reviewed at the detailed design stage. In addition, any conditions that are part of the
environmental clearance from the SEPA should also be as a basis for the environmental
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compliance program. Therefore, continued monitoring of the implementation of

mitigation measures, the implementation of the environmental conditions for work and
environmental clearance, and monitoring of the environmental impact related to the
operation of the treatment plants and pipelines subprojects should be properly carried
out and reported monthly to track and determine the net environmental benefits that
have accrued. These should be summarized by CDGK in regular quarterly progress
reports to ADB also summarized at least twice per year as part of the ADB project
performance report. The negative environmental impacts from treatment plants and
pipelines will mostly take place during the construction. There are no operational impacts
to be addressed in the detailed designs. If the projects are managed in line with
internationally accepted environmental auditing procedures very significant
environmental benefits can be expected to be demonstrated in the operational stage.
162.The implementation of the environmental mitigation measures during the
construction period will be assigned to the contractors. However, experience suggests
that contractors may have little impetus or interest to deal with environmental problems
in the absence of performance linked criteria. Therefore, the required environmental
mitigation must be clearly described in the contract documents at the bidding stage and
the completion of mitigation should be linked to payment milestones.
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VIII.CONCLUSIONS
163.Environmental impacts associated with the construction and operation of the

treatment plants and pipelines need to be effectively mitigated and institutional
arrangements are available. Additional human and financial resources will be required by
CDGK to complete the detailed designs and incorporate the recommendations
effectively and efficiently in the contract documents, linked to payment milestones. The
proposed mitigation and management plans are practicable but require additional
resources.
164.Monitoring activities in the design and construction phase will need to focus on
compliance with IEE and EIA requirements, license conditions, recording implementation
of mitigation measures, recording environmental parameters, reviewing contractor
environmental performance and proposing remedial actions to address unexpected
impacts. Monitoring activities in the operational phase will need to focus on full
implementation of the recommended monitoring requirements in the EMP to ensure
good system performance, delivery of water of the expected quality and control of
pollution due to waste from treatment plants. The operational controls must ensure
efficient measurement of water quality parameters and recording of water, waste and
wastewater to allow and ensure feedback of results to management to propose remedial
actions to address unexpected problems and amend monitoring as necessary.
165.The water sector subprojects in Karachi are sustainable environmental options but
thorough implementation of the EMP, that includes operational monitoring, is required
throughout the construction and operation of the treatment plants and pipelines in order
to deliver quality water efficiently, minimize impacts and retain public support for the
project.
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Appendix A:Selected Photographs
Pipri-Malir Pipeline existing RoW
Pipri-Malir Pipeline existing RoW – Malir River Crossing
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Pipri-Landhi Pipeline RoW along National Highway
Pipri-Landhi Pipeline RoW along the Final Stretch
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Appendix B:Environmental Management Plan
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B.1.1 Water Treatment Plant and Water Distribution Mains - Environmental Management Plan – Matrix
Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement Implement Implement Monitor
(MM) (MM) (MM) (MM)
DESIGN STAGE
1. Project Ensure statutory Disclose WTP & WDM project and design to the SEPA Commencement All WTP and WDM Design CDGK -
disclosure compliance with and clarify what documents are required to be filed (if of detailed consultant / ADB
PEPA 1997 any) with the provincial and federal EPA to ensure design CDGK
compliance with Secion 12(1) of the PEPA 1997 (as
amended).
2. Buffer Ensure sufficient Detailed designs to assess and include appropriate Completion of All WTP & WDM Design CDGK –
distance buffer distance to layout to allow setback of noisy and hazardous detailed design. facilities consultant / ADB
sensitive installations (e.g. chlorine storage) from SRs to CDGK
receivers to prevent nuisances.
prevent nuisance
and achieve
safety criteria.
3. Subproject Ensure EMP Review IEE and EMP and confirm findings and Completion of All WTP & WDL Design CDGK –
detailed design. sufficient to recommendations. detailed design. facilities consultant / ADB
control impacts CDGK
Submit REA, revised IEE/EIA and EMP to ADB.
and compliance
with statutory Complete the environmental assessment process in
requirements line with SEPA and ADB Guidelines. Obtain waiver for
PEPA 1997. IEE from SEPA OR “No Objection Certificate” from
SEPA.
Prepare EMP and Obtain “Clearance Certificate” from
SEPA.
4. Asbestos Confirm ACP condition survey - trial pits to assess condition Completion of All WTP & WDM Design CDGK –
management provisions in and extent of ACM pipes to be removed. detailed design. facilities consultant / ADB
asbestos CDGK
Review AMF and EMP with CDGK and confirm
management
findings and recommendations.
framework are
CDGK = City District Government Karachi CSC=construction supervision consultant DDC = Detailed Design Consultant
PMU = Project Management Unit or Similar WTP & WDM = Water Treatment Plant & Water Distribution Main ACP=Asbestos Cement Pipe
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(MM) (MM) (MM) (MM)
met sufficient to Submit revised AMF and EMP to ADB.
control asbestos
Confirm AMF included in tender documents and that
waste removal
bidding contractors have capacity to comply with AMF
and disposal and
and other safety requirements.
comply with ADB
ERP guidelines.
5. Waste Ensure rapid 1. Operational waste management of sludge from 1. Detailed All WTP & WDM Design CDGK
Disposal removal of ACP clarifiers and filter wash water to be planned for by the design output. facilities consultant /
and adjacent detailed designers and agreed with CDGK. CDGK
contaminated
2. Design consultants to identify sufficient stockpiling
spoil and other 2. Within one
or disposal locations for excavated materials cut
wastes and month of award
surface materials and include disposal locations and
sufficient disposal of contract or
requirements in contracts.
space for all earlier.
wastes and 2. Before works commence selected contractor to
prevent fly- prepare Waste Management Plan with disposal sites
tipping. identified for agreement by construction supervision
consultants and CDGK.
6. Minimize To ensure that Detailed Design Consultants include in detailed design Before the 1. All WTP & WDM CDGK with CDGK
impacts due to provisions are - commence- facilities close to the Design
Water made to preserve ment of mosques, schools Consultant
1. Footbridges and overpasses to be included in
Distribution the operation of construction. and other SRs to
mobilization/preparation works to avoid severance of
Mains alignment any existing local Installations and be avoided.
pedestrian access.
designs. infrastructure and activities
2. Locations of
that utilities are 2. Existing drainage and other utilities identified and included during
overpasses and
protected. avoided /re-provisioned. design stage.
utilities to be
included in plans..
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(MM) (MM) (MM) (MM)
7. Retain trees To avoid negative 1. Detailed design to avoid tree removal unless 1. Detailed All WTP & WDM Design CDGK
and landscape impacts due to justified on engineering, safety and environmental design output. facilities consultant /
designs unnecessary grounds. CDGK.
removing of trees
2. If trees have to be removed identify of off-site
landscape opportunity spaces in liaison with local
community for planting with trees and shrubs and
spaces for compensatory planting to be included in
detailed designs.
4. Include tree protection and mitigation requirements
in tender and contract documentation as milestone
payments.
5. Landscaping with trees and shrubs shall take place
at Water Treatment Plants. Planting of
trees/shrubs/ornamental plants as enhancement.
8. Noise control Ensure noise 1. Detailed design stage, with the benefit of known 1. During Noise sensitive CDGK with CDGK
impacts are plant specifications, make acoustical assessments to designing stage locations to be the design
acceptable in determine if noise mitigation at source (noise barriers) no later than reconfirmed and consult-ant.
operational is required to prevent nuisance to sensitive receivers. pre-qualification.checked in the
phase. EMP that is
2. For schools, hospitals and temples make detailed 2. Include in the
approved by
assessment of noise climate and conduct detailed contract.
ADB/SEPA.
acoustic assessment for all residential, school, temple
(other sensitive structures) within 100m of WTP.
3. if predicted noise at sensitive receiver exceeds
agreed criterion [e.g. 3dB(A) above baseline or
leq67dB(A) if who criterion acceptable] design and
include construction of acoustic measures to control
noise at source, e.g. solid barrier to attenuate noise to
below agreed criterion at SR.
9. Water quality, To design to Detailed design engineers to prepare a competent During detailed Locations to be Design CDGK/AD
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(MM) (MM) (MM) (MM)
monitoring and minimize leaks operations and maintenance plan and monitoring plan design. identified and listed consultants/ B
Chlorine usage. and monitor of relevant water quality parameters to address in revised WQO&M CDGK
chlorine problems of delivery of contaminated water (Water Plan.
leakage/check Quality O & M Plan). Determination of
chlorine usage at critical sites and
Review strategy and policy on chlorination,
the treatment methods of
disinfection methods, continuity of supply, monitoring
plants in the monitoring.
raw water quality and delivered water quality.
operational
phase. Design chlorination system to minimize leaks in the
operational phase and during maintenance.
10.Traffic Plan to minimize 1. Avoiding blocking existing roads access near WDM During detailed The most Detailed CDGK
Condition disturbance of routes. design important locations design
vehicular traffic to be identified and engineer /
2. Design provisional temporary traffic management
and pedestrians listed in revised CDGK.
plan for updating by the construction contractors one
during EMP. Relevant
month prior to start of works in any given sector.
construction. plans and possible
3. Formulate a construction related traffic hot-spots to be
management plan that takes into account other made available to
Tranche 1 subprojects such as the Urban Traffic the Contractor with
Control System and Transport Master Plan. tenders.
4. Proximity of schools and hospitals to be considered.
5. Installation of traffic warning signs, and enforcing
traffic regulations during transportation of materials
and equipment and machinery.
7. Include plans for conducting awareness programs
on safety and proper traffic behavior near construction
sites.
8. Plan requirements to assign dedicated traffic control
personnel.
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(MM) (MM) (MM) (MM)
9. The EMP review must take into account any
changes to operational modeling assumptions that will
need to be reviewed relative to ground realities or
other changes that result from the assumptions made
in other Tranche 1 subprojects such as the
development of the Urban Traffic Control System and
preparation of the comprehensive long term Transport
Master Plan. I.e. the potential cascade of effects upon
traffic conditions at the street level resulting from the
proposals for the of Urban Traffic Control System and
Transport Master Plan must be integrated into the
WDM proposals at the detailed design stage. There is
insufficient data to make these assumptions at the
present stage.
11. Avoid operational Contractor to submit Method Statement and schedule At tender stage CSC/Tender CSC/Tender CDGK
Environmentally environmental of environmental mitigation measures with tender. and again evaluators to evaluators
responsible pollution and during product check contractors
Contractor required to include techniques and
procurement impacts upon acquisition, prior Method
machinery selection to minimize impacts and duration
decommissioning to purchase. Statements and
of works.
. proposed
Choose non polluting equipment. mitigation
measures and
Specify equipment not to contain POP, asbestos, timing.
other hazardous or toxic components.
Equipment
specifications and
performance with
company
certificates /
accreditations.
CONSTRUCTION STAGE
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(MM) (MM) (MM) (MM)
1. Plans to Avoid impacts 1. Temporary traffic management plan, Prior to To cover Contractor. CDGK.
control from unplanned construction construction of all
2. Drainage and utilities re-provisioning plan,
environmental activities activity WTP & WDM
and associated 3. Noise and dust control plan, facilities.
Submission to
impacts.
4. Waste management plan, ADB
5. Tree removal and compensatory planting plan.
6. Written agreement to follow Asbestos Management
Framework.
should all be deliverable in final form by the
contractors one month before construction
commences.
2. Loss of trees To avoid several PAYMENTS LINKED TO TREE REESTABLISHMENT One month prior All WTP & WDM Contractor CDGK/
and vegetation negative impacts NOT TREE REMOVAL- to and during facilities and where and CSC.
CSC
cover of the due to construction of more trees can be
1. Removal of trees>10cm DBH (diameter at breast
areas work- unnecessary relevant replanted for
height) to be justified on engineering and safety
areas and removing of trees activities. enhancements.
grounds in tree removal plan.
aesthetics and other street
foliage. 2. Clearing of trees for construction, cutting trees and
other important vegetation during construction should
be minimized.
3. Trees that are unavoidably to be removed for
construction shall have compensatory planting and
replacement and establishment plans for trees that
shall be approved by the CSC and agreed with
Contractor one month before existing trees are cut.
4. Payments for site clearance shall be withheld until
compensatory tree planting is complete for that sector
and payment therefore linked to tree reestablishment
not removal as one of the milestone payments.
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(MM) (MM) (MM) (MM)
5. At lease seven (7) new trees shall replace each cut
tree and maintained alive for three years as part of the
contractual agreement and milestone payments.
6. Landscaping with trees and shrubs shall take place
at all WTP stations and boundaries as an
enhancement. Planting of trees/shrubs/ornamental
plants to contribute to the aesthetic value of the area.
7. At conclusion of the project, all debris and waste
shall be removed. All temporary structures, including
office buildings, shelters and portable toilets shall be
removed.
3. Orientation Ensure that the Contractors tenders shall be required to separate Induction for all All site agent staff. Contractor CDGK &
for Contractor, CSC Contractor clearly the resources and funds to be applied to the site agents and monthly induction management to observe
and Workers and workers mitigation measures for environmental impacts above including and six month with the CSC and record
understand and all CSC staff refresher course and record success.
Contractors tenders shall identify named staff to
have the capacity new staff before as necessary until details and
supervise and plan,
to ensure that the commencement contractors report
environmental Drainage and utilities re-provisioning of work. comply/improve. quarterly.
requirements and
Temporary traffic management,
mitigation
measures must Noise and dust control, Weekly tool box
be implemented talks and
by them. Waste management, refreshers at
Tree removal and compensatory planting early stages of
construction for
Compliance with asbestos management framework. all construction
Contractual clauses shall be included to tie the employees as
implementation of environmental mitigation measures far as
in the above plans to milestone payments. reasonably
practicable.
Contractual clauses shall require Contractors to Include with
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(MM) (MM) (MM) (MM)
conduct special induction briefing and/or on-site safety talks.
training for the contractors management, contractors
staff, subcontractors and workers to cover the
environmental requirement of the project. Contractors
shall record and report regularly on record attendance
and achievement test for all staff and managers.
Contractual clauses shall be included to require
contractors to employ dedicated environmental
management staff to conduct/oversee the
environmental orientation sessions and the
implementation of environmental mitigation measures
so as to facilitate checking for milestone payments.
Contractual clauses shall emphasize that financial
compensation shall not be allowed as mitigation for
environmental impacts or environmental nuisance
without written and environmentally justifiable
agreement from the relevant environmental
authorities.
Engineering controls shall be proposed in the first
place by the construction contractors and shall be
designed as mitigation measures to control the
impacts at source in the first place. The CSC shall be
responsible to approve the measures and report the
