Thar Coalfield Block VI 2x330MW Coal-fired Power Plant

Thar Coalfield Block VI 2x330MW Coal-fired Power Plant

Volume II: Environmental and Social Impact Assessment (ESIA)

March 2017

Oracle Coalfields PLC

366982 02 B Mott MacDonald

Mott MacDonald Victory House Trafalgar Place Brighton BN1 4FY United Kingdom T +44 (0)1273 365000 F +44 (0)1273 365100 mottmac.com

Oracle Coalfields PLC 6th Floor Two Kingdom Street London W2 6BD

Thar Coalfield Block VI 2x330MW Coal-fired Power Plant

Volume II: Environmental and Social Impact Assessment (ESIA)

March 2017

Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Road, Croydon CR0 2EE, United Kingdom

Oracle Coalfields PLC

Mott MacDonald | Thar Coalfield Block VI 2x330MW Coal-fired Power Plant Volume II: Environmental and Social Impact Assessment (ESIA)

366982 | 02 | B | March 2017

Issue and Revision Record

Revision Date Originator Checker Approver Description

A February 2017

Various Various

L. Stone

G. Clamp

I Scott

Draft for client comments

B March 2017

Various Various

L. Stone

G. Clamp

I Scott

Final

Document reference: 366982 | 02 | B

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-

captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being

used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied

to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other

parties without consent from us and from the party which commissioned it.

This report has been pr epared sol el y for use by the party which commissi oned it (the ‘Client’) i n connecti on with the capti oned proj ect. It should not be used for any other purpose. N o person other than the Client or any party who has expressl y agreed ter ms of r eliance with us (the ‘Reci pient(s)’) may rel y on the content, i nformati on or any vi ews expressed i n the repor t. We accept no duty of care, responsi bility or liability to any other r eci pient of thi s document. T his r eport is confi denti al and contains pr opri etar y intell ectual property.


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Contents

Glossary 1

1 Introduction 4

1.1 Overview 4

1.2 Project summary 4

1.3 Financing of the Project 6

1.4 Purpose of the ESIA report 6

1.5 Structure of the ESIA report 6

2 Project description 8

2.1 Overview 8

2.2 Site location 8

2.3 Power plant components 11

2.4 Construction phase 6

2.5 Operation phase 6

2.6 Decommissioning 7

2.7 Associated facilities 7

3 Project need and alternatives 9

3.1 Introduction 9

3.2 Project need 9

3.3 Analysis of alternatives 13

3.4 Summary 16

4 Policy, legal and institutional framework 17

4.1 Introduction 17

4.2 National institutional and legal framework 17

4.3 Sindh Environmental Protection Act 2014 17

4.4 Sindh Environmental Quality Standards 18

4.5 Requirements for environmental impact assessment in Sindh Province 18

4.6 International treaties and conventions 20

4.7 National and international non-governmental organisations 21

4.8 International standards and guidelines 21

5 ESIA process and methodology 22

5.1 Introduction 22

5.2 Impact assessment methodology 22

5.3 Cumulative impacts and transboundary impacts 25


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6 Information disclosure, consultation and participation 26

6.1 Overview 26

6.2 Consultation requirements 26

6.3 Stakeholder identification and analysis 27

6.4 Introducing stakeholders to the Project and the developments in Block VI 31

6.5 Disclosure and consultation on the draft ESIA 33

6.6 Stakeholder engagement planned throughout the lifetime of the Project 33

6.7 Project grievance redress mechanism 34

6.8 CLO contact details 37

7 Air quality 38

7.1 Introduction 38

7.2 Applicable legislation 39

7.3 Methodology and assessment criteria 42

7.4 Baseline description 55

7.5 Impact identification and assessment 56

7.6 Mitigation and enhancement measures 72

7.7 Residual impacts 73

8 Greenhouse gas 74

8.1 Introduction 74


8.3 Guidelines and policies 74





8.8 Summary 80

9 Noise and vibration 82

9.1 Introduction 82







10 Waste and materials 93

10.1 Introduction 93




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11 Hydrology, hydrogeology and flood risk 117








12 Landscape and visual 141

12.1 Overview 141

12.2 Assessment methodology 141


12.4 Likely impacts and assessment of significance 155



13 Ground conditions 165


13.2 Methodology criteria 165





14 Ecology & biodiversity 181




14.4 Baseline context 188




15 Social impact assessment 206


15.2 Applicable legislation and standards 207



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15.5 Likely impacts and assessment of significance 226

15.6 Potential risks 228



16 Cumulative impact assessment 236


16.2 Employment generation cumulative impacts 236

16.3 Influx of workers’ cumulative impacts 237

16.4 Landscape and visual amenity cumulative impacts 237

16.5 Noise cumulative impacts 238

16.6 Air quality cumulative impacts 238

16.7 Dust cumulative impacts 239

16.8 Hydrology and hydrogeology cumulative impacts 239

16.9 Summary 239

Mott MacDonald | Thar Coalfield Block VI 2x330MW Coal-fired Power Plant 1Volume II: Environmental and Social Impact Assessment (ESIA)

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Glossary

Acronym Definition

AEWA African-Eurasian Waterbird Agreement

AIS Alien invasive species

AoI Area of influence

BAP Biodiversity action plan

BAT Best available techniques

BOD Biological oxygen demand

CBD Convention on Biological Diversity

CDDIT Community Development Department of Information Technology

CEDD Coal and Energy Development Department

CFB Circulating Fluidised Bed

CIP Community investment plan

CITES Convention on International Trade of Endangered Species of Wild Fauna and Flora

CLO Community liaison officer

CMS Conservation of Migratory Species

COD Chemical oxygen demand

CPEC China-Pakistan Economic Corridor

CPPA Central Power Purchasing Authority

DEMP Decommissioning environmental management plan

ECA Employment of Children Act

EHS Environment health and safety

EIA Environmental impact assessment

EMF Electro-magnetic fields

EPC Engineering procurement and construction

EPRP Emergency preparedness and response plan

ESIA Environmental and social impact assessment

ESMP Environmental and social management plan

ESMS Environmental and social management system

ESP Electrostatic precipitator

EWC European waste catalogue

FGD Flue-gas desulphurisation

GDP Gross domestic product

GHG Greenhouse gas

GIIP Good international industry practice

GLVIA Guidelines for Landscape and Visual Assessment

GPS Global positioning system

HFO Heavy fuel oil

HSE Health safety and environment

IAI Immediate area of influence

IAIA International Association of Impact Assessment

IBA Important biodiversity area

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2

Acronym Definition IECC Information and Education Communication Centre

IEE Initial environmental examination IEMA Institute of Environmental Management and Assessment

IFC International Finance Corporation ILO International Labour Organisation

IUCN International Union for Conservation of Nature KBA Key biodiversity area

LAA Land Acquisition Act LCA Landscape character area

LAI Local area of influence LBOD Left bank outfall drain

LFO Light fuel oil LI Landscape Institute

LOR Limit of reporting LNG Liquified natural gas

LVIA Landscape and visual impact assessment MIGA Multilateral Investment Guarantee Agency

MSDS Material safety data sheet NEPRA National Electricity Pricing and Regulatory Authority

NEQS National Environmental Quality Standards NGO Non-governmental organisation

NIAP National Impact Assessment Programme NOC No objection certificate

NTDC National Transmission and Dispatch Company OHS Occupational health and safety

O&M Operations and maintenance Pak-EPA Pakistan Environmental Protection Agency

PAP Project affected people PEC Process environmental concentration

PEPA Pakistan Environmental Protection Act PC Pulverised coal

PMCCC Prime Minister’s Committee on Climate Change PPE Personal protective equipment

PPIB Private Power Infrastructure Board RO Reverse osmosis

SCA Sindh Coal Authority SEP Stakeholder engagement plan

SEPA Sindh Environmental Protection Agency SEPCO Shandong Electric Power Construction Company

SEQS Sindh Environmental Quality Standards SMEDA Small and Medium Enterprises Development Authority

SPDC Social Policy Development Center SWMP site waste management plan

TDS Total dissolved solids PAA Project affected area

UNFCCC United Nations Framework Convention on Climate Change WAI Wider area of influence


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Acronym Definition

WAPDA Water and Power Development Authority

WHO World Health Organization

WHS World heritage site

WRB World Reference Base

ZTV Zone of theoretical visibility


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1 Introduction

1.1 Overview

Pakistan currently imports much of its fuel for the production of electricity to power homes and

businesses. Electricity demand outweighs supply within the country; as such the Government of

Sindh is considering options for power generation. The Government of Sindh is pursuing coal to

power generation since the identification of the Thar Coalfield and as it is believed to be one of

the least costly energy generation options for Pakistan.

The Thar Coalfield which is located in the southeast of Sindh Province was discovered in 1980

and cover an area of 9,100km2 with total lignite coal resources estimated to be in excess of

175 billion tonnes. The development of the Thar Coalfield and the associated establishment of

coal to power projects are major objectives of the Government of Sindh, to achieve increased

power production, with associated economic growth to ultimately reduce poverty in the country.

The Thar Desert has one of the largest coal reserves in the world.

A mining lease was granted by the Directorate of Coal Mines Development, Government of

Sindh, in April 2012 for the Block VI area for a 30 year period, extendable for a further 30 years.

A major drilling programme was carried out as part of a technical feasibility study, undertaken by

SRK Consulting on behalf of Oracle Coalfields PLC (“the Developer), which confirmed the in-

situ coal deposit of 1.4bn tonnes within the Block VI area of the Thar Coalfield. The study

confirmed that an open-pit mine could be developed with a production capacity of 5 million

tonnes per annum (Mtpa) to support the first phase 660MW mine-mouth power plant (‘the

plant’). A second phase is to increase the capacity of the power plant to 1,320MW is expected

at a later date.

The Developer has commissioned Mott MacDonald Limited to undertake an environmental and

social impact assessment (ESIA) for the proposed 2 x 330 megawatt (MW) coal-fired power

plant (“the Project”) to be located in Block VI of the Thar Coalfield. The Project will be will be

constructed adjacent to the open-cut lignite coal mine that will be developed in Block VI.

1.2 Project summary

The Project will consist of a lignite fired power plant capable of generating 660MW gross of

electricity through 2 x 330MW generation units. Two circulating fluidised bed (CFB) boiler units

will be installed at the plant. Each boiler will provide steam for a steam turbine/generator unit

with a minimum electrical (gross) rating of 330MWe1. The Project will be connected to the local

grid through a 500kV substation which will be located at the boundary of Block VI. A project

description providing further detail is given in chapter 2.

Coal will be supplied to the Project from the Block VI open pit coal mine, which will also be the

responsibility of the Developer. Lignite coal will be transported from the mine stockpile to the

power plant by a covered belt conveyor, which will be owned and operated by the Developer.

In September 2014, the Developer signed an engineering, procurement and construction (EPC)

contract framework agreement with the Shandong Electric Power Construction Company

(SEPCO) for the construction of the Project. The Developer has registered the project with the

1 Two steam turbines will be provided for the project

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5

Private Power Infrastructure Board (PPIB).

Figure 1 below details the development process for the Block VI mining project and the Project.

Figure 1: Block VI project development process


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1.3 Financing of the Project

It is understood that China Exim Bank (and a number of other Chinese banks yet to be

determined at this stage) will provide finance for the Project. China Exim Bank expects that a

project’s host country EIA laws and regulations will be met in order for them to provide finance.

1.4 Purpose of the ESIA report

The Developer is required to complete an ESIA which will comply with the requirements of the

Pakistan Environmental Protection Act (1997) (PEPA) and the Pakistan Review of Initial

Environmental Examination (IEE) and the Environmental Impact Assessment (EIA) Regulations

(2000) to obtain the national approvals from the Sindh Environmental Protection Agency (SEPA)

and to seek finance for the Project.

Where appropriate, reference to international standards including the International Finance

Corporation (IFC) Performance Standards on Environmental and Social Sustainability 2012 (IFC

PS) and good international industry practice (GIIP) has been made.

Further detail on the regulations and international standards and guidelines applicable to this

ESIA are provided in chapter 4.

The objectives of this ESIA are to:

1. Comply with Pakistan’s legal and institutional framework for undertaking an ESIA

2. Comply with China Exim Bank environmental standards

3. Identify and assess social and environmental impacts caused by the project, both adverse

and beneficial, in the Project’s area of influence (AoI)

4. Avoid, or where avoidance is not possible, minimise, mitigate or compensate for adverse

impacts on workers, affected communities and the environment

5. Promote social and environmental performance through the use of management systems

A gap analysis of previous assessments undertaken for the Project was completed to define the

terms of reference for this assessment and to identify the key environmental and social aspects

and potential impacts relevant to the Project. The degree of appraisal required for each aspect

will differ in accordance with potential significance of impact. While this ESIA aims to identify

both positive and negative impacts associated with the development of the project, it is

inherently more focused on describing and mitigating potential negative impacts. Where

possible, opportunities to enhance positive impacts have been identified. Further discussion

relating to the ESIA methodology is addressed in chapter 5.

A separate EIA for the lignite mining activities at Block VI has been completed by Hagler Bailly

and later updated by Wardell Armstrong and necessary permits have been obtained.

1.5 Structure of the ESIA report

This ESIA comprises of four volumes organised as presented in Table 1. This document forms

Volume II of the overall ESIA documentation.


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Table 1: Structure of this ESIA

Volume No. (and contents) Title

Volume I Non-technical summary

Volume II Environmental and social impact assessment

Chapter 1 Introduction

Chapter 2 Project description

Chapter 3 Project need and analysis of alternatives

Chapter 4 Policy, legislative and institutional framework

Chapter 5 ESIA process and methodology

Chapter 6 Information disclosure, consultation and participation

Chapter 7 Air quality

Chapter 8 Greenhouse gas

Chapter 9 Noise and vibration

Chapter 10 Waste and materials management

Chapter 11 Hydrology, hydrogeology and flood risk

Chapter 12 Landscape and visual

Chapter 13 Ground conditions

Chapter 14 Biodiversity and ecology

Chapter 15 Social impact assessment

Chapter 16 Cumulative impact assessment

Volume III Technical appendices

Volume IV Environmental & social management (and monitoring) plan (ESMP)

Contact details for enquiries on this ESIA are given in Table 2 below:

Table 2: Contact details

Project proponent Information

Name of Company Oracle Coalfields PLC

Address 6th Floor

2 Kingdom Street

London

W2 2PY

Telephone 02035804314

E-mail [email protected]

Website www.sindhcarbonenergy.com


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2 Project description

2.1 Overview

This chapter provides a description of the project location, proposed Project and its associated

facilities.

2.2 Site location

The Project site is located in the southeast corner of the Sindh Province of Pakistan in the Thar

Desert. Block VI occupies the southern part of the Thar Coalfield and covers an area of

approximately 66km2. The Project site within Block VI is located approximately 380km northeast

of Karachi and 20km northeast of Islamkot and 77km east of Mithi. Figure 2 presents the

regional location of Block VI and Figure 3 shows the location of Block VI within the Thar

Coalfield.

Two main villages Ranjho Nun and Kharo Jani are located within Block VI, with other small

villages located in and around Block VI. Figure 4 shows the Project in the setting of Block VI.

Figure 2: Regional location of Block VI

Source: ESIA for Block VI Lignite Mining Project, Hagler Bailly Pakistan, 2013


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Figure 3: Location of Block VI within Thar Coalfield

Source: The Developer


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Figure 4: Project setting

Source: Mott MacDonald


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2.3 Power plant components

Thermal power plants generate electricity by burning fuel (in this instance lignite), which heats water to

generate high temperature, high-pressure steam, which drives a steam turbine. At one end of the

steam turbine is a condenser. As steam passes from the boiler to the condenser, it passes through the

steam turbine thereby rotating the turbine blades and generating electricity.

The key components of the Project to be located within Block VI include:

● Coal yard

● 2 x 330MWe generation units

● A substation that will connect to an existing 500kV transmission line

● One 210m exhaust stack

● Cooling water system

● Ash yard (providing temporary storage)

● Ash disposal area

● Access roads

● On-site accommodation, office facilities, fire station, workshop and open materials storage area.

Figure 5 illustrates the plant layout.


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Figure 5: General plant layout

Source: SEPCO (2016)


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Figure 6 provides a conceptual visualisation of the Project. The coal stockyard is in the

foreground with a conveyor delivering coal to the boiler in the centre and the two generating

units. The two cooling towers towards the rear of the plant.

Figure 6: Power plant conceptual view

Source: SEPCO (artist’s impression)

2.3.1 Fuel

The Developer will operate the Block VI open pit lignite mine will supply coal to the plant from

the Block VI coal deposits. Covered belt conveyors owned and operated by the Developer will

transport coal from the mine to the plant.

The Plant will be designed to meet performance objectives (ie output) and all emissions limits

applicable with the fuel specification design range.

2.3.2 Additional key operating materials

An injection of limestone directly in to boiler is required to reduce sulphur emissions to

appropriate levels. The limestone powder is transported to the project by truck. It is combusted

in the boiler for desulphurisation of the flue gas at an estimated rate of 600 tonnes/day over 24

hours.

Light diesel oil will be used for boiler start-up and flame stabilisation during low-load operation.

The fuel oil system stores fuel oil in tanks and supplies it with transfer pumps to the boilers

during start-up or shut-down activities.


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2.3.3 Coal handling and storage

A three-part conveyor system will be utilised for unloading the delivered coal, transferring

crushed or pulverised coal from a stockpile to the storage bunkers and delivery of the pulverised

coal to the boiler. Two coal storage yards will be utilised for the project. Dust from the coal

storage yards will be controlled by a permanently mounted water sprinkler system using

recycled process water.

The estimated storage capacity of the coal storage yards is a combined 65,000 tonnes, which is

equivalent to five days’ consumption while operating two boilers at full capacity. The coal

stocking area is concreted and will be uncovered. Water drainage, collection and subsequent

treatment will be provided. Temperature monitoring equipment will be used to reduce

spontaneous combustion fire risk from the coal stockpiles (lignite is prone to spontaneous

combustion during transport and storage).

The boiler fuel system will comprise four coal storage bunkers (per boiler) with an estimated

total capacity of 625m3 and eight coal feeders per boiler.

2.3.4 Generation units

Two circulating fluidized bed (CFB) boiler units will be installed at the Plant. The fluidized bed

material will be made from sand sourced from the desert. Each boiler will provide steam for a

steam turbine/generator unit with a minimum electrical (gross) rating of 330MWe2. CFB

technology allows for relatively high combustion efficiency of the fuel. It separates solid particles

from the hot flue gases. The larger solid particles that have not been fully combusted in the

furnace will be returned to the furnace to undergo the combustion process again.

The benefits of using CFB boiler technology are as follows:

● Reduction in levels of nitrogen oxides (NOx) as a result of the low combustion temperatures

● Reduction of sulphur dioxide (SO2) emissions – through the use of limestone and low

combustion temperatures.

● Fuel flexibility – a wide range of fuel characteristics can be used in a single boiler.

It is estimated that approximately each boiler will consume 718,896 tonnes coal per year.

2.3.5 Boiler air and gas system

Flue gas will be transported through the boiler by the boiler air and gas system, which also

supplies combustion air to the boiler. The flue gas leaving the furnace passes through large

cyclones which recirculate larger particles transported with the flue gases back to the fluidized

bed. Lighter fly ash and the remaining flue gas pass through the convective elements of the

boiler i.e. the superheater, reheater and economiser, which transfer heat from the flue gases to

the water and steam of the steam cycle. The feed water is heated in the economiser, while the

superheater and reheater heat the steam supplied to the turbine.

To remove the entrained fly ash and un-reacted limestone from the desulphurisation process,

cooled flue gas is passed through an electrostatic precipitator (ESP) flue gas cleaning system.

An ESP is a filtration device that removes fine particles from flue gas using the force of an

induced electrostatic charge. Fans will then discharge the cleaned flue gas into the atmosphere

via the stack. The project will also allow for the future installation of fabric filters.

2 Two steam turbines will be provided for the project


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2.3.6 Steam turbines

The boiler steam system transfers superheated and reheated steam between the boiler and the

turbine. The main steam system delivers superheated steam to the high-pressure turbine, while

the reheat steam system returns exhaust steam from the high-pressure turbine to the boiler,

where it is again heated before being supplied to the intermediate pressure turbine. Steam from

the boilers feed to the condensing and reheat turbine generators.

2.3.7 Cooling towers

A closed-cycle circulating water system with natural draft cooling towers will be adopted by this

project. In closed systems the warm process water is cooled down by recirculating it through

cooling towers. Although there are some evaporative losses of water in closed systems, the

majority of the water is conserved. Evaporation losses are estimated to be 1,160m3/h and drift

losses are expected to be approximately 38m3/h. Each cooling tower will be 125m in height with

a diameter of 98.8m at the base of the structure.

2.3.8 Flue stack and emissions abatement technology

A single cylinder stack is proposed for the project which will be 210m in height.

Table 3 provides a summary of the abatement technologies that will be used to control

emissions from the plant and the emissions levels that the project will achieve.

Table 3: Emissions abatement technology implemented on the Project

Emissions Emissions abatement Guaranteed plant emissions

Sulphur oxides (SOx) Direct injection of limestone powder into the CFB boilers

≤650mg/Nm3

Oxides of nitrogen (NOx) Relatively low combustion temperatures and staged air injection in the CFB boilers generally result in less generation of thermal NOx compared to other boiler technologies.

≤350 mg/Nm3

Particulates ESP’s will be installed to remove particulate matter from the flue gas prior to exiting the stack.

≤50 mg/Nm³

The provision for retrofitting for further emissions abatement (i.e. fabric filters) and carbon

capture and storage has been incorporated in the project design.

2.3.9 Ash handling, storage and disposal

Through the coal combustion process both bottom ash and fly ash will be generated as

residuals and will be disposed of through the ash handling system. Bottom ash will be collected

with slag-coolers, conveyed to a bucket and the bucket will be lifted to a slag storage silo. There

will be one bottom slag storage silo with the capacity for holding the production for 24 hours.

The dry fly ash system will consist of the conveying system, fly ash storage, unloading system

and fluidising air system. Fly ash in the electrostatic precipitators will be discharged into the fly

ash silo through a conveyor system and pipeline. Currently, three concrete fly ash silos are

planned to be installed with the capacity to store 30 hours of production at the site.

The ash removal volume for the project is detailed in Table 4.


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Table 4: Ash removal volumes

Item Design coal

Ash volume t/h 48.5

t/d 1,067.4

t/a 343,600

Slag volume t/h 48.6

t/d 1,070.3

t/a 344,700

Total volume of ash and slag t/h 97.2

t/d 2,137.6

Source: EPC contactor – technical description

Note：

1. Utilisation hours in a day is counted as 22h; Utilisation hours in a year is counted as 7000h.

2. The ratio of fly ash shall be 0.5; dust collection efficiency is 99.7%

The Developer will be responsible for transportation and disposal of ash, which is expected to

be at the Block VI mine site. The ash disposal facility will be located in the worked out mine. Ash

will be transported form the project site to the mine via trucks with a capacity of approximately

50 tonnes. Although conceptual designs of the facility are not available at this stage in the

project development, the following features and components are recommended:

● 25 years of capacity for ash storage

● A geomembrane and geosynthetic lining designed to international requirements

● Cellular design

● Appropriately designed slope gradient and height to facilitate water run-off

● Storm-water drainage system that separates clean and dirty water.

In addition, discussions between the Developer and relevant stakeholders will be consulted to

ascertain whether there is a potential for commercial use for the fly ash (eg blocks or cement

manufacturing) and bottom ash (eg road construction) within Pakistan.

2.3.10 Water supply and demand

There are no rivers within Block VI; however, three primary aquifers have been identified in the

mine EIA report, comprising the Deep, Middle and Top aquifers. Three options have initially

been proposed for water supply for the Project:

● The Deep aquifer

● Top and Middle aquifers which will be dewatered during the mining process and sent to a

mining dewatering facility located outside of the project area.

● Pipeline / reservoir from a Government source.

Based on information available it is expected that large volumes of water will be required to be

extracted from this aquifer for the lifetime of the Project, which could supply the Project.

Water in the Project area is considered saline/brackish, with high levels of chloride, and will

therefore require demineralisation prior to use as process water. A reverse osmosis (RO)

treatment facility is proposed and will be located within the Project site.

In addition, the Government of Sindh is constructing an alternative water supply from the Left

Bank Outfall Drain (LBOD) at Nabissar, along with a large RO plant and lined reservoir, and is


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linking this with the Thar Coalfield via a pipeline to Vejihar where a further large lined reservoir

has been constructed. The total supply capacity of this scheme is approximately 3,100L/s

(269,000m3/d) and individual block holders can apply for a water supply agreement to allow

them to access the reservoir at Vejihar and pipe water to their block. It is understood that the

Government of Sindh has approved the provision of approximately 1,080L/s (93,000m3/d or 38

Cusec) for Block VI from the LBOD phase II water source or Makhi Faresh link canal, subject to

the execution of a water use agreement between the relevant parties.

These combined water resources should safeguard water supply throughout the duration of the

Project. A summary of the water demands for the Project is presented in Table 5.

Table 5: Projected water demand

Power Plant Use Water demand (m3/day)

Fresh water Potable water 240

Brackish / fresh water Cooling / wash down / dust suppression 44,400

Source: RPS Aquaterra Thar Block VI Water Supply & Disposal (February 2017)

The plant will have a potable water pond, with a capacity of approximately 100m3, and a potable

water system with a treatment capacity of approximately 10m3/h.

2.3.11 Wastewater treatment

2.3.11.1 Sewage treatment

Domestic wastewater will be treated biochemically. The design capacity of this system is 240t/d

domestic wastewater. The treated wastewater will then be discharged into an adjustment pool

before being discharged to two buried treatment facilities, where the wastewater will be

biochemically treated.

2.3.11.2 Oily waste water treatment

The oil waste water from the fuel oil storage and unloading area, boiler room and transformer

yard area will be collected in a sump before being treated by an oil separator, in which the

treatment capacity is 10m3/h. The treated oily wastewater will then flow to a central monitoring

basin. Grey water will be recycled and reused for coal dust suppressing and by the ash wetting

system. Opportunities for the reuse of waste oils will be investigated by the EPC contractor.

Final disposal will be included in the site waste management plan (SWMP).

2.3.11.3 Coal yard storm water treatment

Storm water from the coal yard will be collected by a drainage system and discharged to a coal

particle settling basin. The coal particle settling basin will have two chambers, one operating

and one standby. When one chamber will be full, the second chamber will utilised. A coagulant

aid/polymer dosing facility will be provided at the inlet to the settling basin. Wastewater will be

discharged via a pipeline to a final settling lagoon and will then be discharged into the mine

stormwater drainage system.

2.3.11.4 Storm water drainage system

An open ditch drainage system shall be adopted for the storm drainage system for the rest of

the project. The design and drainage ditch size/capacity is yet to be finalised. The storm water


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from the Power Plant complex will either flow by gravity or will be pumped into the mine storm

water drainage system prior to discharge from Block VI.

2.3.12 Emergency power supply

Two 630 kilowatt (kW) diesel generating sets will supply power to the essential loads in the

whole plant in the event of complete loss of normal supply. The diesel generators will provide

power for the safe shut down of the boilers and turbines and for the essential operation of the

critical loads and facilities such as the plant control system, communication system, emergency

lighting and small power outlets.

2.3.13 Site access

Site access will be from Karachi by a road that runs through the towns of Thatta, Badin, Mithi

and Islamkot. An access road of approximately 6km in length will be constructed as part of the

EPC contracts for the mine and power plant to facilitate access to Block VI. There will be two

entrances and exits at the site and will include 20m wide extending gates.

2.4 Construction phase

The construction area will consist of a boiler assembly yard, turbine maintenance and assembly

yard, concrete batching plant and sand/stone yard, concrete reinforcement processing yard,

equipment yard and temporary spoil dump which is expected to occupy an area of

approximately 157,500m2.

Approximately 1,000 workers are expected to be employed during peak construction, 60% of

which will be Pakistani nationals. The accommodation camp area is separated from the

construction area, adjacent to the project site, and will occupy an area of approximately

22,500m2. In total the land area for construction is about 180,000m2.

The construction phase is expected to start in 2018, last for 40 months and will involve key

activities including:

● Site clearance

● Vegetation removal

● Earthworks

● Water supply, waste disposal and wastewater treatment

● Site access, traffic and transport.

Temporary facilities, including temporary offices and accommodation blocks will be provided for

both the mine and the power plant whilst the permanent site facilities are constructed.

A landfill will be constructed in the worked out mine and will be designed to international

standards. Further details are provided in Table 6.

2.5 Operation phase

Commissioning of the Project is planned to commence in 2020 and operational by 2021. The

operation phase is estimated to be for a minimum of 30 years. The plant is expected to operate

at 100% capacity for 7,400 hours per annum. Local labour will be used as much as possible

during the operation phase through upskilling or capacity building in the area.


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2.6 Decommissioning

Upon end of life of the Project all hazardous wastes will be removed and sent for safe disposal,

either within the industrial areas solid waste disposal area or under license by a third party

contractor. A full ground investigation, including soil and groundwater monitoring, will be

undertaken in and around all project areas to identify any contamination. If contamination is

identified, a remedial programme should be elaborated as part of decommissioning.

Remaining plant will be considered for re-use and recycling following dismantling. A dedicated

decommissioning strategy should be developed in advance of the end of Project life which

includes industry best practice at the time of decommissioning.

2.7 Associated facilities

Table 6 overleaf details the Project’s associated facilities and supporting infrastructure.

Associated facilities are items of infrastructure that are required to enable or support the Project

but do not form part of the project responsibilities of the Developer with other agencies

responsible for their development. Supporting infrastructure will also be required to facilitate the

operation of the Project and is the responsibility of the Developer to construct and operate; at

the time of writing, no conceptual designs had been produced.


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Table 6: Associated facilities and supporting infrastructure for the Project

Associated/ supporting components Summary Detail Responsible party

Associated facilities

Transmission line Power will need to be exported from the power plant to the national grid.

A new transmission line is proposed which will connect the power plant to the existing 500kV Jamshoro substation. The transmission line will be approximately 160km in length. The transmission line will largely traverse rural areas and is being designed and developed by the Government of Sindh.

National Transmission and Dispatch Company (NTDC)

Substation To export the electricity generated by the Plant,

A new substation will be developed at Block VI. The substation will connect the project and the transmission line to the national grid.

NTDC

Access roads Permanent paved access roads required for construction and operation vehicle and plant access.

To facilitate access to the mine and power plant, the Government of Sindh have commissioned construction of an 8km access road, which will be connected to a local highway to the south of the project.

Government of Sindh

Wastewater discharge pipeline

Any wastewater which cannot be reused in the process will be discharged off site in accordance with national discharge limits.

The detailed route of the wastewater discharge pipeline is yet to be determined.

Government of Sindh

Supporting infrastructure

Landfill site No appropriate waste disposal facilities are located in the area. The Developer will have a duty of care to ensure that the waste is disposed of in an environmentally sound manner

Details of the landfill site have not been provided; however, it is expected that the landfill will be developed within the mine.

The Developer

Ash disposal facility Ash disposal facility required to dispose of fly and bottom ash generated during operation

Details of the ash disposal facility have not been provided; however, it is expected that the landfill will be developed within the mine.

The Developer

Raw water supply pipeline

Government of Sindh will be responsible for providing a water supply source (in addition to the dewatering undertaken at the mine) to the site, which is sourced from the Vejhiar Reservoir.

The Government of Sindh Energy Department has confirmed that the project will be considered for the provision of 38 cusecs either from left bank outfall drain (LBOD) phase II water source or the Makhi Farash link canal.

The detailed route of the water supply pipeline is yet to be determined. The pipeline is expected to be approximately 15km in length.

The Developer


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3 Project need and alternatives

3.1 Introduction

This chapter sets out the needs case for the Project in the context of economic, socio-economic

and market factors in order to evaluate whether there are sufficient drivers to justify

development of the Project. This section also provides analysis of the suitability of the site

selection and potential alternatives.

The significant alternatives considered for the Project are broadly categorised as follows, and

discussed in more detail below:

● Project need

● No project option

● Site alternatives

● Options and alternatives for key technical and process aspects of the Project.

3.2 Project need

3.2.1 Introduction

Historically, electricity in Pakistan was generated, transmitted, distributed and supplied to

consumer by a single entity, the Pakistan Water and Power Development Authority (WAPDA),

except in Karachi where the functions was carried out by the Karachi Electric Supply Company.

Structural changes and new policies developed during the past two decades have resulted in

devolution of WAPDA into 11 separate companies for thermal and hydroelectric power

generation, transmission and distribution. In addition, there are around 20 independent power

producers that contribute significantly in electricity generation in Pakistan.

Despite these measures, Pakistan is not meeting the country’s electricity needs resulting in

chronic power cuts in the main cities and prolonged power outages in rural areas of between 12

and 16 hours per day. Electricity generation in Pakistan has shrunk by up to 50% in recent

years due to an over-reliance on fossil fuels. In its state of industry report 2014, the National

Electricity Pricing and Regulatory Authority (NEPRA) projects that the existing shortfall in

generating capacity of 5,500MW will continue until at least 2020 despite new capacity coming

on stream during this period as demand continues to rise. In 2016, the IFC also estimated that

the power shortage was between 3,000 and 6,000MW. Although, the Government of Pakistan

has taken various measures to bridge the gap between supply and demand of the electricity,

the energy crisis is anticipated to worsen in the coming years due to increase in demand and a

host of other factors on the supply side. The most critical of these are the depleting natural gas

reserves in the country which are the primary fuel for thermal power plants, failure to develop

new hydroelectric energy resources and inadequate investment in the power sector. The

country has increased its dependency on imported fuel. It is essential to take measures that

decrease the dependence of the country on imported fuel and improve energy security through

the development of Thar coal deposits to generate electric power from in-country coal

resources. The Government of Pakistan is also committed to increasing energy supply to foster

economic and social development.