update of EMP.
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(MM) (MM) (MM) (MM)
4. Institutional To ensure that Capacity building activities Initiate All senior staff in CDGK ADB
strengthening CDGK and PMU preconstruction CDGK at senior
Consolidation of the DOE or Setting up of an
and capacity officials are and continue engineer and
Executive District Officer (EDO), Environment Office
building trained to beyond project above in PMU and
within CDGK
understand and completion related units
to appreciate Development of a strengthening plan for the EDO
EMP
5. Air quality To minimize air Contol all dusty materials at source. Before works All WTP & WDM The CDGK
impacts commence and facilities Contractor
1. If any area of the WDM replacement works are
effectively and throughout all should
within 10m of any sensitive receivers, or have given
avoid complaints construction maintain the
rise to complaints over dust, the contractor shall install
due to the works accepted
segregation between the works at the edge of the
airborne standards.
excavation trench nearest the SRs before works
particulate matter
commence to provide a barrier to protect the sensitive CSC should
released to the
receivers and passing traffic. The segregation should monitor
atmosphere.
be easily erectable 3 m high tarpaulin hoarding within hoardings
which all construction works can take place. The and wetting
hoarding can be moved on from worksite to worksite and other
along the WDM routes as the work proceeds and relevant
removed when the works are completed to trigger a activities.
milestone payment.
The design of the hoardings and works layout must
also allow for pedestrians to cross the roads and avoid
community severance.
2. All heavy equipment and machinery shall be fitted in
full compliance with the national and local regulations.
3. Excavated or stockpiled soil and sand shall be
slightly wetted before loading, particularly in windy
conditions.
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(MM) (MM) (MM) (MM)
4. Fuel-efficient and well-maintained haulage trucks
shall be employed to minimize exhaust emissions.
Smoke belching vehicles and equipment shall not be
allowed and shall be removed from the project.
5. Vehicles transporting soil, sand and other
construction materials shall be covered. Speeds of
such vehicles shall be limited to 10km/h within the
works site and on unpaved areas.
6. Transporting materials through densely populated
areas should be avoided.
7. Open areas of the sites and nearby roads (50m
adjacent either side of the active works areas) shall be
sprayed at least twice per day with water to suppress
dust.
6. Noise/Ground To minimize Install, maintain and monitor all requisite mitigation as Maximum All WTP & WDM Contractor CDGK/
Vibration noise level per contract allowable noise facilities should
CSC
increases and levels at the monitor and
1. Outside schools or hospitals construction timetable Within 50m of all
ground vibrations façade of the maintain the
shall be discussed with the occupiers and work should hospitals schools
during sensitive accepted
be avoided at sensitive times. As fall back option to and colleges
construction receiver are standards)
control noise, mass of hoardings can be increased
operations.
using heavy thick ply-board or corrugated metal sheet 1. 70dB(A)LEQ CSC should
to achieve a mass of >10kg/m2. Design and works monitor
or
layout must allow pedestrians to cross roads or pass relevant
around or over sites and avoid community severance. 2. 3dB(A)LEQ activities.
The installation of such measures should be above the
discussed with the local population and serve as a background
means for further public consultation during (measured no
implementation and assist in public relations. more than 2
weeks before
2. All heavy equipment and machinery shall be well
the
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(MM) (MM) (MM) (MM)
maintained and fitted in full compliance with the commencement
national and local regulations. of work).
3. As a rule, the operation of heavy equipment shall be
conducted in daylight hours unless agree otherwise
with local residents.
4. Construction equipment, which generates
excessive noise, such as compressors, jack-hammers
shall be enclosed to prevent noise release. Well-
maintained haulage trucks will be used. The
contractor shall also maintain and service all
equipment to minimize noise levels.
5. Performance criteria during nighttime (10 pm to
7 am) shall be the measured impact noise at the
residential or hospital sensitive receiver shall not be
more than 3dB above background noise levels
measured at the nearest sensitive receiver (Leq15minutes)
two weeks prior to the commencement of works. The
contractor shall also maintain and service all
equipment to minimize noise levels.
7. Near Mosques and schools the contractor shall
discuss with the CSC and the school and mosque
principals the agreed time for operating the noisy
machines and completely avoid machine use near
schools during examination times and near mosques
during religiously sensitive times.
8. Large concrete building components shall be
prefabricated near the concrete batching plants or in
controlled dedicated areas away from SRs to minimize
impacts.
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(MM) (MM) (MM) (MM)
9. Contractor shall be allowed to take other acoustic
measures to minimize noise nuisance in the vicinity of
construction sites if the necessary noise attenuation to
keep within the noise criteria can be achieved.
10. Contractor may obtain guidelines for noise
reduction from ISO/TR11688-1:1995(e), which
enumerates methods by which air-borne, ground–
borne and structure-borne noise sources may be
curtailed with suitable design criteria.
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(MM) (MM) (MM) (MM)
1. To adopt ERP Asbestos cement pipes shall be carefully excavated,
Update once a 1. The location of 2.CDGK DOE CDGK/
7. Removal of in line with ADB lifted on to plastic sheets, wrapped in polythene and
month and buffer temporary and CSC
CSC
Asbestos requirements. sealed with duct tape to be transported to the report quarterly. store or permanent should
Cement Pipes 2. To control the
designated storage area or landfill. disposal areas to supervise and
(ACP) be identified by take action to
release of The procedure shall follow the measures indicated
detailed design ensuure
harmful asbestos below:
engineer to be completion of
fibres.
Preparation prepared at the Contractor’s
3. To control contract stage for relevant
1) The CONTRACTOR shall implement all the pro-
disposal of ACP, agreement. activities
cedures in Appendix 2 of the AMF and make avail-
a hazardous according to
able all the materials in Appendix 3 of the AMF.
waste. environmental
2) The CONTRACTOR shall agree to remove and 2. The records of standards.
transport all the wrapped asbestos (ACP) from the asbestos
sites to secure temporary buffer store(s) desig- abatement
nated by DOE - CDGK to await disposal. activities and audit
of waste disposal
3) The CONTRACTOR shall provide approved pro- quantities to be
tective clothing to all workers and DOE – CDGK reconfirmed and
inspector as and when requested. that disposal area
4) Workers handling the asbestos cement pipes shall is available as
wear the personal protective clothing provided. identified by
detailed design
5) The DOE - CDGK Asbestos Specialist inspector engineer.
shall visually inspect the preparation before in-
structing the Contractor to proceed.
6) The DOE - CDGK Asbestos Specialist inspector
shall monitor the works and carry out a visual in-
spection to certify that all the ACP have been re-
moved to a satisfactory standard in line with Ap-
pendix 2 of the AMF.
7) The DOE - CDGK Asbestos Specialist inspector
will check and record the number of packs of
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(MM) (MM) (MM) (MM)
8. Construction To minimize the Waste Management Plan to be submitted to the CSC Update once a 1. A list of 1.Contractor CDGK/
Waste Disposal impacts from the and approved one month prior to starting works. month and temporary
CSC
disposal of report quarterly. dumping areas
1. Estimating the amounts and types of construction
construction identified by 2.CSC should
waste to be generated by the project.
waste. detailed design supervise and
2. Investigating whether the waste can be reused in engineer to be take action to
the project or by other interested parties. prepared at the ensure
contract stage for completion of
3. Identifying potential safe disposal sites close to the agreement. Contractor’s
project OR those disposal sites designated in the
relevant
contract.
activities
4. Investigating the environmental conditions of the 2. The list of waste according to
disposal sites and recommendation of most suitable sites to be environmental
and safest sites. reconfirmed and standards.
that dumping areas
5. Redundant asbestos cement and other redundant is available as
pipes and contaminated soil shall not be left in the soil identified by
or stockpiled on site but to be removed efficiently in detailed design
line with the provisions of the Asbestos Management engineer.
Framework.
6. Piling up of inert loose soil based material should
be done in segregated/protected areas to arrest
washing out of soil. Debris shall not be left where it
may be carried by water to down stream drains, flood
plains, lagoons etc.
7. Used oil and lubricants shall be recovered and
reused or removed from the site in full compliance
with the national and local regulations. Oily waste
must not be burned. LICENSED DISPOSAL
LOCATION TO BE AGREED WITH CDGK/SEPA
8. Machinery should be properly maintained to
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(MM) (MM) (MM) (MM)
minimize oil spill during the construction.
9. Solid waste should be disposed at an approved
solid waste facility.
10. Waste shall not be burned - under any
circumstances.
OPEN BURNING IS CONTRARY TO GOOD
ENVIRONMEMTAL PRACTICE and ADB guidelines
on ERP.
9. Worker To ensure that 1. Identify location of worker canteen and toilet UPDATE Once Location Map is Contractor CDGK/
canteen and the operation of facilities in consultation with local communities. a month prepared by the
CSC
toilet facilities the works and Location subject to approval by the CDGK. If possible, Contractor.
worker facilities canteen and toilet facilities shall include drinking water
does not supplies.
adversely affect
2. In order to maintain proper sanitation around
the surrounding
construction routes, temporary toilets will need to be
environment and
provided. Waste shall not be buried (see above)
residents in the
area. 3. Drinking water and sanitary facilities shall be
provided for employees.
4. Solid waste and sewage shall be managed
according to the national and local regulations.
5. The Contractor shall organize and maintain a waste
separation, collection and transport system.
6. The Contractor shall document that all liquid and
solid hazardous and non-hazardous waste are
separated, collected and disposed of according to the
given requirements and regulations.
7. At the conclusion of the project in a particular
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(MM) (MM) (MM) (MM)
sector, all debris and waste shall be removed. All
temporary structures, including office buildings,
shelters, waste receptacles and toilets shall be
removed.
8. Exposed areas shall be replanted with suitable
vegetation in line with the landscape plans and be
inspected by CDGK and CSC shall inspect and report
that the site has been vacated and restored to pre-
project conditions or as agreed with CDGK.
10. Safety To ensure safety 1. Providing adequate warning signs. During Relevant canteen Contractor CDGK/
Precautions for of workers construction and worker and CSC
2. Providing workers with skull guard or hard hat and CSC
the Workers and sanitation facilities.
protective boots.
first aid.
3. Contractor shall instruct his workers in health and
safety matters, weekly, and require the workers to use
the provided safety equipment.
4. Establish all relevant safety measures as required
by law and good engineering practices.
5. Contractor shall provide first aid facilities for the
workers on the WTP and WDM and at the worker
canteens with at least one qualified first-aider or nurse
present at all times. It is recommended that the
workforce be given access to a trained doctor at least
once per two weeks for routine checks and medical
examinations if necessary.
11. Traffic Minimize Submit temporary traffic management plan one month Day time The most Contractor CDGK/
Condition disturbance of prior to start of works in any given sector. important locations and Engineer
CSC
vehicular traffic & to be identified and
Formulation and implementation of a construction
pedestrians listed. Relevant
related traffic management plan and assign traffic
during haulage of plans of the
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(MM) (MM) (MM) (MM)
materials, spoil, control personnel. Contractor on
equipment & traffic
The Temporary Transport Management Plan will
machinery. No arrangements are
include consideration of the following.
blocking access available.
near Lane availability and minimise traffic flows past the
construction works site.
sites.
Establish acceptable working hours and constraints.
Agree the time scale for the works and establish traffic
flow/delay requirements.
Programming issues including the time of year and
available resources.
Acceptability of diversion routes where necessary.
Need for road closures and the necessary Orders.
Co-ordination with other planned road and street
works.
Discuss the CDGK inspection/monitoring role.
Discuss establishment of incident management
system for duration of the works
Agree publicity/public consultation requirements
(advance signing etc.).
The plan will be reviewed by CDGK and approved, if
found appropriate.
Resources from contractor, CDGK, and the traffic
police will be provided as per the plan before
construction commences.
The Vicinity of schools and hospitals to be considered.
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(MM) (MM) (MM) (MM)
Installation of traffic warning signs.
Conducting awareness programs on safety and proper
traffic behavior in densely populated areas near the
construction sites.
12. Nuisance to Control Contractor to agree to monitor and enforcement of At all times All WTP & WDM CSC To CSC /
nearby nuisances and implementation of mitigation measures versus facilities with monitor,
CDGK
properties reduce impacts milestone payments for mitigation. special focus on enforce
on property value areas within 50m implementatio
Contract clauses to specify acceptable construction
or interruption to of all residences, n of contract
practices to mitigate nuisances, noise, vibration and
neighbouring hospitals schools, clauses
dust impacts and liaison with local community on
land uses. colleges and versus
approach to mitigation.
places of worship. milestone
No payment unless environmental mitigation payments.
measures are implemented and penalty clauses in
Complaints
contract.
response time
Incorporating good construction management rerecorded.
practices – complaints reported once per month for
Contractor to
each site/km of water main under construction.
respond and
Compensation will be paid for loss of livelihood due to resolve
construction disruption in line with ADB guidelines. complaints.
Set up complaints hot line, recording, response and
resolution monitoring.
OPERATIONAL STAGE
1. Monitor To reduce Regular inspection of all chorine dosing equipment Throughtout Weekly checks at CDGK CDGK
clorine chlorine and storage facilities. operations all water treatment
usage/leakage leakage/check locations.
Monitor for chlorine leaks all chorine dosing
checking. chlorine usage at
equipment and storage facilities
the treatment
plants and
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(MM) (MM) (MM) (MM)
dosage
equipment.
2. Raw Water Ensure Establishing guidelines and standards and regulations Throughtout Weekly during CDGK CDGK
quality knowledge on for raw water quality. operations operation
water quality to
Implement a competent operations and maintenance
determine
plan and monitoring plan of recommended water
effectiveness of
quality parameters to address problems of delivery of
water treatment.
contaminated water (Water Quality O & M Plan).
Implement agreed strategy and policy on chlorination,
disinfection methods, continuity of supply, monitoring
raw water quality and delivered water quality.
3. Residual To monitor Monitor chlorine at dosing point (>100mg/l). Throughtout Weekly at least CDGK CDGK
chlorine in water chlorine leakage / operations three locations for
Measure pH at dosing point (<8.0)
delivered water check chlorine each WTP & WDL
Clorine usage usage at the Ensure contact time of 30mins to chlorine. facility.
monitoring treatment plants
Monitor chlorine at selected delivery points.
Measure pH at selected delivery points.
Consider to maintain residual chlorine in distribution
mains at 0.2 to 0.3mg/l as a sentinel against pollution
entering the mains and to prevent growth of nuisance
bacteria.
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Appendix C:Asbestos Management Framework
This Asbestos Management Framework (AMF) was prepared for all the subprojects that
will arise in all tranches of the proposed Karachi Mega City Sustainable Development
Program (KMCSDP or the ‘Program’) as required by ADB. The Asbestos Management
Framework focuses specifically on environmental liabilities with respect to asbestos.
Nothing in this AMF shall be construed to modifying or release the Implementing Agency
(IA) CDGK from any other obligations for environmental assessment of subprojects as
required under the EARF with regards to the policy, procedures and institutional
requirements for preparing subsequent sub-projects under the MFF loan. The executing
agency (EA) will be the Department of Finance of the Government of Sindh (GoS) and
the implementing agency (IA) will be the City District Government of Karachi (CDGK).
A Development Activities requiring Asbestos Management