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3.2.2 Energy production in Pakistan

Currently Pakistan’s energy portfolio, detailed in Figure 7, is primarily dominated by natural gas

and oil with at least one third of power being reliant on imported oil.

Pakistan’s discovered crude oil reserves are about 937 million barrels of which 583 million

barrels have already been produced. Oil dominates Pakistan’s energy portfolio not only

because of the need for liquid fuels for transport but also because one third of installed power

generation capacity is reliant on imported furnace oil. Furthermore, dependence on imported oil

is increasing as oil takes a larger share in generated energy due to domestic gas shortages.

Figure 7: Primary energy supply mix

Source: HDIP Pakistan Energy yearbook 2014

There is future potential for electricity imports from large-scale regional electricity transmission

projects, gas imports through regional pipelines and liquified natural gas (LNG) imports but

these all remain under discussion with long lead times.

The country has started diversifying its energy producing capacity by investing in wind and solar

energy parks to help offset the energy shortage while larger hydroelectric projects and new

nuclear plants are under construction; however the country still faces electricity shortages.

The Thar Coalfield based thermal generation projects are one viable option that will provide the

necessary resource which is indigenous, so that it provides energy security, economical and

less dependent on availability of foreign exchange. Its key advantages are discussed inthe

sections below.

3.2.3 Pakistan’s future energy requirements

The Government of Pakistan has given the highest priority to improving the efficiency of the

electricity supply; and also to implement conservation measures. Installed generation capacity

was 19,566MW in June 2008 and current transmission and distribution losses (technical and

non-technical) are estimated at about 25% of total generated power. The Government of

Pakistan has recognised that the electricity distribution system requires considerable upgrading.


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The Power Policy 2013 committed to improving the efficiency of the current system and

encouraging future generation projects throughout the country.

As set out in the Energy Sector Assessment for USAID/Pakistan (2007), the Government of

Pakistan aims to enhance energy supply in Pakistan sustainably while reducing the

dependence on imported oil and gas. Policy measures identified in this document include:

● Enabling a financial recovery, especially in the power sector

● Implementing a social protection programme to assist the poor in receiving a minimum

amount of affordable energy

● Streamlining Government of Pakistan’s institutional set-up in the energy sector to increase

decision-making efficiency

● Increasing private sector participation including through public private partnerships (PPPs)

● Enhancing regional energy trade.

Based on information provided by the NTDC3, it is expected that total energy demand is

expected to increase by factors of between 5.6 to 8.2 times over from 2007 to 2030.

The Government of Pakistan expects a significant demand supply gap to remain in the short to

medium term, even after the concerted promotion of energy conservation and energy efficiency,

and the expanded deployment of lower-carbon energy resources such as indigenous

hydropower, natural gas, and renewables.

In order to address both the overall economic downturn and energy shortages within this

framework it is essential that Pakistan moves forward with its energy sector reform program.

The Government of Pakistan, together with the World Bank and other development partners,

have been working closely to address current challenges as well as to devise and implement a

strategy for sustainable sector development for the medium to long term. Development of the

domestic coal-to-power sector is seen as part of a broader portfolio and the Government of

Pakistan is aiming to increase coal’s share in Pakistan’s power consumption from 1% to 25% by

2025. This will include parallel action to develop domestic renewables including hydropower (to

complement base-load energy production) and low carbon options, including potential for coal

bed methane development, as well as improved energy efficiency and demand side

management. These actions will provide increased energy security.

3.2.4 Government support

The project has strong support from both the federal and Sindh Governments and a number of

fiscal and financial incentives are in place:

● The Thar Coalfield provides fiscal incentives and tax breaks for the life of the Project

● The China-Pakistan Economic Corridor (CPEC) has included coal and power projects being

developed in Thar as being priority projects. The Chinese Government and Chinese banks

will finance Chinese companies investing in approved commercial projects in the corridor.

Total financing is expected to be approximately $46bn USD with the financing of energy

projects expected to be $34bn USD. The inclusion of the Developer’s Block VI integrated

coal mine and 660MW power plant is indicative of the support given by the Chinese and

Pakistani Governments.

● The Government is promoting the use of Thar Coalfield as an alternative to imported oil and

gas

3 NTDC (2008) Electricity demand forecast (2008-2030) http://www.ntdc.com.pk/LoadForecast.pdf


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● The Government of Sindh has committed strong support for Thar coal through the

establishment of:

– The Energy Department

– Sindh Coal Authority

– Coal Mines Development Department

– Thar Coal and Energy Board

● The Central Power Purchasing Authority (CPPA), a division of the NTDC, a government

body which owns and operates the high voltage network in Pakistan, has issued a no

objection certificate in November 2015 for the construction of the project.

● The Government is in the process of constructing major infrastructure improvements in Thar

to facilitate mine and power development, including upgrading and constructing new roads

from Karachi to Thar, constructing a new airport to serve the coalfield, as well as

constructing and upgrading new high voltage transmission lines for power evacuation.

3.2.5 Current status of development of the Thar Coalfield

As of January 2013, the Government of Sindh had identified 12 potential coal development

blocks towards the south of the coalfield area where the coal seams are thickest and nearest to

the surface, with two more blocks nearby in the development stage. The blocks occupy an

extensive area which has implications for ease of access and servicing.

The blocks, which are to be leased to developers, vary in size from 48km2 to over 200km2. Each

block developer will be expected to develop their own block but certain infrastructure may be

shared. It should be noted that the blocks are not likely to be exploited simultaneously and there

could be significant gaps of 20 years or more between the development of adjacent blocks.

Block VI covers an area of 66km2.

3.2.6 Fuel supply

The Thar desert has one of the largest coal reserves in the world. SRK Consultants assessed a

JORC4 mineral resource in Block VI of 529 million wet tonnes of lignite (refer to Table 7).

Although the coal is low grade lignite, it is commercially viable with a low sulphur and ash

content and a high moisture (46%) content. Average gross calorific value of the lignite is 3,182

kcal/wet kg.

Table 7: JORC compliant mineral resources

Mineral resources

Tonnage (Mt)

Moisture (%) RD (wg/cm3)

Gross CV (kcal/wkg) Ash (%) Sulphur (%)

Measured 151 48.0 1.15 3,025 5.10 0.60

Indicated 308 45.3 1.15 3,257 5.60 0.91

Subtotal 459 46.2 1.15 3,181 5.44 0.81

Inferred 70 45.4 1.15 3,193 8.90 1.58

Total 529 46.1 1.15 3,182 5.89 0.91

Electrical power generation in Pakistan from coal is projected to increase from its current 1% to

25% by 2025 according to the Government of Pakistan’s national power policy. This will

significantly increase the share of electricity from indigenous sources.

4 The Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves ('the JORC Code') is a professional

code of practice that sets minimum standards for Public Reporting of minerals Exploration Results, Mineral Resources and Ore Reserves


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As the Project will be at the mouth of the Block VI mine, coal does not need to be transported

far, which makes the process very efficient.

3.3 Analysis of alternatives

3.3.1 ‘No project’ alternative

The ‘no project’ option considers the position if the proposed Project does not proceed. It

assumes that no development would take place and the existing baseline situation would

remain.

This option was not considered as an option due to the energy crisis in Pakistan and the need

for power to boost the national economy. The importance of a power generation project in

overcoming Pakistan’s energy shortages is evident and is discussed in Section 3.2. The

proposed project could help to close approximately 10% of the current gap of 3,000MW to

6,000MW between supply and demand during peak hours. Without the proposed Project, this

gap will continue to grow and have a negative impact on Pakistan’s economy and electricity

supply.

The proposed Project could also help to attract future investments into the area where Thar coal

has thus far remained untapped. By proving the business case for such developments, not only

can Pakistan’s electricity supply increase but business prospects and investor confidence can

also be boosted thereby reducing pressure on the country’s balance of payments.

The Project will result in job opportunities during the construction and operational phases. It is

expected that the Project will provide good quality direct employment and training opportunities

for local people. The Project will also stimulate secondary economic activity in the form of

suppliers and other local service providers that will be supported by the increased income of

people working at the Project.

With a ‘no project’ alternative, the current situation would remain and none of these benefits

would be realised.

3.3.2 Site alternatives

When assessing the suitability of a project site the location is often driven by all or a selection of

the following factors:

● Designation of site for the use of land – the Project site is within an area designated for

strategic coal to power development by the Sindh Government.

● Proximity to sensitive receptors – no settlements are expected to be impacted by the

proposed power plant development. It is not located in an area of ecological significance

and the impacts on flora and fauna are not expected to be significant.

● Proximity to raw materials/fuels - the proposed project is located adjacent to the Block VI

mine, which will minimise the need for transportation of the lignite. The Thar region lacks rail

connection to the rest of the country so other location options are limited.

● Proximity to connections for utilities – the Government of Sindh will construct a 500kV

transmission line for power evacuation and is investing in infrastructure development

initiatives such as building new roads to the coal fields.

● Proximity to newly created or refurbished infrastructure to transport raw materials to the site

during construction.

● Availability of water for the closed-cycle cooling system to be sourced from the mines and a

pipeline to be developed by the Government of Sindh.


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As discussed in section 1.1, the development of the Thar Coalfields and the associated

establishment of coal to power projects are one of the major objectives of the Government of

Sindh, to achieve increased power production, with associated economic growth to ultimately

reduce poverty in the country.

3.3.3 Technology alternatives review

The choice of system employed at a facility is based on economic, technical, environmental and

local considerations such as availability of fuels, operational requirements, market conditions

and network requirements. This section briefly appraises the options available for the project

following the principles of best available techniques (BAT) which is used to assess best practice

given the context of a development, as well as highlighting which options have been chosen.

This section references the European Commission’s BAT Reference (BREF) Notes for Large

Combustion Plants (LCP) 2006 and Best Available Techniques (BAT) Reference Document for

the Large Combustion Plants Draft 1 (June 2013) which set out what would constitute BAT in

terms of a coal fired power plant in Pakistan. This is relevant because it demonstrates that the

techniques being employed by the project are considered the best available based on

economic, technical, environmental and local considerations such as the availability of fuels, the

operational requirements, market conditions, network requirements.

A clear and comprehensive definition of BAT is provided within the European Union Directive

96/61/EC in article 2.11:

● "best available techniques" shall mean the most effective and advanced stage in the

development of activities and their methods of operation which indicate the practical

suitability of particular techniques for providing in principle the basis for emission limit values

designed to prevent and, where that is not practicable, generally to reduce emissions and

the impact on the environment as a whole:

● "techniques" shall include both the technology used and the way in which the plant is

designed, built, maintained, operated and decommissioned;

● "available" techniques shall mean those developed on a scale which allows implementation

in the relevant industrial sector, under economically and technically viable conditions, taking

into consideration the costs and advantages, whether or not the techniques are used or

produced inside the Member State in question, as long as they are reasonably accessible to

the operator,

● "best" shall mean most effective in achieving a high general level of protection of the

environment as a whole.

The main issues relevant to this review were deemed to be the choice of combustion technology

and the techniques proposed to control the key emissions generated by the project. A summary

of the projects chosen option against the technology alternatives has been presented in Table

8.

Table 8: Technology alternatives

System Technology Alternatives Chosen option

Combustion technology

● Pulverised coal (PC) firing:

– Dry bottom ash furnace

– Wet bottom ash furnace

● Fluidised bed combustion furnace:

– Non-pressurised systems

– Pressurised systems

● The project will utilise CFB boiler technology

● The benefits of using this technology are as follows:

– A high level of combustion efficiency

– Low levels of NOx as a result of the low combustion temperatures.


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System Technology Alternatives Chosen option

● Grate firing

● Techniques to increase coal-fired efficiency:

– Unburnt carbon in ash

– Air excess

– Flue-gas temperature

● Techniques to improve combustion efficiency

– Supercritical

– Combined heat and power

– Low SO2 emissions – through the injection of limestone and low combustion temperatures.

– Ability to combust a range of fuels as this technology is not highly sensitive to fuel specifications and as such, lower grade coals can be combusted.

– Supercritical technology is being used more for CFB technology

Techniques to reduce particulate emissions

● Electrostatic precipitators (ESPs)

● Fabric filters

● Wet scrubbers

● ESPs have been selected which have very high efficiency, even for smaller particles and can handle large gas volumes with low pressure drops

● ESPs also reduce the emissions of aerosols and heavy metals

● ESPs can operate over a wide range of temperature, pressure and dust burden conditions

● Option to add fabric filters retrospectively

● The following specified particulate emission limits will be guaranteed: ≤50mg/Nm³ in compliance with the SEQS

Techniques to reduce sulphur oxides emissions (in particular sulphur dioxide SO2)

Primary measures:

● Use of low sulphur fuel

● Use of adsorbents in fluidised bed combustion systems

Secondary measures:

● Wet flue-gas desulfurization (FGD) - water + limestone as reagent

● Semi-dry FGD - lime as reagent

● Seawater FGD

● Pulverised limestone is fed into the CFB boiler to reduce the SO2 content of flue gases.

● A SOx limit of ≤650mg/Nm3 in compliance with the SEQS will be guaranteed.

● Given the achievable emissions levels from the CFB boiler, FGD is not considered necessary.

Techniques to reduce nitrogen oxide emissions

Primary measures:

● Combustion modifications:

● Low excess air

● Air staging

● Air staging in the furnace (burner out of service, biased burner firing, over-fire air)

● Low NOx burners

● Flue gas recirculation

● In furnace

● Reduced air preheat

● Fuel staging

● In furnace (re-burning)

Secondary measures:

● Selective catalytic reduction (SCR)

● Selective non catalytic reduction (SNCR)

● Staged air injection will be used to convert nitrogen oxides formed back to nitrogen which is a simple technique, compatible with other measures to reduce NOx, low NOx combustion will also be used which can reduce NOx by 25-35% with staged air injection

● The following specified NOx limit of ≤350 mg/Nm3 will be guaranteed.

Cooling system ● Open once-through systems

● Open wet cooling tower

● Open hybrid cooling tower

● Natural draft cooling

● Dry air-cooled condenser

A closed-cycle circulating water system with natural draft cooling towers was chosen for the project which uses approximately one-twentieth of the water used in a once-through system. The water will be sourced from the ground water produced from mine dewatering and if necessary from a Government water pipeline.


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3.4 Summary

The Project will generate 2 x 330MW which will contribute towards bridging the gap between

electricity supply and demand. The chosen location is preferred as it provides access to

infrastructure being developed by the Government, has easy access to coal (mine mouth power

plant) and will be developed within a designated strategic area for coal to power generation).

The CFB boiler technology selected is highly efficient and significantly reduces NOx emissions

as a result of low temperature combustion. Coal/lignite is the most appropriate fuel for the

project because of its abundance in the Thar region.


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4 Policy, legal and institutional framework

4.1 Introduction

There are a number of national and regional requirements that the project will have to comply

with in addition to appropriate international standards. This section provides a brief overview of

the applicable legislation, associated regulations and relevant standards that will be applied to

the Project.

4.2 National institutional and legal framework

4.2.1 Historical and constitutional context

Major national environmental legislation which have direct relevance to the Project are the

Pakistan Environmental Protection Act (1997; PEPA) and the Pakistan Review of Initial

Environmental Examination (IEE) and Environmental Impact Assessment (EIA) Regulations

(2000).

PEPA is the basic legislative tool empowering the Government of Pakistan to frame regulations

for the protection of the environment and the promotion of sustainable development. It applies

to a wide range of issues and extends to air, water, soil, noise pollution and to the handling of

hazardous wastes.

The key features of PEPA that have a direct bearing on the proposed Project relate to the

requirement for an environmental assessment. Section 12 requires that “No proponent of a

development project shall commence construction or operation unless he has filed an IEE or,

where the project is likely to cause an adverse environmental effect, an EIA, and has obtained

from the Federal Agency approval in respect thereof.” The Pakistan EPA has delegated the

power of review and approval of environmental assessments to the provincial EPAs in line with

the 18th Amendment of the Constitution of Pakistan in April 2010. This constitutional amendment

delegated powers to the provincial governments, including on environmental matters and made

the provincial EPAs independent authorities in terms of environmental decision-making. The

Pakistan Review of IEE and EIA Regulations (2000) set out the requirements on the

preparation, submission and review of IEEs and EIAs.

In 1993, the National Environmental Quality Standards (NEQS) were established. Section 11

and Section 15 of PEPA prohibits any emissions or discharges in excess of the NEQS which

determine limit values or maximum allowable concentrations for parameters of wastewater,

ambient air, motor vehicles’ exhaust gases and noise emissions, drinking water quality and

ambient noise. The NEQS are applicable to pollutant discharges irrespective of the type of

source and location.

All provinces have now enacted their own environmental protection laws. These provincial laws

are largely based on Pak-EPA 1997 and provide the same level of environmental protection as

the parent law. The provincial assembly of Sindh passed the Sindh Environmental Protection

Act 2014 (the ‘Sindh Act 2014’) in March 2014.

4.3 Sindh Environmental Protection Act 2014

The Sindh Environmental Protection Act 2014 (SEP Act 2014) is the main legislative tool

empowering SEPA to frame and govern regulations for the protection of the environment. The


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act is applicable to a broad range of issues and extends to air, water, industrial liquid effluent,

marine and noise pollution, as well as to the handling of hazardous wastes.

Under the Sindh Act 2014, SEPA is an autonomous agency. For administrative purposes, it is

part of the Forest, Environment and Wildlife Department of the Government of Sindh. SEPA is a

regulatory agency with the following main functions:

● Enforcement of Sindh Act 2014

● Implement environmental policies

● Ensure implementation of Sindh Environmental Quality Standards (SEQS)

● Establish systems and procedures for environmental management

● Issue licence for handling of hazardous substance

● Specify safeguards for the prevention of accidents which may cause pollution

● Review and approve mitigation plans and give guidance for clean-up operations

● Carry out any other task related to the environment assigned by the government.

4.4 Sindh Environmental Quality Standards

Section 6 of the SEP Act 2014 prohibits any emissions or discharges in excess of the SEQS,

which determine limit values or maximum allowable concentrations for parameters including

wastewater, ambient air, motor vehicles’ exhaust gases and noise emissions, drinking water

quality and ambient noise. The SEQS are applicable to pollutant discharges irrespective of the

type of source and location.

4.5 Requirements for environmental impact assessment in Sindh Province

SEPA will be responsible for the review and approval of the EIA of the Project. The articles of Sindh Act 2014 that have a direct bearing on the environmental assessment of the proposed project are:

● Article 17(1): ‘No proponent of a project shall commence construction or operation unless he

has filed with the Agency an initial environmental examination or an environmental impact

assessment, and has obtained from the Agency approval in respect thereof.’

● Article 17(3): ‘Every review of an environmental impact assessment shall be carried out with

public participation.

4.5.1 Objectives of ESIA

The following are objectives of the ESIA study based on the Pakistan’s national and provincial

environmental laws:

● Undertake consultation with the stakeholders to scope out the study and again to provide

them with the feedback on the outcome of the study

● Prepare a physical, ecological and social baseline of the area of influence (the ‘Study Area’)

in order to evaluate the potential environmental impacts of the proposed activities, and

serve as reference for future

● Assess the potential environmental impact of the proposed activities and, where necessary,

suggest mitigation measures to reduce any potential adverse impact to acceptable levels

● Prepare an environmental management plan to ensure that the proposed mitigation

measures and corrective action measures are implemented

● Prepare an ESIA report complying with the legal requirements and the international

guideline for submission to the SEPA.


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4.5.2 EIA approval procedure

The national EIA approval procedure is shown in Figure 8.

Figure 8: EIA approval procedure

Source: EIA Guidance for Coal Fired Power Plants in Pakistan 2014

4.5.3 Other relevant legislation

In addition to the environmental and social legislation presented in the previous sections, there

is a range of further sectorial legislation that is relevant to the Project. This is summarised in

Table 9.


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Table 9: Other legislation relevant to the Project

Legislation (Year of issuance) Brief description

Thar Coal and Energy Board Act, 2011

Thar Coal and Energy Board Act, 2011 was passed by the Provincial Assembly of Sindh on 8 June, 2011 and assented to by the Government of Sindh on 28 June, 2011 and is published as an act in the Legislature of Sindh. Under this act a board is required to be set up, and the membership of the board is made up of representatives from multiple government agencies with an interest in the Thar region or in the development of coal mining and power production. The Thar Coal and Energy Board (TCEB) will have a central role with its mandate for inter-agency support for Thar coal development especially related to policy formulation, programme/project monitoring and project facilitation at every stage of Thar coal projects.

Pakistan Penal Code 1860 The Pakistan Penal Code deals with offences where public or private property and/or human lives are affected, due to intentional or accidental misconduct of an individual or body of people. In context of the environment, the penal code empowers local authorities to control noise, noxious emissions and disposal of effluents.

Factories Act 1934 The Factories Act provides regulations for handling and disposal of toxic and hazardous materials. As construction activity is classified as ‘industry’, these regulations will be applicable.

Sindh Wildlife Ordinance 1972 and Amendments 2001

Sindh Wildlife Ordinance 1972 and Amendments 2001 details the rules, regulations and permits for hunting, trapping, capturing of game animals; conservation of national parks, game reserves; and the laws and guidelines of working in protected area and sanctuaries.

The Antiquities Act, 1975 and Sindh Cultural Heritage Act 1994

These acts deal with protection, preservation and conservation of archaeological/historical sites and monuments. It binds project proponents to notify the department if anything of archaeological value is discovered during project construction.

The National Mineral Policy (NMP), 1995

This policy aims at promoting and developing the mining sector in Pakistan mainly through private investment. It includes environmental safeguards and compensation for injury.

Sindh Coal Act 2012 The Sindh Coal Act 2012 has been designed to provide for regulation and development of coal in the Province of Sindh.

Sections 6 and 7 of the Act stipulate that an environmental impact assessment, social assessment and environmental management plan are required for all projects engaged in exploration and exploitation of coal. Coal-based power generation or any other use of coal shall comply with the resettlement policy of the Government of Sindh.

National Resettlement Policy 2002 and Interim Resettlement Framework Guidelines 2011

The National Resettlement Policy 2002 was developed to ensure equitable and uniform treatment of resettlement issues across Pakistan and applies to all development projects involving adverse social impacts, land acquisition, loss of assets, income and businesses. The Interim Resettlement Framework Guidelines 2010 set out the institutional, legal, and implementation framework to guide the resettlement and rehabilitation of project affected people (PAP) who will be adversely affected by the development of a project.

4.6 International treaties and conventions

Pakistan is a signatory to a number of international E&S related treaties, conventions,

declarations and protocols. The following are the relevant international treaties and conventions

to which Pakistan is a party (Pakistan’s ratification, signatory or accession date is indicated

behind each convention or treaty):

● Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention) –

1987

● Convention on Wetlands of International Importance (Ramsar Convention) – 1976

● Convention on International Trade of Endangered Species of Wild Fauna and Flora (CITES)

– 1976


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● United Nations Convention on Biological Diversity – 1994

● Stockholm Convention on Persistent Organic Pollutants – 2001

● Rotterdam Convention on the Prior Informed Consent Procedures for Certain Hazardous

Chemicals and Pesticides in International Trade – 2005

● Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and

their Disposal – 1994

● International Covenant on Economic, Social and Cultural Rights – 2004

● International Labour Organisation’s (ILO) Core Labour Standards on:

– Freedom of association and collective bargaining (conventions 87 and 98) – 1951 and

1952

– Elimination of forced and compulsory labour (conventions 29 and 105) – 1957 and 1960

– Elimination of discrimination in respect of employment and occupation (conventions 100

and 111) 2001 and 1961

– Abolition of child labour (conventions 138 and 182) – 2006 and 2001

Other ILO Conventions that Pakistan has ratified or signed

● United Nations Convention on the Rights of the Child – 2001

● United Nations Framework Convention on Climate Change – 1994

● Kyoto Protocol to the Convention United Nations Framework on Climate Change – 2005

4.7 National and international non-governmental organisations

National and international environmental non-governmental organisations (NGOs) have been

particularly active in advocacy, promoting sustainable development approaches. Much of the

government’s environmental and conservation policy has been formulated in consultation with

leading NGOs, who have also been involved in drafting new legislation on conservation such as

the International Union for Conservation of Nature (IUCN) in Pakistan, which has developed a

Red List at the Tharparkar regional level and at the national level.

4.8 International standards and guidelines

Substantial information/data exists from previous assessments and studies undertaken in the

area. As such, the air quality and waste and materials management chapters were able to be

prepared in accordance with the International Finance Corporation (IFC) Performance

Standards on Environmental and Social Sustainability 2012 (IFC PS).


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5 ESIA process and methodology

5.1 Introduction

The ESIA has identified negative and positive, direct and indirect and cumulative impacts of the

Project related to the bio-physical and the socio-economic environment.

The definition of the Project includes all infrastructure and facilities that are directly part of the

proposed development. Given the limited detail available regarding the associated facilities at

the time of this ESIA, a high level qualitative assessment of this infrastructure has been

completed, noting that further assessment will be undertaken prior to their development.

5.2 Impact assessment methodology

5.2.1 Overview

Following the review of the studies undertaken to date and the findings of the site visit, specialist

assessments were carried out in order to predict potential impacts associated with the Project

and propose measures to mitigate the impacts as appropriate. Each assessment chapter

follows a systematic approach, with the principal steps being:

● Description of assessment methodology used

● Identification of the spatial and temporal scope of potential impacts (area of influence)

● Description of baseline conditions

● Impact assessment

● Identification of appropriate mitigation measures as required

● Assessment of residual impacts

5.2.2 Area of influence and temporal scope

The area of influence (AoI) indicates where proposed works, including related facilities and

infrastructure, will have a direct or indirect impact on the physical and social environment. This

can result from aspects such as physical land-take or as a result of the extent of the potential

impact that extend beyond the developments physical boundary such as noise emissions or

emissions to air. The AoI can also vary according to the stage of the Project being assessed

such that construction impacts may have a different area of impact than for operation.

For each impact assessment chapter, the spatial and temporal zones of influence are defined. It

is important to note that the area of influence has primarily been based on the impacts

associated with the Project itself. However, as far as reasonably practical and for the purposes

of this ESIA consideration of the potential locations of the associated facilities has been taken

into account in the defined spatial scope for each environmental and social aspect.

It should be noted that this approach has been adopted given that the detailed design and

routing arrangements have not yet been finalised for the associated facilities. Further

assessment will be undertaken for each of these components by the relevant developer/lending.

agency once the design of these components has been confirmed.

5.2.3 Baseline data

The primary sources of information for baseline assessment have been the existing information

(secondary information) as well as some site surveys undertaken in 2016.


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5.2.4 Assessment of impacts

5.2.4.1 Overview

The assessment of the significance of impacts and identification of residual impacts has taken

account of any inherent mitigation measures incorporated into the project by the nature of its

design. The significance of the resultant impact is largely dependent on the extent and duration

of change, the number of people or size of the resource affected and their sensitivity to the

change. The criteria for determining significance are specific for each environmental and social

aspect but generally for each impact the magnitude is defined (quantitatively where possible)

and the sensitivity of the receptor is identified. Generic criteria for the definition of magnitude

and sensitivity are summarised below.

5.2.4.2 Magnitude

The assessment of impact magnitude is undertaken in two steps. First, the key impacts

associated with the Project have been categorised as beneficial or adverse. Second, the

magnitude of potential impacts have been categorised as major, moderate, minor or negligible

based on consideration of the parameters such as:

● Duration of the impact – ranging from temporary with no detectable impact to beyond

decommissioning

● Spatial extent of the impact – for instance, within the site boundary to regionally, nationally,

and internationally

● Reversibility – ranging from no change to permanent requiring significant intervention to

return to baseline

● Likelihood – ranging from unlikely to occur to occurring regularly under typical conditions

● Compliance with legal standards and established professional criteria - ranging from meets

standards or international guidance to substantially exceeds national standards and

limits/international guidance.

Table 10 outlines the generic criteria for determining magnitude.

Table 10: Generic criteria for determining magnitude

Magnitude (beneficial or adverse) Description

Major Fundamental change to the specific conditions assessed resulting in long term or permanent change, typically widespread in nature, and requiring significant intervention to return to baseline; exceeds national standards and limits.

Moderate Detectable change to the specific conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Detectable but minor change to the specific condition assessed.

Negligible No perceptible change to the specific condition assessed.


5.2.4.3 Sensitivity

Sensitivity is generally site specific and criteria have been developed from baseline information

gathered and secondary information sources. The sensitivity of a receptor will be determined

based on review of the population (including proximity/ numbers/vulnerability) and presence of

features on the site or the surrounding area. Generic criteria for determining sensitivity of

receptors are outlined in Table 11. Each detailed assessment defines sensitivity in relation to

their topic if required.


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Table 11: Criteria for determining sensitivity

Sensitivity Definition

High Vulnerable receptor (human or ecological) with little or no capacity to absorb proposed changes or minimal opportunities for mitigation.

Medium Vulnerable receptor (human or ecological) with limited capacity to absorb proposed changes or limited opportunities for mitigation.

Low Vulnerable receptor (human or ecological) with some capacity to absorb proposed changes or moderate opportunities for mitigation

Negligible Vulnerable receptor (human or ecological) with good capacity to absorb proposed changes or and good opportunities for mitigation


5.2.4.4 Impact evaluation and determination of significance

The significance of an impact can be described by the interaction of magnitude and sensitivity

as depicted in the significance matrix shown in Table 12.

Table 12: Significance matrix

Se

nsiti

vity

Magnitude

Adverse Beneficial

Major Moderate Minor Negligible Minor Moderate Major

High Major Major Moderate Negligible Moderate Major Major

Medium Major Moderate Minor Negligible Minor Moderate Major

Low Moderate Minor Negligible Negligible Negligible Minor Moderate

Negligible Minor Negligible Negligible Negligible Negligible Negligible Minor


The objective of the ESIA is to identify the likely significant impacts of the Project on the

environment and people. Impacts that have been evaluated as being ‘moderate’ or ‘major’ are

significant effects and identified as such in the specialist chapters. Consequently, impacts that

are ‘minor’ or ‘negligible’ are not significant. The significance of impacts is given without

mitigation being applied and following the implementation of mitigation (residual impacts).

5.2.4.5 Mitigation and enhancement measures

Where feasible the following hierarchy of mitigation measures will be applied to reduce, where

possible, the significance of impacts to acceptable levels:

● Mitigation/elimination through design

● Site/technology choice

● Application of best practice

5.2.4.6 Uncertainty

Any uncertainties associated with impact prediction or the sensitivity of receptors due to the

absence of data or other limitation will be explicitly stated. Where applicable, the ESIA will make

commitments concerning measures that should be put in place with monitoring and /or

environmental or social management plans to deal with the uncertainty. This is summarised in

the Project ESMP that forms Volume IV of this ESIA.


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5.3 Cumulative impacts and transboundary impacts

Cumulative impacts are those impacts that may result from the combination of past, present or

future actions of existing or planned activities in a project’s area of influence. While a single

activity may not itself result in a significant impact, it may, when combined with other impacts in

the same geographical area and occurring at the same time, result in a cumulative impact that is

significant.

A strategic environmental and social assessment (SESA) was previously completed on behalf of

the Coal and Energy Development Department, Government of Sindh for the whole Thar

Coalfield development to identify potential environmental and social impacts arising from the

development of this area.

A cumulative impact assessment (CIA) which focuses on the development of the Project and

the lignite mining activities within Block VI is presented in chapter 16 to provide an

understanding of the likely combined environmental and social impacts.

The Convention of Transboundary Effects of Industrial Accidents (1992) states that

“transboundary effects mean serious effects within the jurisdiction of a Party as a result of an

industrial accident occurring within the jurisdiction of another Party”. The Project will not have

any impacts to other countries; its effects are on a local/regional scale. Transboundary impacts

have therefore not been considered as part of this ESIA.


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6 Information disclosure, consultation and

participation

6.1 Overview

This chapter outlines the information disclosure and consultation activities that have taken place

prior to and during the development of the ESIA. The key objectives of this chapter are to:

present a summary of all Project consultations that took place between 2011-2012 and served

to inform stakeholders about the Project; outline the outcomes of the ESIA consultation activities

undertaken in June 2016; detail the planned activities for the public disclosure of and

consultation on the ESIA as required by Pakistani and Sindh regulations and to provide an

outline of stakeholder engagement activities for the construction and operational phases of the

Project.

The chapter consists of the following sub-sections:

● Consultation requirements

● Stakeholder identification and analysis

● ESIA consultation activities and outcomes to date (August 2016)

● Disclosure and consultation on the draft ESIA

● Stakeholder engagement planned throughout the lifetime of the Project

● Project grievance redress mechanism

● Community liaison officer (CLO) contact details

6.2 Consultation requirements

6.2.1 Overview

This sub-section provides an overview of the national and regional requirements contained

within the Pakistani and the Sindh Province Initial Environmental Examination (IEE) and

Environmental Impact Assessment (EIA) Regulations, 2000 and 2014 respectively.