166.Government of Pakistan (GoP) has requested the Asian Development Bank (ADB)
to provide a multi-tranche financing facility (MFF) to facilitate investments to support the
proposed Karachi Mega City Sustainable Development Program (KMCSDP or the
‘Program’). Water supply and sewer subprojects are included under the KMCSDP MFF
(Table 1). These subprojects will include replacement of water distribution mains (WDM)
and sewer pipes. Asbestos cement pipes (ACP) are known to have been used to
construct the existing WDM and may also have been used to construct the sewers. The
objective of this AMF is to reduce the risk of exposure of workers that have to handle
asbestos, reduce the environmental liabilities associated with asbestos and also build
capacity in CDGK to manage asbestos related issues.
167.During the course of conducting environmental assessment for the subprojects in
Tranche 1 of the KMCSDP MFF it has been discovered that more than half of the WDM
was constructed from asbestos cement pipes (ACP). The extent of asbestos cement
pipes in the existing sewers is not known. The extent to which the ACP have been
replaced is unknown. ADB Environmental Assessment Guidelines 2003 recommend
environmental responsible procurement (ERP) which that is a fundamental principle for
robust environmental management of subprojects. Asbestos is on the ADB Prohibited
List in the Environmentally Responsible Procurement guidelines (2007)20.
168.Asbestos is recognized internationally as a hazardous material because it can
present a risk to human health. In many jurisdictions asbestos is classified as hazardous
and is a controlled chemical waste or a hazardous waste because if it is mishandled it
can release airborne fibers that are known to cause asbestosis and have also
associated with other lung diseases and cancer. All forms of the asbestos mineral will
release asbestos fibers if broken up and all types of ACM will release asbestos fibers to
some degree if damaged or abraded.
169.Asbestos has been widely used in numerous types of materials, usually because of
its good qualities as a thermal insulation material. Asbestos has also been used
extensively in numerous types of cement materials, pipe insulation plaster and in
refractory brick work. Asbestos is often used because of its good qualities as a thermal
insulation material but it is also useful as a binder to form complicated cement shapes
and durable pipes. The amounts of asbestos used vary from product to product but
certain types of asbestos cement can contain more than 50% asbestos. When bound in
20 Environmentally Responsible Procurement – A guide to better practice ADB (2007)
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the cement matrix of a pipe the asbestos is generally considered safe. However over
time the cement surface of a pipe can become corroded or abraded leading to the
release of asbestos fibers. The surface of the asbestos cement pipe (ACP) can gradually
become more friable and release asbestos fibers. With a buried or submerged pipe the
chemical conditions in the surrounding soil or water will also affect the rate of
deterioration of the pipes as they gradually wear out or become more fragile. The
removal and replacement of pipes will also give rise to some release of fibre as it is
almost impossible to remove more fragile old ACP without breaking them. Therefore in
addition to giving rise to a controlled waste the removal of the ACP can also easily lead
to the release of asbestos fibers if the removal is not conducted under controlled
conditions.
170.This AMF has been prepared because the ACP will most likely be disturbed in the
process of implementing the Water Distribution Mains (WDM) and Sewer subprojects.
Given the concerns over the extensive leaking and dilapidated state of WDM and sewers
it is likely that a significant part of the ACP are broken or cracked underground and will
have to be replaced.
171.Asbestos containing materials (ACM) may also be present in other CDGK
infrastructure and asbestos waste will arise when ACP are replaced. Therefore a
management framework is required to deal redundant asbestos containing materials
(ACM) that will result from the decommissioning of infrastructure in preparation for the
implementation of other component subprojects in Tranche 1 and all future tranches of
the KMCSDP MFF. This AMF shall apply to all subprojects under the MFF so as to
ensure that the environmental liabilities associated with asbestos are appropriately
addressed and managed to reduce the known risks to human health to acceptable
levels.
172.Under the MFF loan procedures of ADB, implementation of safeguards is to be
achieved by environmental assessment of every subproject to be undertaken following
ADB Environment Policy (2002). Therefore the AMF applies to all aspects of the
constituent subprojects, in the KMCSDP-MFF under ADB Environmental Assessment
Guidelines (2003) that must be followed for all subprojects. ADB policy and
recommendations on environmentally responsible procurement1 will prevent further
asbestos materials being used in the KMCSDP MFF subprojects as prescribed in the
EMPs that are included in the IEEs prepared for all subprojects in Tranche 1. Free limits
will not be applied with respect to this AMF.
173.Project implementation will be managed by a Project Implementation Unit (PIU)
within CDGK in coordination with the relevant sector departments of CDGK. It is
recommended that the implementation of the AMF should be managed by one dedicated
officer (Asbestos Specialist) and that officer could be in the DOE in coordination with the
relevant sector departments of CDGK, since the asbestos issues will apply more widely
across all CDGK activities and infrastructure, The Asbestos Specialist could also be
located in the Project Implementation Unit (PIU) within CDGK. If there is no suitably
qualified person available, the DOE could be delegate the asbestos work to an
international asbestos specialist and then the DOE staff can shadow the international
consultant for say six months to gain experience and expertise as the MFF is rolled out.
The Program Reform Monitoring Unit (PRMU) within the Department of Finance of GoS
would also be expected to monitor the asbestos issues, adherence to the AMF along
with monitoring the overall Program and other safeguard issues that arise on specific
subprojects.
174.The Asbestos Specialist (whether located in the PIU or DOE) or consultant in CDGK
will be responsible ensuring that the AMF is implemented, that asbestos issues have
been considered early in the implementation at the detailed design stage and by using
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the asbestos checklist so that necessary asbestos assessments are prepared (to
support preparation of EMPs for subprojects).
Table 1: Proposed MFF Subprojects
Sub- Subproject Asbestos ADB