6.2.2 National and regional requirements

The Pakistan Review of IEE and EIA Regulations (2000) and the SEPA (Review of IEE and

EIA) Regulations (2014) states that in the case of an EIA being conducted for a project, the

following consultation requirements are to be met by the Federal Agency in charge:

● A public notice is to be issued in English and Urdu in a local newspaper within the project

area. The notice should contain: a) the name of the project, b) its exact location, c) the name

and address of the proponent and d) the places where the EIA can be accessed.

● The public notice issued should contain the date, time and place of the public consultation to

be held with stakeholders, where they are able to provide comments on the project and its

EIA.


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● Public consultation should not be earlier than 30 days after the date of publication of the

public notice.

● The EIA must be circulated to all relevant government agencies.

● All comments received by the Federal Agency from the public and/or any Government

Agency shall be collated, tabulated and duly considered before finalising the EIA.

The Guidelines for the Preparation and Review of Environmental Reports (1997) state that in

order for the environmental and social assessment to be credible, fair and transparent, full

public involvement should be a part of the process. This should include:

● Making all environmental reports available to the public

● Publishing lists of decisions – including the requirement for an EIA and the final outcome of

environmental approval

● Public availability of any recommendations for mitigation and impact management plans

According to the Guidelines for the Preparation and Review of Environmental Reports (1997),

good ways to disseminate the information contained within the EIA include local language

video, radio and television, presentations, newsletters and information sheets, displays

(supported by members of the study team), gatherings such as local community groups, small

meetings and workshops.

The Guidelines for Public Consultation (1997) deal with approaches to public consultation and

techniques for designing an effective program of consultation that reaches out to all major

stakeholders and ensures the incorporation of their concerns in the impact assessment. These

guidelines will be applied when undertaking the consultation for this Project.

6.3 Stakeholder identification and analysis

Stakeholders are persons or groups who are directly or indirectly affected by a project, as well

as those who may have interests in a project and/or the ability to influence its outcome, either

positively or negatively. Stakeholders for the Project include locally affected communities and

their formal and informal representatives, national or provincial government authorities, civil

society organisations and groups with special interests, the academic community and

businesses.

A stakeholder mapping and analysis exercise as well as identification of the most appropriate

communication methods was undertaken at the outset of the ESIA process and will be updated

as necessary throughout the Project. The affected communities and interested non-

governmental stakeholders are identified in Table 13.

The Developer recognises that marginalised and disadvantaged groups are likely to experience

impacts differently from mainstream society. For instance, they may be less able to cope with

change such as influx of workers into the area than a typical community household or may be

less able to take advantage of benefits such as employment generation.

Vulnerable groups include seasonal workers, ethnic minorities and people living below the

poverty line. Consultation and information disclosure activities will enable the involvement of

vulnerable groups by applying the appropriate logistical and cultural factors such as language,

physical access, literacy levels, and time availability of these groups.


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Table 13: Identification of community and non-governmental stakeholders and

communication methods

Stakeholders Community population Communication methods Proposed formats

Closest communities to the Project activities

Residents of the five villages in Block VI: Ranjho Noon, Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Salar ji5.

2,250 people; 636 households6.

● Consultations and interviews with directly affected communities

● Disclosure of non-technical project information.

● Invitation to public consultation meeting

● Public consultation

● Focus groups

● SESA scoping meetings

● Brochures and leaflets distributed in locations frequented by people

● Project website

● Local newspapers

● Radio

Vulnerable groups include seasonal workers, ethnic minorities, female headed households and people living below the poverty line.

No data ● Consultations, interviews and informal meetings. Disclosure of non-technical Project information.

● Consultations with village elders or community representatives

● Invitation to public consultation meetings


● Focus groups



● Project website


● Radio

Other nearby communities

Villages outside of Block VI: Jodho Bheel, Baka Karan, Mithe-ji-Wandh, Anchle-ji-Dhani, Meghay Jo Tar, Monhtar, Meenho Lanjo, Magho Bheel, Banbhinyo Bheel, Kanhe-ji-Dhani, Sonal Beh, Jan Mohammand Noon, Poonje-ji-Wandh, Parbho-ji-Dhani, Mansingh Bheel, Seengaro, Aban-jo-Tar, Noray Ji Wandh, Bitra, Jaman Samo, Kachhibo Je Dhani and Saleh Janjhi

24,189 people; 4,719 households6

● Consultations, interviews with key informants

● Disclosure of non-technical Project information

● Invitation to public consultation meeting


● Focus groups



● Project website


● Radio

Project employees and job seekers

Employees, prospective employees (direct/indirect) and representatives of workers’ unions

The total workforce foreseen at construction will be 1,000 people over a three year construction period. Permanent employment for the operations phase of the power station will be between 200 to 300 people.

● Provision of non-technical information about the Project

● Disclosure of job advertisements

● Meetings with staff and trade union representatives regarding key Project changes that affect staff, for example end of construction phase

● Workers’ grievance mechanism

● Newspaper adverts for jobs

● Notices at site and office/noticeboards regarding recruitment

● Project website

5 Initially there were six villages in Block VI; however the village of Kharo Jani is in the process of being resettled as part of the Block VI Lignite Mining Project. As of September 2016, the land ownership survey is

underway and potential resettlement sites within the Block are being identified. 6 Mott MacDonald Pakistan Focus Groups June 2016


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Stakeholders Community population Communication methods Proposed formats

Non-government organisations (NGOs)

Baanhn Beli, Thardeep Rural Development Programme, Marooara

Coordination Council, Tharparkar Social Organization, World Wide

Fund for Nature, Society for Conservation & Protection of

Environment (SCOPE), Thar Aid Program, Association for Water

Applied Education & Renewable Energy (AWARE), Telenor,

Pakistan Village Development Program (PVDP), Thardeep Rural

Development Programme (TRDP), SAMI Foundation, Registhan

Social Welfare Association, Social Welfare Department, Tharparkar,

Thar Aid Program, Actions, Re-construction and Humanitarian

Response (SEARCH), Thar Welfare Council, National Commission

for Human Development (NCHD) and Sindhi Adabi Sungat

● Consultations, interviews

or informal meetings

(commensurate with the

NGO’s level of interest/ or

influence in the Project)

● Disclosure of reports

● Invitation to public

consultation meetings

● One-to-one meetings

and workshops / focus

group discussions

● Letters / personal

invitations

● Brochures and leaflets

Annual Reports

● Project website


● Regional radio

stations

Others

Media:

Geo TV Channel, ARY TV Network, KTN TV Channel, Sindh TV

Channel, Mehran TV, Dawn News TV Channel, Express News

Channel. Daily Dawn Newspaper , Daily Jang Newspaper, The

Nation Newspaper, Pakistan Observer Newspaper, the express

Tribune newspaper, Daily Business Recorder newspaper, Daily Ibrat

Newspaper Hyderabad, Daily Awami Awaz newspaper, Daily Kawish

newspaper, Daily Hilal e’ Pakistan newspaper and Radio Pakistan

● Project staff member

responsible for media

communications identified

● Disclosure of Project

information

● Press articles

● Project website

● Brochure and leaflets

Academia:

Department Of Economics - University Of Karachi, Aga Khan

University Karachi, NED University of Engineering and Technology ,

Mehran University of Engineering and Technology; Engineering

Development Board, Sindh Board Of Technical Education (SBTE)

and Sindh Technical Education and Vocational Training Authority

(TEAVTA)

● Project staff member

responsible for academia

identified

● Disclosure of Project

information

● Press articles

● Project website

● Brochure and leaflets

Table 14 overleaf identifies the government stakeholders and decisions makers at the national,

provincial and local levels.


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Table 14: Government stakeholders and decisions makers

Stakeholders Relevance to the

Project (interest /

influence)

Communication

methods

Proposed formats

National government

Coal Energy Development Department (CEDD) Proponent of Project ● Private meetings

● Invitation to

participate in

public

consultations

● Disclosure of

reports

● On-going

consultations and

working relationships

with the authority


consultations and

meetings

● Project website

National Commission for Human Development

Public Health Engineering Department

State Bank of Pakistan, Pakistan National Shipping

Corporation (PNSC)

Ministry of Commerce, Accountant General Pakistan,

Trading Corporation of Pakistan

Population Census Organisation, Trade Development

Authority of Pakistan

Interested parties

Province Level Government and Authorities

Sindh Environmental Protection Agency (SEPA) Approval of environmental procedures

Private meetings

Invitation to participate in public consultations

Disclosure of reports

On-going consultations and working relationships with the authority

Invitation to public consultations and meetings

Project website

Planning and Development Department

Health Department Environmental Protection Agency

Forest and Wildlife Department Archaeology Department

Agriculture Department

Education and Literacy Department

Information and Archives Department

Home Department Environmental and Alternate Energy Department,

Finance Department Departments responsible for Food and

Agriculture, Human Rights, Housing and Works, Transport, Communications,

Culture, Minorities, Science and Technology, Water and Power, Interior, Labour and

Manpower, Social Welfare and Special Education

Mines and Minerals Department

Interested parties

Sindh Police

Sindh Coal Authority

Thar Coal and Energy Board

Interested parties

Maroora Welfare Association

Community Development Department of Information Technology (CDDIT)

Interested parties

District Level Government and Authorities

District Coordination Officer, Mithi

Executive District Officer, Health

Executive District Officer, Education

District Officer, Social welfare

District Officer, Revenue

Executive District Officer, Agriculture

Interested parties ● Private meetings

● Invitation to

participate in

public

consultations

● Disclosure of

reports

● On-going

consultations and


with the authority


consultations and

meetings

● Project website


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Stakeholders Relevance to the

Project (interest /

influence)

Communication

methods

Proposed formats

Executive District Officer, Community Development

Department

Executive District Officer, Finance and Planning

Municipal Government

Tehsil Municipal Authority, Diplo

Tehsil Municipal Officer, Diplo

Tehsil Municipal Officer, Chachro

Interested parties ● Private meetings

● Invitation to

participate in

public

consultations

● Disclosure of

reports

● On-going

consultations and


with the authority


consultations and

meetings

● Project website

A SEP7 for the Project will be produced. This plan will be considered live, as well as Table 13

and Table 14.

6.4 Introducing stakeholders to the Project and the developments in Block VI

This sub-section presents the previous consultations undertaken in order to introduce

stakeholders to the Project and outline the developments to be undertaken in Block VI. The

stakeholder engagement activities that were undertaken from August 2011 to May 2012 are

briefly outlined in Table 15 and then summarised in more detail in Volume III. The main issues

discussed during these consultations were:

● People’s views on the developments of Block VI (open pit mine and power plant)

● Resettlement and land acquisition processes and people’s concerns

● Information disclosure to affected stakeholders and their current knowledge of the

developments

● Local people’s concerns regarding the availability of local employment opportunities

Table 15 outlines the stakeholder engagement activities undertaken from August 2011 to May

2012.

Table 15: Consultation for the introduction of stakeholders to the Project and Block VI

developments

Date Description Stakeholders Participants

Female Male Total

25 August –

17 October

2011

Interviews and focus

group discussions with

Project stakeholders

70 stakeholders from the list identified in

section 6.3 in Karachi and Tharparkar. In

Tharparkar the meetings were held in

No data No data 70

7 Expected completion date unknown.


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three Talukas (towns), namely Islamkot,

Mithi and Diplo.

October 2011

– January

2012

Consultations conducted

as part of the development

of the Interim

Resettlement Action Plan

Consultations conducted with specifically

selected local stakeholders from the

affected communities, local government,

and the Thar Coal Project team

No data No data No data

1 – 4 May

2012

Presentation of the draft

Strategic Environmental

and Social Assessment

Scoping Report for the

Thar Coal Power Plant

Project

Four focus groups conducted in Diplo,

Nagarparkar, Chachro and Islamkot

No data No data Diplo: 15

Nagarparkar: 28

Chachro: 17

Islamkot: 29

6.4.1 ESIA consultation activities and outcomes to date (August 2016)

More recent ESIA consultations were held with the five affected villages in Block VI in June

2016. The date, location and number of participants that were present at the focus group

discussions are summarised in Table 16.

Table 16: ESIA consultations


Female Male Total

15 June 2016 Data gathering

for ESIA

baseline and

disclosure of

information

Male and female focus group

from Ranjho Noon

18 28 46

16 June 2016 Male and female focus group

from Salar-Ji-Dhani

15 5 20


from Gangoo-Ji-Dhani

7 9 16


from Yaqoob Ji Dhani

3 5 8


from Yousuf-Ji-Dhani

16 9 25


The main focus of the meetings was to gather data from affected stakeholders that in turn has

been used to inform the baseline, impact assessment and the mitigation / enhancement

measures in relevant ESIA chapters. In addition, it was to verify what information regarding the

Project had been disclosed to communities. A standard questionnaire was used and the

information gathered is summarised collectively in Table 17.

Table 17: ESIA consultations conducted between 15 and 17 June 2016 with five affected

communities in Block VI

No. Question from Mott

MacDonald Pakistan

Stakeholder response Chapter within this ESIA where this issue and

relevant mitigation are reflected

1 Are any of the people in the Project affected area considered indigenous?

None of the people are considered indigenous

Chapter 16 ‘Social Impact Assessment’ addresses indigenous people and ethnic minorities in the affected areas.


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No. Question from Mott

MacDonald Pakistan

Stakeholder response Chapter within this ESIA where this issue and

relevant mitigation are reflected

2 Do any community members have experience in construction work?

15 people have experience in masonry in Ranjho Noon. No other experience in the rest of the communities.

Chapter 16 ‘Social Impact Assessment’ reflects the construction experience that people in the affected areas have. There are enhancement measures in the ESIA to enable local people to benefit from the 1,000 construction jobs that will be created as part of the Project.

3 What are some of the challenges that have negatively affected the majority of the village?

Illness

Drought / Water scarcity

Poverty

Lack of resources

Unemployment

Chapter 16 ‘Social Impact Assessment’ has reflected the major challenges that have affected the people in the Project area.

4 Have there been any previous consultations?

Yes community members have previously been consulted by members of the M/S Oracle team (Sponsor).

This chapter reflects all the consultations conducted for the Thar Coal Power Plant Project to date (August 2016).

5 What are the general views of the community regarding the Project?

The people expect positive outcomes from this development for the local community as well as for whole nation.

This chapter reflects people’s opinions regarding the Project.

6 What are people’s views on land acquisition and resettlement? Are people willing to relocate? Where do people expect to be relocated to?

People are unaware of these issues and have not been informed. People will discuss amongst themselves and make a decision if such a situation arises.

Chapter 16 ‘social impact assessment’’ the resettlement in the Project area.

7 Have you been explained how the areas of cultural or historical significance will be protected and is that sufficient?

The communities state that no such cultural heritage sites exist.

Chapter 16 ‘social impact assessment’ addresses impacts on cultural heritage found in the Project area.

6.5 Disclosure and consultation on the draft ESIA

The requirements for the Pakistan Review IEE and EIA Regulations (2000) and the Sindh

Environmental Protection Agency (Review of IEE and EIA Regulations) (2014) for this draft

ESIA are listed in section 6.2.

6.6 Stakeholder engagement planned throughout the lifetime of the Project

The SEP will outline ongoing stakeholder engagement and implementation of the grievance

mechanism throughout the construction and operation phases. Activities will include

communications as necessary with settlement representatives, community consultation events

at key Project milestones such as the beginning and end of construction, regular updating of the

Project website and social media, updating the SEP and annual sustainability reporting.


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Table 18: Stakeholder engagement throughout the construction and operation phases

Stakeholders Activity

Residents of the five villages in Block VI: Ranjho Noon,

Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Salar ji. ● Community visits by the CLO, including meetings with

stakeholders to address grievances and concerns

● Information disclosure when the Project phases change at the

Information and Education Communication Centre (IECC)

● Distribution of the Non-technical summary


● Publishing lists of decisions – including the requirement for an

ESIA and the final outcome of environmental approval

● Public availability of any recommendations for mitigation and

impact management plans

● Workshop to explain Project plans and timescales in non-

technical language and delivered in Sindhi and Thari, timed to

enable participation by local people and vulnerable groups

● Grievance mechanism

Vulnerable groups include seasonal workers, ethnic minorities

and people living below the poverty line.

Villages outside of Block VI: Jodho Bheel, Baka Karan, Mithe-

ji-Wandh, Anchle-ji-Dhani, Meghay Jo Tar, Monhtar, Meenho

Lanjo, Magho Bheel, Banbhinyo Bheel, Kanhe-ji-Dhani, Sonal

Beh, Jan Mohammand Noon, Poonje-ji-Wandh, Parbho-ji-

Dhani, Mansingh Bheel, Seengaro, Aban-jo-Tar, Noray Ji

Wandh, Bitra, Jaman Samo, Kachhibo Je Dhani and Saleh

Janjhi


IECC








IECC







Federal Government Agencies

Sindh Province Government Agencies

Local District offices

NGOs

Media

6.7 Project grievance redress mechanism

6.7.1 Overview

A grievance can be defined as an actual or perceived problem that might give grounds for

complaint. As a general policy, the Project will work proactively towards preventing grievances

through the implementation of impact mitigation measures and community liaison. Anyone can

submit a grievance to the Project if they believe a practice is having a detrimental impact on the

community, the environment, or on their quality of life. They may also submit comments and

suggestions. The sections below consider confidentiality and anonymity and the Project’s

grievance resolution process.