sector Issue Category
First Tranche – 2008 to 2011
Part A Investment Program Management and Support
Program Management
PRMU AMF–A C
PIU AMF–A C
Program Support
Studies AMF–A C
Capacity Development and Training AMF–A C
Public Awareness and Outreach AMF–A C
Monitoring and Evaluation (M&E)
Independent M&E N/A C
Part B Water Supply and Wastewater
Water Filtration Plants at COD and NEK total 100 MGD capacity AMF-D, ERP B
Water Filtration Plants at COD and NEK total 84 MGD capacity AMF-D, ERP B
Water transmission main of 48" and 36" dia. From Pipri Treatment AMF-D, ERP B
Plant to Korangi Industrial Area and 36" from Pipri Treatment Plant to
Malir Town
Water Distribution Network Improvements in priority zone AMF-D, ERP B
Sewer from Shaheen Complex to Clifton PS AMF-D, ERP B
Part C Urban Transport
Bus Rapid Transit along Route 1: Surjani to Karachi CBD; and Route ERP A/B
3: Orangi Town Extn.
Bus Rapid Transit along Route 2: University Road to Karachi CBD ERP B
(Phase 2)
Urban Traffic Control System – Phase 1 N/A C
Dualization of Link Road between National Highway to Superhighway N/A B
Second Tranche – 2009 to 2012
Part A Subproject Preparation AMF-A C
Part B Water Distribution Network Improvements in additional zones AMF-D, ERP B
Transmission main extensions to Mehmoodabad; from Surjani to 5C AMF-D, ERP B
Chowrangi and Nazimabad
24" Main from Hub Reservoir to Baldia Town and Scheme 42 and 48" AMF-D, ERP B
Main from Board Office to Urdu Cowk
Phase 3 extension of water supply network improvement program AMF-D, ERP B
Trunk sewer replacements and extensions based on JICA-supported AMF-D, ERP B
sewerage Masterplan
Part C Bus Rapid Transit (Routes 4,5,6) ERP A/B
Urban Traffic Control System – Phase 2 N/A C
Key link Road Malir Expressway Phase 1 N/A B
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Sub- Subproject Asbestos ADB

sector Issue Category
Part D Pilot low-income housing plot formation and associated studies and ERP C
assistance
Third Tranche – 2010 to 2013
Part B Further water transmission and distribution network extensions based AMF-D, ERP B
on outcome of water balance and equitable distribution study
Trunk sewer replacements and extensions based on findings of JICA- AMF-D, ERP B
supported sewerage Masterplan
Part D Scaled up social housing fund for low-income plot formation and ERP C
assistance
Fourth Tranche – 2011 to 2015
Part B Further water transmission and distribution network extensions based AMF-D, ERP B
on outcome of water balance and equitable distribution study
Trunk sewer replacements & extensions based on JICA-supported AMF-D, ERP B
sewerage Masterplan
Part C Bus Rapid Transit (Routes 7,8,9,10,11) ERP A/B
Key link roads N/A B
N/A = not applicable = no foreseeable asbestos issues.
ERP = Guidance on Environmentally Responsible Procurement – A reference guide for better practices
2007 that recommends no ACM to be used in new infrastructure. AMF-D = AMF will require waste ACP to
be disposed. AMF A = AMF will raise awareness and included in hazardous waste strategy.
175.The procedures to be adopted are outlined in this framework by reference to known

asbestos in ACP but this AMF should be applied to all subprojects where any ACM is
identified. Asbestos investigations should be prepared for each subproject to check if
there is any likelihood of ACM being implicated and if ACM is present Asbestos
Management Plans should be prepared, disclosed to ADB for review and approval prior
to including the AMP in the contracts before commencement of work. The PIU within the
DOF of GoS shall monitor the progress of the environmental work stream in general and
the EMP that will include asbestos issues to ensure that the AMF is implemented and
that where relevant all asbestos assessments are submitted to ADB prior to the PFR for
all Tranches.
176.Each subproject will undergo a preliminary review of asbestos issues to identify any
known uses of asbestos containing materials or asbestos containing products that have
been procured. In the case of the WDM and Sewer subprojects either all the cement
pipes can be assumed to be ACP or sampling of the pipes can be undertaken by the
Asbestos Specialist early in the detailed design phase, The ACP samples shall be
referred to the relevant laboratory for analysis (Appendix 3).
B Requirement for Asbestos Management

177.Best practice asbestos management usually entails several stages. Survey and
investigation are the first steps in which the asbestos specialist will check all structural
elements, fixtures and fittings for fibrous materials that are potentially asbestos. Samples
are taken under controlled conditions and an accredited laboratory analyses the samples
using polarized light microscopy. The asbestos specialist will then assess the type,
location and condition of asbestos and make a hazard assessment. If asbestos needs to
be removed an asbestos abatement plan is usually prepared to cover removal with
detailed work specifications for specialist contractors. In all cases the asbestos should
be labeled and safety procedures instigated to prevent disturbance, until such time as it
can be removed safely.
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178.Typical of many developing countries Pakistan uses asbestos for many industrial
and commercial purposes. Best professional judgment suggests that at this stage
asbestos cement pipes have been typically been used in 50% to 70% of the Karachi
water supply pipe system which extends over thousands of kilometers. Significant parts
of this system will be replaced by ADB supported projects in the immediate future and in
a rolling programme over several years. There may well be other residual asbestos
waste entering the solid waste management system.
179.There are as yet no statutory controls on hazardous waste in Pakistan. The
Hazardous Substances Rules were drafted in 2003 but were never brought into force.
Asbestos waste is listed in the draft Hazardous Substances Rules 2003 (HSR). If
enacted the HSR would require an entity licensed under the Pakistan Environmental
Protection Act (1997) to have a waste management plan for any listed hazardous
substance. This AMF is in line with the spirit of Pakistan’s draft legislation.
180.The solid waste management Roadmap for Karachi Mega City Sustainable
Development MFF envisaged as one goal as “an effective regulatory framework for the
environmentally safe and healthy management of all municipal and hazardous solid
wastes generated in Karachi”.
181.The lack of a functioning HWM system in Karachi is of serious concern, as many of
the wastes are presumably being disposed of also through illicit dumping methods
throughout the city. This would presumably be the fate of any asbestos waste from the
MFF Tranche 1 projects if disposal of ACM is not controlled.
182.Therefore although hazardous waste management (HWM) in Karachi is in its
infancy, with no regulatory or legislative framework, and no institutional capacity or
funding at the Government level, the need for a HWM system has been recognized.
183.ADB may well be involved in HWM (therefore waste asbestos management)
corollary to the implementation of subprojects for Karachi Mega City Sustainable
development MFF. It is also noted that another ADB initiative, the RETA on Hazardous
Wastes Management, covering Nepal, India, Bangladesh and Bhutan is also underway
in 2007).
184.Some previous ADB projects and guidelines have also considered asbestos issues.
The recently published Environmentally Responsible Procurement1 lists asbestos fibers
on the Prohibited List asbestos fibers are on the prohibited list but asbestos cement
sheets with less than 20% asbestos are exempted. Other available information on ADB
projects does not reveal that asbestos has been a major consideration to date, however
ACM is mentioned in several project reports (Appendix 4).
185.ADB standards are guided by the World Bank Pollution, Prevention and Abatement
(PPAH) that requires asbestos disposal should be carried out in line with host country
regulations or following best international practice.
186.Therefore as there are as yet no local standards for asbestos control in Pakistan,
any known asbestos waste requiring removal should be disposed of following best
international practice.
187.In line with best international practice, the requirement for a dedicated Asbestos
Management Plan has been included in the IEE / EMP for relevant Trance 1 subprojects
for Karachi Mega City MFF. This AMF has been prepared taking into consideration other
future developments in Karachi and other ADB experience and lessons.
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C Responsibilities / Authorities of Various Agencies

188.Potential environmental liabilities with respect to asbestos associated with
subprojects will be minimized by implementing the requirements of the AMF and by
prescribing the selection of alternative non-asbestos materials (section D and Appendix
2). All measures shall be in line with ADB’s Environment Policy 2002 and ADB
Environmental Assessment Guidelines 2003, the GOP’s regulations and guidelines, the
Environmental Assessment Review Framework and the Guidance on Environmentally
Responsible Procurement1.The subprojects shall only involve asbestos activities that
follow the AMF.
189.The CDGK as IA will be solely responsible for the implementation of all of the
asbestos assessment and review procedures required in the AMF for all subprojects.
This will include, but not be limited to, ensuring that the asbestos control procedures are
strictly adhered to, that preparation of AIR and AMP are carried out in a timely and
efficient manner and included in the construction contracts. CDGK will submit the
asbestos checklist (Table 2) an AIR and an AMP and monitoring reports to ADB for
review.
190.Prior to the submission of the PFR for a Trance of subprojects the CDGK (Asbestos
Specialist) will:
i) Assist CDGK to identify a suitable secure buffer store for waste asbestos.
ii) Prepare an asbestos investigation report (AIR) and checklist to identify any
asbestos issues in any subprojects in each Tranche.
iii) Ensure that adequate sampling and analysis of the existing facilities has
been carried out to ensure all environmental liabilities with respect to
asbestos have been identified, review the asbestos assessments AIR and
AAP and submit the AIR and AAP to ADB.
iv) Prepare the asbestos surveys and investigations prepare asbestos
assessments, AIR and AAP reports including an AMP for inclusion in the
construction contracts.
191.Prior to the commencement of civil works for a subprojects in a Tranche the CDGK
will:
i) Set up the buffer store facility and ensure that all contractors have been
briefed as to the presence of ACM in the subproject works and the nature of
the hazards posed by the type of asbestos present.
ii) Ensure that the contracts have specified the asbestos management
procedure AMP to be used in the construction of the subproject to control
environmental liabilities to acceptable levels.
iii) Ensure that the required mitigation measures during construction and the
AMF are included in the bidding document of the subproject and that the all
bidding contractors have access to the IEEs and EMP.
iv) Ensure that CDGK have identified a suitable secure buffer store for the waste
ACM in lieu of landfill disposal being available and that the contractors know
the location of the buffer store in the bidding documents.
v) Ensure the selected contractor has made adequate provisions (including
human resources, materials methods and training) to carry out works in line
with the AMF as a payment milestone. have access to the IEEs and EMP
192.During the implementation of civil works for a subprojects in a Tranche the CDGK
Asbestos specialist will:
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i) Ensure that the asbestos abatement procedures, including all proposed

mitigation measures and monitoring in Appendix 2 are properly implemented.
ii) Monitor the implementation of AMPs and present its monitoring report.
iii) Ensure that ADB be given access to undertake environmental due diligence
for all subprojects. However, the CDGK shall have the main responsibility for
undertaking environmental due diligence and monitoring of all the
subprojects. The due diligence report as well as monitoring reports on EMP
implementation will be systematically prepared and include asbestos
abatement issues.
Table 2: Proposed preliminary checklist for AMF Implementation on MFF
Subprojects@
Stage Task / Progress Yes / no Date

(comment)
1 Employ Asbestos Specialist (registered /qualified asbestos /
hazardous waste consultant#
2 Prepare asbestos screening checklist. A preliminary review of
asbestos issues by AS. Are ACM / ACP known to have been used
in the system?
3 Have potential locations for ACM / ACP been identified, surveyed,
sampled and investigated by the Asbestos Specialist / qualified /
registered asbestos consultant in line with best practice.
5 Have the potential ACM/ACP bulk samples been analyzed by an
accredited laboratory in line with best practice (Appendix 4).
6 Has the Asbestos Specialist / registered asbestos consultant
prepared an asbestos investigation report including the survey,
sampling locations and confirmed or refuted the presence and
types of asbestos in line with best practice
7 Has the Asbestos Specialist prepared an asbestos management
plan (AMP) including asbestos abatement plan including results of
the asbestos investigation and ACM locations types of asbestos in
line with the AMF procedures and best practice
8 Are the requirements for asbestos management plan including
asbestos abatement plan included in the contracts.
9 Have CDGK provided the necessary buffer storage space or
landfill disposal location for the asbestos.
10 Can the contractors obtain the necessary skills capability and
equipment to carry out the asbestos management in lie with the
AMF.
11 Can the contractors obtain the necessary skills capability and
equipment to carry out the asbestos management in lie with the
AMF.
12 If no to any of the above provide remedial action and detail on
separate sheets
# Link to technical assistance for hazardous waste management strategy - Appendix 1 for ToR Asbestos
Specialist.
@ To be updated at the detailed design stage as necessary.
193.ADB will be responsible for regular review and timely approval of subproject AMF
checklists (Table 2). Technical guidance will be provided by ADB to the CDGK as
29/03/08 Page 87 of 101

needed. ADB will also be responsible for reviewing regular monitoring reports and
officially disclosing the any aspects of on the ADB website if required.
194.During the MFF ADB will:
i) Review asbestos AIR and AMP as a basis for subproject and Tranche
approvals.
ii) Monitor the AMF and AMP implementation and due diligence as part of MFF
reviews.
iii) Provide assistance to CDGK, if required, in carrying out its responsibilities
and for building capacity for compliance with the AMF.
D Asbestos Control Procedures
1. Minimizing Asbestos Liabilities