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6.7.2 Confidentiality and anonymity

The Project will aim to protect a person’s confidentiality when requested and will guarantee

anonymity in annual reporting. Individuals will be asked permission to disclose their identity.

Investigations will be undertaken in a manner that is respectful of the aggrieved party and the

principle of confidentiality. The aggrieved party will need to recognise that there may be

situations when disclosure of identity is required and the Project will identify these situations to

see whether the aggrieved party wishes to continue with the investigation and resolution

activities.

6.7.3 Grievance Reporting and Resolution

Grievances will be logged in a formal logging system for which the CLO will be responsible.

People may register grievances by contacting the CLO or reporting to their village leader, or

other community representative. Contact details for the CLO will be included in appropriate

Project communication materials such as the non-technical summary (NTS).

The CLO will classify grievances according to Table 19. Where investigations are required,

Project staff and outside authorities as appropriate, will assist with the process. The CLO will

collaborate with the project management team to identify an appropriate investigation team with

the correct skills to review the issue raised. The investigation will also aim to identify whether

the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and

implementing activities, procedures, equipment and training to address and prevent

reoccurrence will be part of the investigation activities.

Table 19: Grievance classification criteria and response process and timeframes

Classification Risk Level (to health, safety or

environment)

Response process and timeframes

Low No or low CLO will conduct investigation, document findings and provide a response.

Medium Possible risk and likely a one-off event

CLO and an appropriate investigation team will conduct investigation. The Site Manager or Occupational Health and Safety Manager may decide to stop work during the investigation to allow the corrective preventive actions to be determined. The CLO will provide a response.

High Probable risk and could reoccur CLO will get the contractor to organise an investigation team for prompt investigation and resolution. Work may be stopped in the affected area. The CLO will provide a response.


Where investigations are required, Project staff and outside authorities will assist with the

process. The CLO will collaborate with the CEDD to identify an appropriate investigation team

with the correct skills to review the issue raised and to decide whether it is Project related or

whether it is more appropriately addressed by a relevant authority outside the Project. The

investigation will also aim to identify whether the incident leading to the grievance is a singular

occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment

and training to address and prevent reoccurrence will be part of the investigation activities. In

some cases, it will be appropriate for the CLO to follow up at a later date to see if the person or

organisation is satisfied with the resolution or remedial actions. Each grievance will be given an

identification number and followed through by recording details and timing for their resolution

and closing out.


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The CLO will summarise grievances to report on Project performance weekly during

construction and bi-annually during operation removing identification information to protect the

confidentiality of the complainant and guaranteeing anonymity. The contact details of the CLO

are to be advised by CEDD once the appointment has been made. This should be done

immediately so that the grievance mechanism can be opened to members of the public as soon

as possible. The procedure for processing grievances is depicted in Figure 9.

Figure 9: Flowchart for processing grievances


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6.8 CLO contact details

All general comments, queries and grievances can be submitted to the CLO, whose contact

details are listed below in Table 20.

Table 20: CLO contact details

Community Liaison Officer

Name Noushaba Kamran Soomro

Company Sindh Carbon Energy Postal Address: Suite No.203, Cotton Exchange Building, I.I Chundriger Road Karachi

Telephone +3333917412

E-mail address [email protected]

Project Website www.sindhcarbonenergy.com


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7 Air quality

7.1 Introduction

7.1.1 Overview

This chapter provides an assessment of the potential impacts on air quality caused by the

construction, decommissioning and operation of the Project. This assessment has been carried

out in accordance with national and international guidelines.

7.1.2 Key pollutants

The combustion of fossil fuel gives rise to a number of pollutants with the potential to negatively

affect local air quality. With respect to lignite coal (the proposed fuel for this Project), the primary

pollutants of concern are:

● Oxides of nitrogen (NOx)

● Sulphur dioxide (SO2)

● Particulate matter (PM)

● Carbon monoxide (CO)

● Hydrogen fluoride (HF)

● Hydrogen chloride (HCl)

● Heavy metals

7.1.2.1 Oxides of nitrogen

Oxides of nitrogen is a term used to describe a mixture of nitric oxide (NO) and nitrogen dioxide

(NO2), referred to collectively as NOx. These are primarily formed from atmospheric and fuel

nitrogen as a result of high temperature combustion.

During the process of combustion, atmospheric and fuel nitrogen is partially oxidised via a

series of complex reactions to NO. The process is dependent on the temperature, pressure,

oxygen concentration and residence time of the combustion gases in the combustion zone.

Most NOx exhausting from a combustion process is in the form of NO, which is a colourless and

tasteless gas. It is readily oxidised to NO2, a more harmful form of NOx, by chemical reaction

with ozone and other chemicals in the atmosphere. NO2 is a yellowish-orange to reddish-brown

gas with a pungent, irritating odour and is a strong oxidant.

7.1.2.2 Sulphur dioxide

SO2 is a colourless, non-flammable gas with an odour that irritates the eyes and air passages. It

reacts on the surface of a variety of airborne solid particles, is soluble in water and can be

oxidised within airborne water droplets. The most common sources of SO2 include fossil fuel

combustion, smelting, manufacture of sulphuric acid, conversion of wood pulp to paper,

incineration of waste and production of elemental sulphur. Coal burning is the single largest

man-made source of SO2, accounting for about 50% of annual global emissions, with oil burning

accounting for a further 25-30%.


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7.1.2.3 Particulates

PM is a complex mixture of organic and inorganic substances present in the atmosphere.

Sources are numerous and include power stations, other industrial processes, road transport,

domestic coal burning and trans-boundary pollution. Secondary particulates, in the form of

aerosols, attrition of natural materials and, in coastal areas, the constituents of sea spray, are

significant contributors to the overall atmospheric loading of particulates. In urban areas, road

traffic is generally the greatest source of fine particulate matter, although localised effects are

also associated with construction and demolition activity.

7.1.2.4 Carbon monoxide

Carbon monoxide (CO) is a colourless, odourless gas produced by the incomplete combustion

of carbon-based fuels and by biological and industrial processes. The major source of carbon

monoxide is traffic, particularly in urban areas. CO is produced under conditions of inefficient

combustion, is rapidly dispersed away from the source and is relatively inert over the timescales

relevant for its dispersion. CO has always been present as a minor constituent of the

atmosphere, chiefly as a product of volcanic activity but also from natural and man-made fires

and the burning of fossil fuels.

7.1.2.5 Hydrogen fluoride

HF is a colourless gas with a pungent smell. HF can cause irritation to the eyes, nose and

throat, and high levels of exposure can cause muscle spasms and may damage internal organs.

The main releases of hydrogen fluoride are from high temperature industrial processes.

7.1.2.6 Hydrogen chloride

HCl is a colourless or slightly yellow corrosive gas. It is highly soluble in water, forming

hydrochloric acid. HCl is formed by industrial activities such as coal-burning power stations and

incinerators. Fossil fuels contain small amounts of naturally-occurring chlorides and HCl is

produced when they are burnt.

7.1.2.7 Heavy metals

Heavy metals associated with coal combustion include arsenic, cadmium, chromium, copper,

mercury, nickel, lead, selenium, vanadium and zinc. Emissions of these metals result from their

presence in the coal and are released during combustion.

7.1.2.8 Other

In addition to the above pollutants, other substances such as dioxins and unburnt hydrocarbons

can also be released. Often these pollutants are found in coal and released when incomplete

combustion occurs when there is insufficient oxygen.

7.2 Applicable legislation

7.2.1 Overview

This section details the legislative requirements in terms of ambient air quality standards for the

protection of human health and emissions limits applicable to coal fired power plants. For

comparison and reference, international standards for emissions limits have also been included.


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7.2.2 National requirements

The Government of Pakistan’s Ministry of Environment published two Statutory Notifications

relating to air quality on 10 August 2000 and t18 October 2010. The Statutory Notifications,

known as the NEQS, set the standards in Pakistan for emission limits and ambient air quality

standards.

In December 2014, SEPA issued Notification NO.EPA/TECH/739/2014, which repealed the

NEQS in the Sindh Province and provides a new set of emissions limits and ambient air quality

standards. The Sindh EPA standards are referred to as the SEQS for industrial gaseous

emissions.

7.2.2.1 Pakistan emissions limits

Relevant emission limits from the SEQS are presented and compared to international standards

in Table 21.

7.2.3 International guidelines

7.2.3.1 IFC PSs

The IFC provides a portfolio of standards and guidelines that should be adhered to for any

Project seeking IFC finance. The IFC PS3: Resource Efficiency and Pollution Prevention aims:

‘to avoid or minimize adverse impacts on human health and the environment by avoiding or

minimizing pollution from Project activities’. To achieve this, the IFC provides both industry-

specific and general guidance on Good International Industry Practice (GIIP) with respect to

emissions to air. Relevant IFC emission limits are presented for comparison in Table 21.

Table 21 provides a summary of the relevant international emission limits potentially applicable

to the Project.

Table 21: Relevant emission standards

Pollutant Pakistani standards (mg/Nm3) (a) IFC guidelines (mg/Nm3) (b)

Non-degraded airshed (NDA)

Degraded airshed (DA)(c)

NOx 1200 510 or up to 1,100 if volatile matter of fuel <10%

200

SO2 Emissions limits for SO2 are dependent on existing ambient air quality in the Project area and specify maximum emissions limits and allowable contributions to ground level concentrations shown in Table 22.

900-1500(e) 400

PM 500(d) 50 30

CO 800 - -

Lead 50 - -

Mercury 10 - -

Cadmium 20 - -

Arsenic 20 - -

Copper 50 - -

Antimony 20 - -

Zinc 200 - -

Source: NO.EPA/TECH/793/2014, Government of Sindh Environment Protection Agency (2014).

Notes: (a) Reference conditions not stated


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(b) IFC EHS Guidelines for Thermal Power Plants. Nm³ is at 0ºC, dry, 6% O2, 1 atmospheric pressure

(c) An airshed is considered to be degraded if nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly.

(d) Sectoral guidelines state that removal efficiencies from exhaust gases are over 99% for all particulates and over 98% for PM10. These removal efficiencies should be achieved at least 95% of the time that the plant is operating.

(e) Targeting the lower guideline values and recognising issues related to quality of available fuel, cost effectiveness of controls on smaller units, and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant).

National emissions limits for SO2 are dependent on existing ambient air quality in the Project

area. The maximum emissions limits and allowable contributions to ground level concentrations

shown in Table 22.

Table 22: Standards for oil and coal fired power plants – sulphur dioxide

Background Air Quality (SO2 Basis)

Annual Average

Concentration (µg/m³)

Maximum 24 Hour

Concentration (µg/m³)

Criterion I Max SO2

Emissions (tpd per plant)

Criterion II Max allowable ground

level increment to ambient (µg/m³) (c)

Unpolluted < 50 < 200 500 50

Moderately polluted (a) - low

- high

50

100

200 400

500 100

50 10

Very polluted (b) > 100 > 400 100 10

Source: NO.EPA/TECH/793/2014, Government of Sindh Environment Protection Agency (2014)

Notes: (a) For intermediate values between 50 and 100µg/m³ linear interpolations should be used. (b) No projects with SO2 emissions will be recommended. (c) Annual average.

In addition to the emission limits from NOx, presented in Table 21, the SEQS also provides

maximum mass emissions of NOx for stationary source discharges, based on heat input of the

plant and are presented in Table 23.

Table 23: Maximum mass emissions for stationary sources – oxides of nitrogen

Fuel-fired steam generator type Nanogram per joule of heat input

Liquid fossil fuel 130

Solid fossil fuel 300

Lignite fossil fuel 260

Source: NO.EPA/TECH/793/2014, Government of Sindh EPA (2014)

7.2.4 Ambient air quality standards

7.2.4.1 Government of Sindh air quality standards

The Government of Sindh’s EPA published updated air quality standards for Pakistan in

December 2014. All ambient air quality standards and the applicable averaging periods are

presented in Table 24 overleaf.


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Table 24: Sindh Environmental Quality Standards for ambient air

Pollutant Time-weighted average (a) (b)

Concentration in ambient air

Sulphur dioxide (SO2) Annual 80 µg/m³

24 hours 120 µg/m³

Oxides of nitrogen (as NO)

Annual 40 µg/m³

24 hours 40 µg/m³

Oxides of nitrogen (as NO2)

Annual 40 µg/m³

24 hours 80 µg/m³

Ozone (O3) 1 hour 130 µg/m³

Suspended particulate matter (SPM) Annual 360 µg/m³


Respirable particulate matter (PM10) Annual 40 µg/m³(c)


Respirable particulate matter (PM2.5) 24 hours 75 µg/m³

Carbon monoxide (CO) 8 hours 5 mg/m³

1 hour 10 mg/m³

Lead (Pb) Annual 1µg/m3

24 hours 1.5µg/m3

Source: NO.EPA/TECH/793/2014, Government of Sindh EPA (2014)

Note: (a) Annual arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval.

(b) 24 hourly / 8 hourly values should me met 98% of the time in a year. 2% of the time it may be exceeded but not on two consecutive days.

(c) Annual Average limit of 40µ/m³ or background annual average concentration plus allowable allowance of 9µg/m³, whichever is lower.

7.2.4.2 IFC Guidelines

The IFC General Environmental Health and Safety (EHS) Guidelines advise that ‘relevant

standards’ with respect to ambient air quality are national legislated standards or, in their

absence, the current World Health Organisation (WHO) Air Quality Guidelines or other

internationally recognised sources. As Pakistan has its own nationally legislated standards, as

described above, no additional international standards have been presented for comparison

purposes.

The IFC General EHS Guidelines suggest that, as a general rule, emissions should not

contribute more than 25 percent of the relevant air quality standards to allow additional, future

sustainable development in the same airshed and this approach has been used to help

determine the significance of impacts.

7.3 Methodology and assessment criteria

7.3.1 Overview

This section provides an overview of the assessment approach taken and the inputs used within

the dispersion modelling.


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7.3.2 Scope of assessment

7.3.2.1 Temporal scope

It is anticipated that the construction period of the Project will be a maximum of 40 months and

the operational lifetime of the Project will be for a minimum of 30 years.

7.3.2.2 Spatial scope

The baseline includes a review of available air quality data in the vicinity of the Project.

Construction impacts would be located close to the site and will not extend beyond 500m from

the construction or decommissioning activities.

In accordance with best practice, potential impacts of emissions from the operation of the

Project on ambient air quality have been assessed within 15km of the stack as all potentially

significant impacts are predicted to occur within this distance.

7.3.3 Construction phase impact assessment methodology

Construction activities can result in temporary effects from dust. ‘Dust’ is a generic term which

usually refers to particulate matter in the size range 1-75 microns. Emissions of construction

dust are predominantly associated with the movement and handling of minerals and therefore

composed of the larger fractions of this range, which do not penetrate far into the respiratory

system. Therefore, the primary air quality issue associated with construction phase dust

emissions is normally loss of amenity and/or nuisance caused by, for example, soiling of

buildings, vegetation and washing and reduced visibility.

Dust deposition can be expressed in terms of mass per unit area per unit time, e.g.

mg/m2/month. No relevant Pakistani or IFC standards exist for dust deposition; however, a

range of criteria from 133 to 350mg/m2/month is found around the world as representative of

thresholds for significant nuisance.

It is considered that a quantitative approach is inappropriate and unnecessary for assessing

particulate emissions associated with the construction and decommissioning phases of the

Project, given their relatively short duration and limited number of sensitive receptors. The

potential for construction and decommissioning activities to raise dust, and the likely

consequences of dust emissions have therefore been assessed qualitatively.

The first stage of the assessment involved the identification of construction activities which have

the potential to cause dust emissions, along with the degree of dust potential. Table 25 provides

a generic list of potential activities at each stage of construction. Selected information for this

table has been used within this assessment to determine the impact of the Project with respect

to construction dust.


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Table 25: Relevant generic dust emitting activities

Potential dust emitting activities

Description Dust emission potential

Aggregate handling Potential to be high in dust nuisance, depends on soil dryness

High

Loading Activities Potential to be high in dust nuisance, depends on material characteristics

High

Storage of materials onsite Potential to be high in dust nuisance, depends on material characteristics

High

Transport of materials within site Can be high depends on type of transport and nature of road surface

Medium

Drilling and digging activities (Including soil excavation)

Can be high depending on type of drilling and digging activities and material characteristics

High

Transport of material offsite Generally low as transport occurs by surfaced roads

Low

Construction of new buildings Generally low although some activities with high dust raising such as material cutting can occur

Medium-Low

Assembly of plant Generally low as involves assembling prefabricated pieces

Low

Source: Table adapted from UK Department for Environment and Rural Affairs and Buildings Research Establishment guidance

In the second stage of the assessment, all sensitive receptors with the potential to be

significantly affected by construction dust emissions have been identified. The distances from

source at which construction dust effects are felt are dependent on the extent and nature of

mitigation measures, prevailing wind conditions, rainfall and the presence of natural screening

by, for example, vegetation or existing physical screening such as boundary walls on a site.