195.Potential environmental liabilities with respect to asbestos associated with
subprojects will be minimized by taking the following measures:
i) Implementing the requirements of the AMF and by prescribing the selection
of alternative non-asbestos materials.
ii) Where ACM must be disturbed in a subproject the ACM shall only be
removed under controlled conditions for disposal in line with the provisions of
the AMF or any rules subsequently promulgated by the Federal EPA or Sindh
EPA.
iii) Construction of the subprojects will not take place until the contractor has
agreed to carry out the asbestos abatement procedures in line with the
procedures included in the AMF.
iv) Conducting sampling of potential asbestos containing materials (ACM) and
compiling an asbestos investigation report (AIR) with adequate
implementation.
v) For low risk ACP prepare an asbestos management plan (AMP, including
asbestos abatement plan (AAP) with adequate implementation and
monitoring budget will be developed for each subproject based on Appendix
2 to this AMF.
vi) For other high risk friable materials if they are identified prepare alternative
asbestos abatement plans (AAP) with adequate implementation and
monitoring budget will be developed for other subproject based on best
international practice.
vii) All measures shall be in line with ADB’s Environment Policy 2002 and ADB
Environmental Assessment Guidelines 2003, the GOP’s environmental
assessment regulations and guidelines, the Environmental Assessment
Review Framework and the Guidance on Environmentally Responsible
Procurement1.
viii) The subprojects shall only involve asbestos activities that follow the AMF.
2. Preparation of Detailed Design

196.Detailed design work for each additional subproject will include and follow the
recommendations of the AMF. The CDGK will include the requirements of the EMP and
IEE/EIAs (including the AMF) in the bid documents and ensure the detailed designs
include such requirements. Before contracts are finalized certification shall be provided
29/03/08 Page 88 of 101

to ADB by CDGK that the detailed designs comply with IEE/EIAs (including AMP)
recommendations will be required before contracts can be signed and made effective.
The CDGK shall also allocate sufficient resources to recruit and support an Asbestos
Specialist in the DOE of CDGK to monitor the progress of the asbestos management
process for all subprojects under the MFF.
3. Preparation of Construction Contracts

197.Early in the implementation period, model construction contracts will be prepared
incorporating general environmental safeguards and asbestos management practices
based on Appendix 2 and Appendix 3 to this AMF. Specific, individual contracts will be
based on the model contracts, but will also be checked by the CDGK to ensure that all
special or particular safeguard requirements and mitigation measures, recommended in
the AMP for the particular additional subproject, are all incorporated within the contract.
The CDGK shall also allocate sufficient resources to the Asbestos Specialist to monitor
the asbestos abatement mitigation measures specified in the AMP are included in all
construction contracts under the MFF.
4 Monitoring During the Construction Period

198.Monitoring during construction will be the responsibility of the CDGK Asbestos
Specialist. Monitoring will relate to compliance with construction contracts. The Asbestos
Specialist will inspect the ongoing works regularly and systematically; checking that the
above-mentioned the asbestos abatement mitigation measures specified in the AMP
have been implemented effectively during the design and construction stages of the
project (Table 2) and ensure the implementation and effectiveness of mitigation
measures. Reporting will be to the CDGK on a regular basis (at least quarterly) and to
ADB semi-annually. The asbestos will be removed in the construction stage and
therefore no monitoring will be required in the operational stage.
E Institutional Arrangements
199.The IA for the AMF for the MFF will be CDGK. An environment officers (Asbestos
Specialist) within the DOE or other suitably qualified consultant shall lead the
implementation of the AMF and have those responsibilities for the duration of the MFF
loan and shall report directly to the head of the DOE of CDGK, who will be accountable
and responsible for implementation of the AMF. The dedicated Asbestos Specialist will
coordinate consistently the implementation of the AMF in all subprojects where asbestos
has been identified as an issue.
200.The Asbestos Specialist shall also be responsible for coordinating and supervising
monitoring of asbestos abatement, quality control, and writing the periodic progress
reports on implementation of the AMF. The implementation of the AMF shall commence
immediately upon commencement of the detailed designs for the MFF subprojects. The
Asbestos Specialist will therefore be designated at least one month before and released
for duty before the loan becomes effective. CDGK will further ensure the release of
resources for asbestos management and that monitoring budgets are made available for
timely AMP implementation.
F Monitoring and Evaluation

201.The AMF will have both internal and external monitoring. The Asbestos Specialist at
the local level will be responsible for internal monitoring of the AMF implementation, and
will forward quarterly progress reports to CDGK. The reports will contain progress made
in AMF implementation with particular attention to compliance with the principles set out
29/03/08 Page 89 of 101

in the AMF. The CDGK will submit a brief annual monitoring report to ADB at least once
per year.
29/03/08 Page 90 of 101

APPENDIX 1 DRAFT TERMS OF REFERENCE FOR ASBESTOS SPECIALIST
This TOR to be modified depending on the management details.

202.
Qualifications
203.The Asbestos Specialist shall preferably be a registered asbestos consultant or
member of a recognised waste management association in an ADB member country
and/or have work experience and familiarity with all aspects of asbestos management
and/or have attended a recognised full time training course on all aspects of asbestos
management. Candidates with broad experience in the field of asbestos management or
hazardous waste management will be preferred. The Asbestos Specialist shall at least
be a graduate in environmental science, environmental engineering or a related
discipline with significant experience in asbestos management or hazardous waste
management and monitoring of projects and implementation of mitigation measures and
engineering controls to minimise risks associated with control of asbestos or hazardous
wastes in the environment.
204.The general scope of work will be:
i) To plan asbestos investigations and arrange for bulk sampling of potential as-
bestos containing materials (ACM) and prepare asbestos investigation report
for all subprojects to confirm the extent or refute the presence of ACM.
ii) Prior to controlled landfill disposal facilities being available, to assist CDGK to
identify a suitable buffer store to stockpile ACM collected up from subprojects
and prepare an asbestos management plan (AMP) for the buffer store and fu-
ture landfill.
iii) Monitor the management of stockpiled ACM in the buffer store buffer store
and subsequently monitor the management of waste ACM in the controlled
landfill disposal facilities.
iv) When controlled landfill disposal facilities are available, to assist CDGK to
monitor the implementation of necessary controls on asbestos disposal and
to monitor the controlled handling, transfer and disposal of the stockpiled
ACM from the buffer store.
205.If ACM is identified:
v) To prepare asbestos management plans (AMP) including asbestos abate-
ment plan (AAP) for CDGK DOE for all subprojects and to report directly to
the Head of CDGK if the progress with the AMF is insufficient to support PFR
to ADB.
vi) To review and verify the progress in AMP implementation for each subproject.
vii) To assess whether robust asbestos management practices have been
achieved and /or improved continually on all subprojects.
viii) To assess efficiency and effectiveness of asbestos management practices
and engineering control measures that have been implemented, their impacts
(positive as well negative) and sustainability, drawing both on policy and prac-
tice and to suggest any corrective measures, if necessary.
206.The Asbestos Specialist will be involved in ongoing monitoring of the AMF
implementation for the CDGK. The major tasks expected are:
29/03/08 Page 91 of 101

i) To Compile and report on preparation of AMP for all subprojects and to notify
PMU and Head of CDGK if the progress in AMP is insufficient to support PFR
to ADB;
ii) Compile and report results of bulk sampling and monitoring and verify results
through random checking at the field level to assess whether AMF objectives
have been generally met;
iii) Identify the strengths and weaknesses of the AMF objectives, approaches,
implementation strategies and identify any unexpected locations of ACM ;
and
iv) Review and verify the progress in AMF implementation of each subproject
and every six months prepare reports for CDGK and ADB.
29/03/08 Page 92 of 101

APPENDIX 2 ASBESTOS ABATEMENT PROCEDURES
Removal of Asbestos Cement Pipes (ACP)
Principle
The principle will be that asbestos cement pipes shall be carefully excavated, lifted
on to plastic sheets for wrapping, wrapped in polythene and sealed with duct tape
and then lifted and lowered on to the transport lorry for transport to the designated
storage area or landfill.
The procedure shall follow the measures indicated below:
Preparation
1.The CONTRACTOR shall make available the materials in Appendix 3.
2.The CONTRACTOR shall be prepared and agree to remove and transport, on
lorries covered with tarpaulins, all the wrapped asbestos cement pipes ACP and
fractured ACP that is in drums, from the site to the secure temporary buffer store
designated by DOE - CDGK to await disposal.
3.The CONTRACTOR shall provide approved protective clothing to all workers. The
CONTRACTOR shall also provide approved protective clothing to the DOE – CDGK
inspector as and when requested. Protective clothing shall consist of an approved
disposable full body coverall, with head cover. Hard hats and boots shall also be
made available to all workers by the CONTRACTOR.
4.Workers handling the asbestos cement pipes shall wear approved half face dust
masks protective coverall and goggles. The CONTRACTOR shall ensure all workers
wear the protective clothing provided.
5.The DOE - CDGK Asbestos Specialist inspector shall carry out a visual inspection
to check that the preparation has been carried out satisfactorily and instruct issue a
written certification to the Contractor to proceed.
Abatement Method
6.First of all the ground / pipe trench shall be excavated carefully using hand tools to
expose the old ACP. Any accidentally excavated loose pieces of asbestos cement
shall be picked up and stored in plastic bags or barrels and sealed.
7.The ACP shall be removed in sections carefully using manual labour and hand
tools to expose the old ACP so that it can be lifted carefully to avoid cracking as far
as possible. Any accidentally fractured loose pieces of asbestos picked up and
stored in plastic bags or barrels and sealed.
8.The drums / barrels to contain the fractured pieces of asbestos cement pipe shall
be made of plastic or metal. If made of some other material the drums / barrels shall
be lined with two layers of 0.15mm polythene sheeting. When the drums are full the
plastic lining shall be folded over the pipe segments and secured in place with duct
tape and the lid placed on the drum and secured in place with duct tape.
9.Before commencing with the removal of the ACP the surface of the asbestos shall
be wet. Any dry areas of exposed existing asbestos cement pipes shall be sprayed
with water (preferably containing a wetting agent) to reduce fibre release. The
29/03/08 Page 93 of 101