However, research indicates that effects from construction activities that generate dust are

generally limited to the areas within 350m8 of the construction site boundary. To ensure a

conservative assessment, any receptors within 500m of the construction site boundary have

been identified, and their classification determined in accordance with Table 26.

Table 26: Receptor classification

Classification

High Medium Low Negligible

Hospitals and clinics Residential property Arable farm land Pastoral farmland

- School Other Industry -

- Place of worship - -

It should be noted that the same approach used for the construction phase has been used for

assessing operational impacts from the coal storage and handling facilities.

At this stage exact numbers of construction vehicles are not known and the routes that they will

take are not defined. However, during peak construction periods the total number of vehicle

movements is expected to be less than 200 per day9. On this basis, there is not considered to

be the potential for significant impacts. Nevertheless, appropriate mitigation measures have

been included to further reduce effects on local air quality.

8 Holman et al (2014). ‘Guidance on the assessment of dust for demolition and construction’, Institute of Air Quality Management, London 9 Design Manual for Roads and Bridges’, HA207/07, Volume 11, Section 3 Part 1 ‘Air Quality’, Highways Agency, UK


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7.3.4 Operation phase impact assessment methodology

7.3.4.1 Dispersion model

A number of commercially available dispersion models are able to predict ground level

concentrations arising from emissions to atmosphere from elevated point sources such as a

power plant. A new generation dispersion model - AERMOD (executable version 15181) was

used to inform the basis of the air quality assessment. AERMOD is approved for use in Pakistan

and is listed in the ‘EIA Guidance for Coal Fired Power Plants in Pakistan’10. A model

description is included below.

A committee, AERMIC (the American Meteorological Society / Environmental Protection Agency

Regulatory Model Improvement Committee), was formed to introduce state-of-the-art modelling

concepts into the US Environmental Protection Agency’s local-scale air quality models.

AERMIC’s focus was on a new platform for regulatory steady-state plume modelling. AERMOD

was designed to treat both surface and elevated sources in simple and complex terrain.

Special features of AERMOD include its ability to treat the vertical heterogeneity nature of the

planetary boundary layer, special treatment of surface releases, irregularly-shaped area sources

and limitation of vertical mixing in the stable boundary layer.

AERMOD is a modelling system with three separate components and these are as follows:

● AERMOD (AERMIC Dispersion Model)

● AERMAP (AERMOD Terrain Pre-processor)

● AERMET (AERMOD Meteorological Pre-processor).

AERMET is the meteorological pre-processor for AERMOD. Input data can come from hourly

cloud cover observations, surface meteorological observations and twice-a-day upper air

soundings. Output includes surface meteorological observations and parameters and vertical

profiles of several atmospheric parameters.

AERMAP is a terrain pre-processor designed to simplify and standardise the input of terrain

data for AERMOD. Input data include receptor terrain elevation data. For each receptor, the

output includes a location and height scale, which is an elevation used for the computation of

air-flow around hills.

7.3.4.2 Emissions to air

Emissions data have been based on information provided by SEPCO and additional

calculations have carried out as part of this assessment.

Data provided by SEPCO including stack dimensions, exhaust gas temperature and excess air

in the exhaust gas have formed the basis of data used within the dispersion modelling and this

data is presented in Table 27 overleaf.

Following a review of the potential operating scenarios two scenarios have been assessed to

identify the potential impacts of the Project:

● Scenario 1: Maximum load (100% boiler load)

● Scenario 2: Low load (45% boiler load)

10 Coutinho, Miguel and Butt, Hamza K. 2014. Environmental Impact Assessment Guidance for Coal Fired Power Plants in Pakistan.

Islamabad: IUCN Pakistan. 149 pp.


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The Project is expected to achieve emissions lower than the SEQS emission limits for NOx, SO2

and PM. In addition, the Project will also achieve emissions lower than the IFC non-degraded

airshed emission limits for NOx and SO2 and meet the emissions limits for PM.

Emissions of CO are related to poor combustion and therefore would be mitigated through the

efficient operation of the Project. Emissions of CO have not been assessed further as they are

not a key pollutant with respect to this assessment given the predicted emission rates and

because relevant ambient standards are significantly higher than those for NO2, SO2 and PM10.

In addition to the pollutants included in the dispersion modelling assessment, the consideration

of heavy metals is also relevant for human health (concentrations in ambient air quality). Table

28 presents the results of a study that analysed borehole lignite samples within Block I, II and III

in the Tharparkar Region. These data have been used to calculate likely emission rates of a

range of heavy metals after the exhaust gas has passed through the electrostatic precipitator

(ESP). An International Journal of Coal Geology entry on the analyses of chemical elements

and their behaviour in power plants demonstrated that heavy metals are present in fly ash

downstream of ESP and in the last hopper (finest fraction) of an ESP11. It has therefore been

assumed that all metals are present in the PM2.5 emitted.

The only heavy metal that the SEQS set an ambient standard for is Pb, as presented in Table

24. The heavy metal emissions rates presented in Table 28 are several orders of magnitude

lower than those for NO2, SO2 and PM. Therefore, concentrations of heavy metals would also

be several order of magnitude lower than those predicted for NO2, SO2 and PM. The impacts

from heavy metals have not been considered further within this assessment as predicted

impacts are likely to be extremely low, have no ambient standards for comparison, except for

Pb, and are therefore considered to be not significant.

Although the proposed abatement for the Project will not specifically reduce emissions of HCl

and HF, emissions are expected to be very small relative to pollutants such as NOx, SO2 and

PM. The European Union (EU) Best Available Technique Reference document for Large

Combustion Plants (BREF note) Final Draft BREF12 note states that the BAT associated level of

HCl is between 15-30mg/Nm3. On this basis, no further assessment has been undertaken as

impacts are considered to be not significant.

The EU BREF note states ‘emissions of dioxins and furans from coal plants are low due to their

specific combustion characteristics and the sulphur content of the fuel which impedes the

combustion of these compounds’. The BREF note provides emission levels of dioxins from a

range of existing coal plants which are 2pg/Nm3 (10-12g). This indicates that the maximum

impacts would be over a million times smaller than the impacts predicted for PM and therefore

have not been considered further as impacts are considered to be not significant.

Table 27: Emissions data

Parameter Unit Scenario 1 Scenario 2

Stack Height m 210 210

Stack Diameter(b) m 7.1 7.1

Efflux Temperature °C 130 130

Plant load % 100 45

Output MWe 660 297

Actual Volumetric Flow Am3/s 1087.4 489.3

11 Meij, R. and te Winkel, B.H. (2009) “Trace elements in world steam coal and their behaviour in Dutch coal-fired power stations: A

review”, International Journal of Coal Geology, 77, 289-293. 12 European Commissions, Best Available Techniques (BAT) Reference Document for the Large Combustion Plants, Draft 1, June 2013


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Parameter Unit Scenario 1 Scenario 2

Normalised Volumetric Flow (a) Nm3/s 685.5 308.5

Efflux Velocity m/s 27.7 12.5

NOx emission limit mg/Nm3 350 350

SO2 emission limit mg/Nm3 625 625

PM emission limit mg/Nm3 50 50

NOx mass emission g/s 239.9 108.0

SO2 mass emission g/s 428.5 192.8

PM mass emission g/s 34.3 15.4

Note: (a) – 6% O2, dry, 1 atm

(b) – Two boiler units, each with a 5m diameter flue will feed into a common wind shield. The combined cross sectional area of the two flues, at which the exhaust gas is released at the top of the windshield, is calculated. The 7.1m dimeter is representative of the joint cross sectional area.

Table 28: Metal content of Thar Coalfield lignite samples (Block I, II and III)

Metals PPM (mg/kg) Emission Rate (g/s) after ESP

Minimum Maximum

Antimony (Sb) 1 4 0.00197

Arsenic (As) 1 4 0.00197

Beryllium (Be) (a) 1 1 0.00049

Cadmium (Cd) 0.1 0.4 0.0002

Chromium (Cr) 21 47 0.02319

Cobalt (Co) 2 25 0.01234

Copper (Cu) 8 38 0.01875

Lead (Pb) 36 65 0.03208

Manganese (Mn) 0.1 2 0.00099

Mercury (Hg) (a) 1 1 0.00049

Nickel (Ni) 9 75 0.03701

Selenium (Se) (a) 1 1 0.00049

Zinc (Zn) 8 116 0.05725

Source: PhD Thesis13

Note: (a) Assumed values in the absence of other data.

7.3.4.3 Meteorological data

The most important meteorological parameters governing atmospheric dispersion of pollutants

are wind direction, wind speed and atmospheric stability; as described below:

● Wind direction determines the sector of the compass into which the plume is dispersed.

● Wind speed affects the distance which the plume travels over time and can affect plume

dispersion by increasing initial dilution of pollutants and inhibiting plume rise.

● Atmospheric stability is a measure of the turbulence of the air, and particularly of its vertical

motion. It therefore affects the spread of the plume as it travels away from the source. New

generation dispersion models use a parameter known as the Monin-Obukhov length that,

together with wind speed, describes the stability of the atmosphere.

13 Environmental Study of Coal Deposits of Sindh, with Special Reference to Heavy and Trace Metal Study in Thar, Sonda and Meting-

Jhimpir Coal Field. Dr Imdadullah Siddiqui, National Centre of Excellence in Geology, University of Peshawar (2007)


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For meteorological data to be suitable for dispersion modelling purposes, a number of

parameters need to be measured on an hourly basis. These parameters include wind speed,

wind direction, cloud cover and temperature. Available data from Chorr and Mithi were reviewed

and data capture and consistency found to be insufficient for modelling purposes. Data were

therefore sourced from the closest and most representative meteorological monitoring site to the

Project that measures all the required parameters and is internationally verified by the National

Oceanic and Atmospheric Administration’s Climate Data Center and has been converted to

hourly values using an internationally recognised method14. The meteorological monitoring site

at Badin is located approximately 140km to the west of the Project.

As part of the baseline monitoring undertaken for the Project, presented in section 7.4, three

days of meteorological data were collected at three separate sites; their locations are presented

in Figure 14. The Project meteorological data collected, presented in Volume III: Technical

Appendices, shows dominant southerly winds similar to those monitored at Badin.

On the basis that meteorological data from Badin is internationally verified and similar to Project

specific meteorological data, the dispersion modelling has been based on data from Badin

meteorological station from 2009-2013. Windroses presenting this data are presented in Figure

10 overleaf.

14 Atkinson. D. and Russell. F. Lee, (1992) ‘Procedures for Substituting Values for Missing NWS Meteorological Data for Use in

Regulatory Air Quality Models’, USEPA.


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Figure 10: Badin meteorological windroses (2009 – 2013)


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7.3.4.4 Surface roughness and terrain

Roughness of the terrain over which a plume passes can have a significant effect on dispersion

by altering the velocity profile with height and the degree of atmospheric turbulence. This is

accounted for in the meteorological data processing by a parameter called the ‘surface

roughness length’.

The surface roughness length within the study area has been calculated based on the land uses

(grassland) around the meteorological station within a 1km and a 15km area and calculated

within the AERMET meteorological processor.

The presence of elevated terrain can significantly affect (usually increase) ground level

concentrations of pollutants emitted from elevated sources such as stacks, by reducing the

distance between the plume centre line and ground level and increasing turbulence and, hence,

plume mixing. The effect of complex terrain occurs when gradients exceed 1 in 10m (10%). As

the study area consists of relatively flat terrain its inclusion within the dispersion modelling is not

considered necessary.

7.3.4.5 NOx to NO2 conversion

A 100% conversion of NOx to NO2 has been assumed for all averaging periods, in line with the

first tier of the ‘EIA Guidance for Coal Fired Power Plant in Pakistan.’ A conversion rate of 100%

is a conservative assumption as international methods often assume NOx to NO2 conversion

rates between 35% and 70%.

7.3.4.6 Particulate matter fraction

This assessment conservatively assumes that all fly ash, known as total suspended particulates

(TSP), and referred to as SPM in Table 24, is in the PM10 size range (10µm or less). Therefore,

the predicted concentration of TSP will be equal to the predicted concentration of PM10 and

assessed against the relevant SEQS. The fraction of fly ash in the PM2.5 size range (2.5µm or

less) is assumed to be 7%15.

7.3.4.7 Buildings and Project layout

The movement of air over and around buildings generates area of flow circulation, which can

lead to increased ground level pollutant concentrations in the building wakes. The buildings

likely to have the dominant effect (i.e. with the greatest dimensions likely to promote turbulence)

are the boiler houses, the turbine house and the deaerator bay. Table 29 presents the building

dimensions assumed within the assessment and Figure 11 provides a visual representation of

the building inputs in the dispersion model.

Table 29: Modelled buildings

Building Name Height (m) Length (m) Width (m) Angle

Turbine House 29 27 136.2 31.5

Deaerator Bay 65 9.5 136.2 31.5

Boiler House 1 69.7 79 44 31.5

Boiler House 2 69.7 79 44 31.5

Note: (a) Angle shows rotation clockwise from a line running north to south

15 Aerosol and Air Quality Research. Hui Li, Guijian Liu, Yan Cao. Content and Distribution of Trace Elements and Polycyclic Aromatic

Hydrocarbons in Fly Ash from Coal-Fired CHP Plant.


366982 | 02 | B | March 2017

Figure 11: Buildings included within the Model

Source: Grid lines show 100m spacing

7.3.4.8 Receptors

Within this chapter of the ESIA, the phrase ‘discrete receptor’ has been used to refer to a

specific location where the dispersion model has been used to predict pollutant concentrations.

Additionally, a ‘receptor grid’ refers to a dispersion modelling concept where pollutant

concentrations are predicted over a grid in uniform arrangement. The discrete receptors allow

air quality impacts to be assessed at identified existing receptor locations. The receptor grid aids

the assessment of pollutant concentrations over a wide spatial area and, by interpolating

between these points, allows the production of pollutant contours which illustrate how pollutant

concentrations change across the study area.

In order to assess potential impacts on sensitive receptors, modelling was carried to predict

pollutant concentrations across a study area with a 15km radius grid. This involved modelling a

30 x 30km grid of receptors with a receptor spacing of 300m and a 10 x 10km grid with a

receptor spacing of 100m and assumed receptor heights of 1.5m.

Outputs from the modelled grids have been used to present ground level ambient pollutant

concentrations from the Project, referred to as ‘process contributions’. These process

contributions have been added to ‘ambient concentrations’ to report the ‘predicted

environmental concentrations’.

Discrete receptors have also been modelled at locations presented in Table 30 and Figure 12

overleaf. The discrete receptors are consistent with those assessed as part of this ESIA in

chapter 15.


366982 | 02 | B | March 2017

Table 30: Discrete receptor locations

Receptor Name X Y

Yusuf Ji Dhani 633578 2749593

Gangu Bhil Ji Dhani 634138 2750416

Salar Ji Dhani 634072 2751040

Jadhe Dhani 637355 2751057

Murad Dhani 638414 2752053

Mithe Ji Wand 639278 2750936

Saleh Jhanihi 642047 2749736

Bakhato Dhani 641074 2748568

Bhitro Bhill 639694 2746701

Munhan Tar 631591 2751384

Mehun Linju 629679 2750931

Mangu Bheel 626928 2747726

Ramnia Bhil 624034 2748818

Singharo 633485 2742931

Bhilan Jo Goth 633570 2741761

Aban Jo Tar 637604 2743050

Achie Ji Dhani 637929 2753663

Mangho Thakar Jo Tar 633727 2753887

Note: Coordinate System: Universal Transverse Mercator (UTM) WGS1984 Zone 42N

Receptor height is 1.5m above ground level

Figure 12: Discrete receptor locations


366982 | 02 | B | March 2017

7.3.5 Impact assessment criteria

7.3.5.1 Construction impacts

The methodology for determining impact significance from dust is presented in Figure 13.

Figure 13: Methodology for determining the impact significance of dust

Note: [1] According to Table 32

[2] According to Table 31

[3] According to significance criteria adopted for this assessment, presented in chapter 5 of this

ESIA.

A combination of dust emission potential from on-site activities (Table 31) and their expected

duration has been used to determine the impact magnitude of construction and

decommissioning phases (Table 32).

Table 31: Determination of impact magnitude – construction phase

Dust Raising Potential (a) Duration Magnitude

High Any Major

Medium > 3 Months Moderate

Medium < 3 Months Minor

Low Any Negligible

Notes: (a) Dust raising potential defined in accordance with the approach described in Section 7.3.3

In addition, receptor sensitivity has been based on the type of receptor and the distance from

the construction or decommission activity boundary. Table 32 overleaf presents the criteria on

which receptor sensitivity has been based.