wetting agent shall be of a correct mix and concentration in accordance with the
manufacturer’s instructions as specified under materials (Appendix 3).
10.The wetting solution (amended water) shall be sprayed using equipment capable
of providing a ‘mist’ application to reduce the release of fibers. The existing asbestos
material shall be sufficiently saturated to wet it thoroughly. The existing asbestos
material shall be sprayed repeatedly during the removal processes to maintain a wet
condition and to minimize asbestos fibre dispersion.
11.The fixed asbestos cement pipes shall be carefully separated and prized off any
supporting brackets and separated from any attached asbestos cement pipes or
cement screed base and taken up in manageable sections taking care not to drop,
crack, break or damage the asbestos cement pipes. POWERED MECHANICAL
EQUIPMENT (such as backhoe) SHALL NOT BE USED TO REMOVE THE
ASBESTOS PIPES because this will increase the risk of cracking and fibre release.
12.The asbestos cement pipes shall then immediately be wrapped in two layers of
polythene or smaller pieces can be double bagged and goose neck tied with duct
tape and the polythene shall be wet wiped clean.
13.The bottom 10cm of soil below the old ACP shall be assumed to be contaminated
with asbestos fragments or fibers and shall be loosened and shoveled or picked up
and stored in plastic bags or barrels and sealed as ACM.
14.The bottom 5cm of soil below the old ACM pipe, loose debris and rubble will be
removed to create a level floor to the trench and to designate the completion of the
removal work
15.The exposed surfaces of the partially wrapped pipes and the surface of the trench
to be sprayed with adhesives (PVA) to be used as “lock down” on surfaces during the
final clean up of the area. This is to bind any traces of asbestos fibre which may
remain on exposed surfaces.
16.All wrapped asbestos cement packs shall be transferred to the lorries for
immediate transportation to the temporary buffer store to await disposal. All wrapped
asbestos cement packs shall remain at the temporary buffer store and not be
removed
17.The workers shall immediately wet wipe down the overalls and mask and wash
hands and face and any accidentally exposed areas of skin to decontaminate. The
dust masks and overalls, gloves, wet wipes and any other litter shall then
immediately be double bagged and goose neck tied for disposal as asbestos waste.
18.The DOE - CDGK Asbestos Specialist inspector will then carry out a visual
inspection to certify that all visible asbestos cement pipe and fragments have been
removed to a satisfactory standard. If the visual inspection indicates a satisfactory
standard all the asbestos cement packs shall be counted and picked up and
transferred to the lorries for transportation to the temporary buffer store to await
disposal.
19.The DOE - CDGK Asbestos Specialist inspector will then carry out a reassurance
visual inspection to certify that all remaining polythene packs and equipment and
visible asbestos has been removed to a satisfactory standard and proper
decontamination of tools and equipment has taken place.
20.The DOE - CDGK Asbestos Specialist inspector will then check and record the
number of packs of waste transferred to the lorries are the same as those that arrive
at the temporary buffer or landfill using a trip ticket system.
29/03/08 Page 94 of 101

21.The DOE - CDGK Asbestos Specialist inspector will monitor and periodically audit
the buffer store and landfill security to ensure no pilfering or theft of the stockpiled
waste.
22.The Asbestos Specialist inspector will report on the progress of all the asbestos
abatement works under the MFF twice per year to ADB.
29/03/08 Page 95 of 101

APPENDIX 3 MATERIALS AND EQUIPMENT and ASBESTOS LABORATORIES
Containment Materials
a. At least two layers of transparent plastic (0.15mm thickness low density
polythene (B.S.4932:1973) shall be used for wrapping the ACP in sizes which
minimize the need for jointing. Polythene transparent bags and containers used for
packing of asbestos waste should be able to resist puncturing by the sharp edges
of the asbestos cement.
b. The wrappings shall be carefully joined and sealed with wide duct tape, spray
adhesive capable of sealing adjacent sheets of polythene and facilitating
attachment of polythene to the asbestos cement. The adhesive agents should be
capable of adhering and maintaining the wrapping in place under both wet and dry
conditions.
c. Pipe sections and fragments of 2m or less shall be completely wrapped in
polythene or collected in polythene bags. Pipe sections and fragments of greater
than 2m shall have the end up to 1m and any cracked or broken areas completely
wrapped in polythene. Intact pipe sections greater than 2m shall have the ends
end up to 1m and any cracked or broken areas completely wrapped in polythene.
d. The access to the asbestos waste shall be guarded at all times by security
personnel.
Wetting Agent and Lock Down

e. It is strongly recommended to apply amended water containing a wetting agent
on the asbestos materials prior to removal so as to minimize the release of
asbestos fibers during the removal process. Electrical equipment is not likely to be
present in the excavated trenches but if electrical cables are present these should
be de-energized and isolated prior to the application of wetting agents.
f. The recommended wetting agent for the amended water to enhance
penetration should be 50% polyoxyethylene ester and 50% polyoxyethylene ether
or equivalent. The wetting agent shall be diluted in accordance with the
manufacturers’ instructions. As a fall back option household washing up detergent
mixed at 10% to amend wetting water can be substituted
g. Water based polyvinyl acetate adhesives (PVA) to be used as “lock down” for
spraying on to surfaces during the final clean up of the area shall be able to bind
traces of asbestos fibre which may remain on exposed surfaces. The adhesive
shall be dyed to indicate where it has been sprayed and facilitate a check as to
whether they have been applied or not and to facilitate cross-checking at a later
stage.
Lifting Gear & Ladders

h. All lifting appliances, i.e. wire slings, ropes and chain blocks, must comply with
the local construction sites safety regulations. Valid test certificates must be kept
on site for checking at all times.
i. Ladders shall be used in line with general safety procedures. Joints and ends
of ladders, scaffolds and parts of lifting gear where appropriate shall be sealed with
tape to prevent the incursion of asbestos fibers and finished to create a smooth
surface to facilitate cleaning.
29/03/08 Page 96 of 101

Respirators (dust mask)

j. The respirators to be provided by the CONTRACTOR shall be of an approved
type contained appropriate for protection against the level of asbestos fibers
reasonably expected in the particular stage and environment of work. In this case
half face dust mask shall be required.
k. The CONTRACTOR shall provide disposable paper respirators to all workers
with a protection factor of 4 (e.g. recommended 3M8812 or equivalent). The
CONTRACTOR shall also provide approved respirator(s) to the DOE - CDGK
Asbestos Specialist inspector as and when requested.
l. The respirators shall be removed when wet and be treated as contaminated
waste. A new half face dust mask shall be provided to each worker prior to each
shift, and the CONTRACTOR shall hold sufficient spare masks on site at all times
for replacement purposes.
Protective Clothing
m. The CONTRACTOR shall provide approved protective clothing to all workers.
He shall also provide approved protective clothing to the DOE – CDGK Asbestos
Specialist inspector as and when requested. Protective clothing shall consist of an
approved disposable full body coverall, with head cover. Hard hats and boots shall
also be made available by the CONTRACTOR. Coveralls will be of a disposable
type:
•made from material which does not readily retain asbestos dust and
•prevents, so far as is reasonably practicable, dust penetration;
•is close fitting at the neck, wrists and ankles; and
•without external pockets or unnecessary pleating or accessories.
Preferred disposable coveralls, mask and Workers handling drummed

sprayer high risk friable asbestos
29/03/08 Page 97 of 101

APPENDIX 3 continued - LABORATORIES IN PAKISTAN WITH CAPABILITY TO

IDENTIFY ASBESTOS
1.
Pakistan Council of Scientific & Industrial Research
PCSIR Labs Complex
Off University Road
Karachi
Tel#: +92-21-8141841
Fax#: +92-21-8141847
2.
National Physical and Standards Laboratory (NPSL), Islamabad
Plot No.16, Sector H-9
Islamabad
Tel#: +92-51-9257459, 9257462-7
Fax#: +92-51-9258162
3.
Pakistan Council of Scientific & Industrial Research
PCSIR Labs Complex
Ferozepur Road
Lahore
Tel#: +92-42-9230688-95,9230704
Fax#: +92-42-9230705
29/03/08 Page 98 of 101

APPENDIX 4 REVIEW OF ADB PROJECTS WITH ASBESTOS
Asbestos issues for Karachi Mega city Sustainable Development MFF subprojects.
1. Asbestos is internationally recognized as a hazardous waste. Many developed
and some developing countries have statutory controls on the manufacture, use,
handling, removal, storage and disposal of asbestos containing materials (frequently
referred to as ACM).
2. Whereas ACM were often materials of choice for many applications and used
widely in the second half of the 20th century, these materials have generally been
removed from most applications in developed countries because of the hazard and
replaced with materials with equivalent or better performance (e.g. asbestos cement
pipes replaced with high density polyethylene or UPVC).
3. Friable forms of asbestos (e.g. woven gaskets, acoustic plaster and thermal
plaster pipe insulation - high risk) can readily release asbestos into the environment with
potential carcinogenic effects in the lung and less commonly in the gastrointestinal tract.
All forms of asbestos (including cement and resin based ACM – low risk) can potentially
release asbestos if they are deliberately disturbed or abraded. Therefore controls are
placed on all forms of asbestos manufacture, use, handling, removal, storage and
disposal to reduce the release of asbestos fibres into environment to reduce the risk.
4. The engineering controls that need to be in place for non-friable (so-called) low
risk ACM (including cement based ACM) for handling, removal, storage and disposal, do
not require high-tech solutions and need not be expensive or difficult to introduce. The
controls will however require some other administrative controls to identify and track the
ACM waste “cradle to grave” to further reduce the risk.
Main concern for asbestos in Pakistan relevant to Karachi Mega City MFF subprojects
5. Typical of many developing countries Pakistan uses asbestos for many industrial
and commercial purposes. Best professional judgment suggests that at this stage
asbestos cement pipes have been typically been used in 50% to 70% of the Karachi
water supply pipe system which extends over thousands of kilometres. Much of this
system will be replaced by ADB supported project in the immediate future and in a rolling
programme over several years. There may well be other residual asbestos waste
entering the solid waste management work stream.
6. There are as yet no statutory controls on hazardous waste in Pakistan. The
Hazardous Substances Rules were drafted in 2003 but were never brought into force.
Asbestos waste is listed in the draft Hazardous Substances Rules 2003 (HSR). If
enacted the HSR would require an entity licensed under the Pakistan Environmental
Protection Act (1997) to have a waste management plan for any listed hazardous
substance.
SWM in Karachi Mega City MFF
7. The solid waste management Roadmap envisages one goal as “an effective
regulatory framework for the environmentally safe and healthy management of all
municipal and hazardous solid wastes generated in Karachi”
8. Therefore although hazardous waste management (HWM) in Karachi is in its
infancy, with no regulatory or legislative framework, and no institutional capacity or
funding at the Government level, the need for a HWM system has been recognized.
9. ADB may well be involved in HWM (therefore waste asbestos management)
corollary to the development of SWM in Karachi Mega City MFF. (N.B. Another ADB
29/03/08 Page 99 of 101

initiative, the RETA on Hazardous Wastes Management, covering Nepal, India,

Bangladesh and Bhutan is now underway).
10. The lack of a functioning HWM system in Karachi is of serious concern, as many
of the wastes are presumably being disposed of also through illicit dumping methods
throughout the city. This would presumably be the fate of any asbestos waste from the
MFF Tranche 1 projects if disposal of ACM is not controlled.
Standards for asbestos issues arising in Karachi Mega City MFF
11. ADB standards are guided by the World Bank Pollution, Prevention and
Abatement (PPAH) that requires asbestos disposal should be carried out in line with host
country regulations or following best international practice.
12. Therefore as there are as yet no local standards for asbestos control in Pakistan,
any known asbestos waste requiring removal should be disposed of following best
international practice. In the recently published ADB Guidelines on Environmentally
Responsible Procurement (2007) asbestos fibres are on the prohibited list but asbestos
cement sheets with less than 20% asbestos are exempted.
Way forward
13. In line with best international practice, a dedicated Asbestos Management Plan in
IEE / EMP for relevant subprojects for Karachi Mega City MFF should be developed. As
far as can be anticipated, dovetail the AMP with future developments in SWM and HWM
for Karachi and other MFFs in Karachi and other ADB experience and lessons.
14. Recommend that Under Karachi Mega City MFF TA (Option 1) or extend existing
ToR of international consultant (Option 2) to develop an interim an Asbestos
Management Plan for the Tranche 1 subprojects in Water Treatment and Supply and
SWM subprojects under the MFF.
Some projects mentioning Asbestos from ADB website
15. Asbestos has been identified as a concern in several projects in the table below
(this is not necessarily a complete list of all projects an exhaustive list.
Short I.d. Comment ADB website disclosure reference
Korangi RRP Not mentioned in SIEE http://www.adb.org/Documents/RRPs/PAK/rrp-
R15897.pdf
PAK PCR Mentions AC http://www.adb.org/Documents/PCRs/PAK/pcr-pak-
replacement as a 22302.pdf
benefit, no issues
flagged.
Malaysia: AC pipes referenced, http://www.adb.org/Documents/PCRs/MAL/in7_02.pdf
nothing flagged
Manila Water: referencing replacing http://www.adb.org/Documents/RRPs/IND/rrp-35068-
old AC pipes as a ind.pdf
benefit, nothing
flagged
India RRP mentions AC pipes but http://www.adb.org/water/actions/phi/Manila-Water-
doesn't flag any issues Reducing-NRW.asp
in handling
Cook Islands asbestos roofing: has http://www.adb.org/Documents/PPARs/COO/ppa-coo-
RRP # one footnote 24331.pdf
BAN RRP # Mentions AC pipes http://www.adb.org/Documents/Environment/BAN/36297-
and has Text below as BAN-SIEE.pdf
mitigation (?)
measures.
# see comments below
29/03/08 Page 100 of 101

One other power sector project for ADB Bangladesh Project

16. A contractor (demolition and construction) in Bangladesh working under ADB
funded Power plant project was looking for an asbestos demolition and disposal
Specialist/firm/inspector having license as it was apparently a requirement under ADB
funded project (personal approach to David Green as asbestos consultant mid 2007).
The asbestos handling contractor/Specialist/ Inspector was needed to work or supervise
a team for1-2 months engaged in demolition and disposal of asbestos in an old power
plant. No other details could be found on the ADB website
17. In the following paragraphs the text located at the specific location is quoted and
reviewed and [CONSULTANT OBSERVATIONS IN CAPS and SQUARE
PARENTHESES]
BAN RRP: http://www.adb.org/Documents/Environment/BAN/36297-BAN-SIEE.
18. Mitigation measures include: (i) damaged AC pipes will be left in place and the
replacement PVC pipes [THIS IS NOT MITIGATION BY INTERNATIONAL
STANDARDS] whenever possible will be laid parallel to the existing AC pipes [THIS IS
NOT RESPONSIBLE PROCUREMENT AS IT DOES NOT PROVIDE ANY CONTROL
TO DEAL WITH THE RESIDUAL ACM IF OTHERS HAVE TO DIG THE TRENCH
LATER];
19. Adequate space will be provided between the proposed and current alignments,
so that the excavation of trenches for the replacement PVC pipes will not expose the AC
pipes. [HOW CAN THIS BE ASSURED]? Left buried [IS NOT IN LINE WITH BEST
PRACTICE], impacts due to exposure to airborne asbestos fibers are eliminated; and
[BUT FUTURE EXPOSURE CANNOT BE RULED OUT, THEREFORE NOT
ELIMINATED]
20. Maintenance workers will be made aware that the old pipe is still there through
appropriate documentation and a marker layer. [OPTIMISTIC APROACH AT BEST – IN
BEST PRACTOCE AN ASBESTOS MANAGEMENT PLAN WOULD BE PUT IN PLACE
TO MAKE SURE THE ACM WAS MANAGED].
21. An asbestos management plan will be prepared by a qualified international
asbestos management consultant as part of the Project Consultants. Exposure to
asbestos can be prevented by containment, regular inspections, and proper precautions
when working around or with the material. [ACCEPTABLE BUT WHO WILL INSPECT -
DOUBTFUL IF ANY EXPERIENCED CONSULTANT WOULD RECOMMEND
DELIBERATELY LEAVING MATERIALS IN THE GROUND WHEN THEY COULD BE
REMOVED EASILY AND STOCKPILED EVEN IF DISPOSAL IS LATER].
22. [THE PROPOSED MEASURES ARE NOT IN LINE WIT BEST INTERNATIONAL
PRACTICE.]
Cook Islands RRP: http://www.adb.org/Documents/PPARs/COO/ppa-coo-24331.pdf
23 Asbestos cement sheeting is generally not hazardous if it is intact. But if it is
broken or damaged (e.g., during removals), it can become friable and release asbestos
fibres, which are a respiratory hazard and are respiratory and gastrointestinal
carcinogens. Precautions need to be taken during removal. [OK APPROPRIATE
RESPONSE WOULD BE TO HAVE AN ASBESTOS MANAGEMENT PLAN PREPARED
BY A QUALIFIED REGISTERED ASBESTOS CONSULTANT IN LINE WITH
RECOGNISED CODES OF PRACTICE ON SAFE HANDLING OF LOW RISK ACM].
24 The consultant could not identify reference text for asbestos in any of the
other reports
29/03/08 Page 101 of 101

IEE Water Sector - Mar 29, 2008

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Karachi Water and Sewerage Board

City District Government Karachi

Karachi Mega City Sustainable Development Program

Initial Environmental Examination

Document Stage: Final Report

The initial environmental examination is a document of the

II. DESCRIPTION OF WATER SECTOR SUBPROJECTS.........................9

III. DESCRIPTION OF ENVIRONMENT....................................................14

IV. ENVIRONMENTAL IMPACTS AND MITIGATION................................25

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VI. INSTITUTIONAL REQUIREMENTS AND

VII. FINDINGS AND RECOMMENDATIONS.............................................56

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Figure 1: Water Sector Subprojects.......................................................13

Figure 2: COD Filtration Plant.................................................................19

Figure 3: NEK Filtration Plant.................................................................20

Figure 4: Pipri to Landhi Pipeline...........................................................23

Figure 5: Pipri to Malir Pipeline..............................................................24

Figure 6: Location of Public Consultations...........................................37

Table 1: Ambient Air Quality in Karachi (µg/m3)...................................15

Table 2: Population of Karachi................................................................18

Table 3: Land Use Distribution for Filtration Plants.............................21

Table 4: Land Use Distribution for Pipelines.........................................22

Table 5: Summary of Public Consultation.............................................38

Table 6: Environmental Monitoring Plan for Tranche 1 Water Sector

Table 7: Summary of Estimated Costs for EMP Implementation.........54

Table 8: Operations Phase Environmental Monitoring Plan................55

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WEIGHTS AND MEASURES

LAWS AND REGULATIONS

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B Environmental Regulatory Compliance

C Environmental Category of Water Sector Subproject

D Objectives and Scope of IEE

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II. DESCRIPTION OF WATER SECTOR SUBPROJECTS

Water Supply to Karachi

4 Calculated from the data provided in the KMP

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5 Reported in the KMP.

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B Criteria for Site and Route Selection

Filtration Plant Extensions

Filtration Plant Extensions at COD and NEK Plants

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New Transmission Mains from Pipri to Korangi and Malir Town

Distribution Network Improvement Programs

D Projects Implementation Schedule

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Figure 1: Water Sector Subprojects

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III. DESCRIPTION OF ENVIRONMENT

A Environmental Profile of Karachi

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Maximum Minimum Average WHO Guidelines and

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Social and Cultural Environment

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Source Year Population (‘000) Annual Growth Rate

60.Literacy rates have constantly increased in Karachi, with substantial reduction in