366982 | 02 | B | March 2017

Table 32: Determination of receptor sensitivity – construction phase

Receptor Classification(a) Distance to Activities

0-50m 50-100m 100-200m 200-500m

High High High Medium Low

Medium Medium Medium Low Low

Low Medium Low Low Negligible

Negligible/No Receptors Negligible Negligible Negligible Negligible

Notes: (a) Receptors classified based on method described in Table 26

7.3.5.2 Operational impacts

Guidance has been issued in the UK16 to assist in determining the significance of operational

phase impacts in air quality assessments. This guidance recommends that significance should

be determined by a combination of two aspects:

● Change in concentrations (Process Contribution (PC) caused by the Project at sensitive

receptors

● Resulting total concentrations (Predicted Environmental Concentrations (PEC)) at sensitive

receptors as a percentage of the relevant ambient air quality standard(s)

This approach is considered to represent best practice for assessments of this kind and has

therefore been adopted in determining the significance of impacts on local air quality from the

Project.

Changes in ambient concentrations over 25% of the relevant standards are considered to

represent an impact of ‘major’ magnitude as the General EHS Guidelines note that projects

should:

‘…prevent or minimize impacts by ensuring that …emissions do not contribute a significant

portion to the attainment of relevant ambient air quality guidelines or standards. As a general

rule, this guideline suggests 25 percent of the applicable air quality standards to allow additional

future sustainable development in the same airshed.’ (IFC EHS Guidelines).

The IFC General EHS Guidelines classify ‘poor quality airsheds’ as those where relevant

standards are exceeded significantly. Therefore, receptors experiencing existing ambient

pollutant concentrations above the relevant standards are concluded to be of ‘High’ sensitivity.

For each of the key pollutants and averaging periods assessed, a number of ambient air quality

standards are applicable.

Impact magnitude and receptor sensitivity criteria are presented in Table 33 and Table 34.

Table 33: Determination of impact magnitude– operational phase

Change in concentrations as % of standard Magnitude

Increase >25% Major

Increase 15-25% Moderate

Increase 5-15% Minor

Increase <5% Negligible

16 Air emissions risk assessment for your environmental permit’ (2016), UK Environment Agency and Department for Environment, Food

and Rural Affairs


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Table 34: Determination of receptor sensitivity – operational phase

Baseline pollutant concentrations in relation to standard Receptor sensitivity

Above standard High

75 to 100% of the standard Medium

50 to 75% of the standard Low

Below 50% of the standard Negligible

7.3.5.3 Significance

Based on the methods defined above for determining the magnitude of impact and sensitivity of

receptors, the significance matrix specified in chapter 5 has been applied to determine overall

significance.

Notwithstanding the above, any non-negligible increases causing a new exceedance of the

relevant standards are considered of ‘major’ adverse significance. All impact descriptors

described as ‘moderate’ or ‘major’ are considered to be significant.

7.4 Baseline description

7.4.1 Overview

There is no long term air quality monitoring data within the Sindh province suitable for

comparison with applicable legislative ambient air quality limits. However, SGS Pakistan (Pvt)

Limited were commissioned to undertake an air quality monitoring study. The air quality

monitoring data collected has been presented below along with a location map of the monitoring

sites. The location map shows that site 1 was located downwind of the Project, whilst sites 2

and 3 were located upwind. The overall outcomes of the monitoring have been presented in this

section.

7.4.2 Monitoring results

The ambient air quality monitoring was performed on an hourly basis for a period of 24 hours at

each monitoring site. Average values were calculated for each monitored pollutant at each

monitoring site and the ambient air quality monitoring results are presented in Table 35 and

Figure 14. The monitoring data show that average values of NO2, SO2 and CO and Lead (Pb)

are well below the SEQS limits. Ozone (O3) was not detected or remained below detection limit

at all monitoring sites. The most significant air pollutants in the area were found to be TSP and

PM10, which exceeded the SEQS. These higher concentrations are likely to be due to the

natural soil and meteorological conditions of the Tharparkar area.

As the monitoring covered a relatively short period it is possible that the worst case 1 hour and

24 hour concentrations may have been missed. To overcome this, the ambient concentrations

presented in Table 35 are assumed to be representative of annual ambient concentrations and

in accordance with best practice methods have been doubled for short term averaging periods

(less than 24 hours), for comparison with the short term SEQS.


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Table 35: Overall results of ambient air quality

Monitoring Location NO2

SO2

CO Pb TSP

PM10 PM2.5 O3

1 0.4 4.6 4500 ND 345 121 38 ND

2 0.3 6.6 2200 ND 467 297 48.1 ND

3 0.3 5.7 3700 ND 421 231 40.2 ND

Average 0.3 5.6 3466.7 ND 411 216.3 24.1 ND

Annual SEQS Limit 40 80 5000 1 360 40 - 80

24 Hour SEQS Limit(a) 80 120 10000 1.5 500 150 75 130

Units: µg/m3

ND = not detected or below detection limits

Bold text indicated SEQS value is exceeded

(a) O3 SEQS limit is for a 1 hour averaging period

Figure 14: Air quality monitoring locations

7.5 Impact identification and assessment

7.5.1 Construction impacts

As described in Section 7.3.3, consideration has been given to receptors within 500m of the

Project or associated access roads. Table 36 presents receptors within these criteria and their

associated sensitivity in accordance with Table 26.


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Table 36: Receptor sensitivity

Construction activity Receptor type Distance from source

Receptor sensitivity

Access road (new and existing)

Residential 100-200m Low

Place of worship 100-200m Low

School 100-200m Low

Project Site Animal grazing 0-50m Negligible

Although no detailed construction methodology is available at present and therefore the

construction assessment has been based on generic activities. The construction period is

expected to commence in Q2 2017 and last for 40 months and will consist of major construction

works including site clearance and considerable earthworks at the start of construction. Table

37 presents the dust raising potential of the assumed activities associated with construction of

the Project whilst Table 38 presents the overall impact significance. Figure 15 presents the

locations of the Project, the access road, and sensitive receptors.

Table 37: Construction activities and dust emitting activities during construction

Section Description of works

Key activities Dust raising potential

Duration at any one point

Impact magnitude

Site preparation, clearance and groundworks

Excavation and moving material

Earthmoving

Excavation

Wind

High (assumes undertaken in dry seasons)

>3 months Major

Roads and infrastructure

Ancillary works and delivery of materials to site, removal of wastes from site

Minor excavation works.

Transport of materials.

Re-suspension of dust on unsurfaced roads.

Medium > 3 months Moderate

Construction of plant

Assembly of the main components of the plant

Storage of materials

Preparation of materials (cutting)

Re-suspension of dust on unsurfaced roads

Medium > 3 months Moderate

Landscaping Landscaping requirements

Earthmoving

Excavation

Transport of materials

Wind

Re-suspension of dust on unsurfaced roads

High (assumes undertaken in summer months)

< 3 months Major

Table 38: Impact significance

Section Worst case receptor sensitivity

Worst case impact magnitude

Impact significance

Roads and infrastructure Low Moderate Minor

All activities at Project site Negligible Major Minor


366982 | 02 | B | March 2017

Figure 15: Construction Dust Receptor Locations

In accordance with the significance criteria adopted for this assessment, the risk of construction

dust impacts associated with the Project is minor adverse and therefore not considered

significant. It should be noted that fugitive dust arising from natural lift and transport of

particulate matter is a common phenomenon due to the nature of the ground and the climate in

Sindh and the Tharparkar area.

In the event of decommissioning of the Project, it is likely that any potential air quality impacts

would be similar to those in the construction phase, as broadly similar activities would be

required. Similar to the construction phase, these impacts are considered to be minor adverse

and therefore not significant.

There is some uncertainty related to the presence of receptors in the future, which, depending

on the time of decommissioning, may have been introduced or removed from the study area.

Therefore, at the time of decommissioning, the management plan should take due care to

ensure that all receptors at that time are accounted for and that the management plan

adequately minimises potential issues for receptors that could be affected.

7.5.2 Operation impacts

7.5.2.1 Emissions from coal storage and handling

The proposed storage and handling of the coal would be potential sources of particulate

emissions during operation:

● Coal will be transported to the power plant by a covered belt conveyor

– Releases at the loading and delivery ends of the conveyor

● Storage of coal at the stockpile

● Wind erosion of pile (particularly during hot, dry conditions)


366982 | 02 | B | March 2017

● Plant activity around the stockpile during maintenance

Particulate emissions from coal storage and handling comprise of small particles (PM10) which

can have negative health effects and larger particles (referred to as ‘dust’) which can cause

nuisance or a loss of amenity.

The potential for emissions of fugitive dust and PM10 from the coal storage and handling

facilities is high due to wind erosion of the stockpile during hot, dry conditions and plant activity

around the stockpile during maintenance and therefore is described as ‘major’.

Based on the proposed plot plan there is animal grazing land within 50m of the Project site. In

accordance with the construction dust assessment these receptors are described as being

‘negligible’ in sensitivity.

In accordance with the significance criteria adopted for this assessment, the risk of operation

phase dust impacts associated with the Project is minor adverse and therefore not significant.

Operation phase activities will be controlled by best practice mitigation techniques to reduce any

potential impacts on grazing land to negligible and therefore not significant.

7.5.2.2 Emissions from the stack

The following section presents the maximum predicted ground level concentrations as a result

of emissions from the Project and provides an assessment of their significance against the

SEQS.

Scenario 1 – 100% boiler load Table 39 and Table 40 present the maximum ground level concentrations predicted within the

modelled grids and at discrete receptors for Scenario 1.

Table 39 shows that the impact magnitude of process contributions of NO2 and SO2 for the 24

hour 98th percentile and annual averaging periods are ‘minor’. The existing ambient

concentrations of these pollutants are well below the SEQS and therefore the receptor

sensitivity is ‘negligible’. In accordance with the assessment approach the impact descriptor is

described as ‘negligible’ and therefore not significant.

Predicted process contributions of TSP, PM10 and PM2.5 from the Project are ‘negligible’. As

discussed in Section 7.4, the ambient concentration of these pollutants is relatively high, due to

natural soil and meteorological conditions in the Tharparkar area. Therefore, the receptor

sensitivity is classed as ‘high’ for TSP and PM10 and ‘low’ for PM2.5. Overall, the impact

descriptor for TSP, PM10 and PM2.5 is described as ‘negligible’ as a result of the low process

contribution from the Project and therefore described as not significant.

The SEQS requires that 24 hourly ambient standards should be met 98% of the year. For the

other 2% of the year, the relevant 24 hour ambient standard may be exceeded but not on two

consecutive days.


366982 | 02 | B | March 2017

Table 41 lists the dates during which the seven maximum 24 hour concentrations

(corresponding to the 24 hour 98th percentile) were predicted and demonstrates that worst case

meteorological conditions occurred sporadically throughout the year.

Table 39 shows that the predicted maximum 24 hour concentrations are below the relevant

SEQS for NO2, SO2 and PM2.5; therefore there are no predicted consecutive days where the

pollutants exceed the 24 hourly SEQS.

Table 41 shows that for the worst case model year of 2010, the model predicts two consecutive

days where the predicted concentration is greater than the 24 hour 98th percentile (which is

equivalent to the seventh highest predicted concentration). As discussed above, the ambient

concentration of TSP and PM10 are greater than the SEQS, which is likely due to the natural soil

and meteorological conditions in the Tharparkar area. The process contributions of these

pollutants is negligible and consecutive days of exceedence of the 24 hour SEQS are likely

caused by the natural environment in Tharparkar and not by the Project.

According to the significance criteria adopted for this assessment, the impacts associated with

Scenario 1 are not significant.

Figure 16 to Figure 21 present the results from the dispersion modelling assessment as contour

plots. Contours plots of PM2.5 have not been presented due to low process contributions. The

contour plots show that process contributions reach ground level approximately 3km north east

of the Project site and that the prevailing south westerly winds strongly influence dispersion

patterns, as presented in Figure 10. The prevailing wind causes the area of impact to be narrow

and mainly confined to the north east corner of the study area.


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Table 39: Scenario 1 – Comparison with legislated Pakistan SEQS (µg/m3)

Pollutant Averaging period

Max PC

PC as a % of SEQS

Impact magnitude

AC PEC PEC as a % of SEQS

SEQS Receptor sensitivity

Impact descriptor

Significance

NO2 24 hr Max 11.9 14.9 Minor 0.8 12.7 15.9 80 Negligible Negligible Not Significant

24hr 98th %ile 9.4 11.8 Minor 0.8 10.2 12.8 80 Negligible Negligible Not Significant

Annual mean 3.9 9.6 Minor 0.4 4.3 10.6 40 Negligible Negligible Not Significant

SO2 24 hr Max 21.3 17.8 Moderate 11.2 32.5 27.1 120 Negligible Negligible Not Significant

24hr 98th %ile 16.9 14.1 Minor 11.2 28.1 23.4 120 Negligible Negligible Not Significant


TSP 24 hr Max 1.7 0.3 Negligible 822.0 823.7 164.7 500 High Negligible Not Significant

24hr 98th %ile 1.4 0.3 Negligible 822.0 823.4 164.7 500 High Negligible Not Significant

Annual mean 0.6 0.2 Negligible 411.0 411.6 114.3 360 High Negligible Not Significant

PM10 24 hr Max 1.7 1.1 Negligible 432.6 434.3 289.5 150 High Negligible Not Significant

24hr 98th %ile 1.4 0.9 Negligible 432.6 434.0 289.3 150 High Negligible Not Significant

Annual mean 0.6 0.5 Negligible 216.3 216.9 180.7 120 High Negligible Not Significant

PM2.5 24 hr max 0.1 0.2 Negligible 48.2 48.3 64.4 75 Low Negligible Not Significant

24hr 98th %ile 0.1 0.1 Negligible 48.2 48.3 64.4 75 Low Negligible Not Significant

Note: PC – Process contribution, SEQS – Government of Sindh’s Environmental Quality Standards , AC – Ambient concentration, PEC – Predicted environmental concentration. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m3. Bold indicates exceedance of Pakistan SEQS


366982 | 02 | B | March 2017

Table 40: Scenario 1 – Maximum modelled process contributions at discrete receptors (µg/m3)

Receptor NO2 SO2 TSP PM10 PM2.5

24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile

Ranjho Noon 2.7 0.4 4.8 0.7 0.4 0.1 0.4 0.1 0.0

Yusuf Ji Dhani 1.6 0.2 2.9 0.3 0.2 0.0 0.2 0.0 0.2

Gangu Bhil Ji Dhani 1.7 0.2 3.1 0.3 0.2 0.0 0.2 0.0 0.2

Salar Ji Dhani 1.8 0.2 3.2 0.4 0.3 0.0 0.3 0.0 0.3

Jadhe Dhani 8.3 3.5 14.9 6.2 1.2 0.5 1.2 0.5 1.2

Murad Dhani 7.8 3.1 14.0 5.6 1.1 0.4 1.1 0.4 1.1

Mithe Ji Wand 4.0 1.2 7.1 2.2 0.6 0.2 0.6 0.2 0.6

Saleh Jhanihi 3.4 0.5 6.1 0.9 0.5 0.1 0.5 0.1 0.5

Bakhato Dhani 3.3 0.5 6.0 0.8 0.5 0.1 0.5 0.1 0.5

Bhitro Bhill 1.0 0.2 1.7 0.3 0.1 0.0 0.1 0.0 0.1

Munhan Tar 1.2 0.2 2.1 0.3 0.2 0.0 0.2 0.0 0.2

Mehun Linju 0.8 0.1 1.5 0.2 0.1 0.0 0.1 0.0 0.1

Mangu Bheel 0.6 0.1 1.1 0.2 0.1 0.0 0.1 0.0 0.1

Ramnia Bhil 0.5 0.1 0.9 0.2 0.1 0.0 0.1 0.0 0.1

Singharo 4.5 0.6 8.0 1.1 0.6 0.1 0.6 0.1 0.6

Bhilan Jo Goth 3.2 0.5 5.7 0.9 0.5 0.1 0.5 0.1 0.5

Aban Jo Tar 0.8 0.1 1.4 0.2 0.1 0.0 0.1 0.0 0.1

Achie Ji Dhani 3.3 1.1 5.9 2.0 0.5 0.2 0.5 0.2 0.5

Mangho Thakar Jo Tar 1.1 0.1 1.9 0.3 0.2 0.0 0.2 0.0 0.2

Pakistan SEQS 80 40 120 80 500 360 150 40 75

Note: Pakistan SEQS – Government of Sindh’s Environmental Quality Standards. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m3.


366982 | 02 | B | March 2017

Table 41: Scenario 1 - Worst Case 24 Hour Meteorological Conditions

Rank 2009 2010 2011 2012 2013

1 20 March(a) 20 May 12 June 05 March(a) 31 May

2 12 May 21 June 21 August 05 March(a) 08 June

3 21 June 03 May(a) 08 June(a) 07 June 16 May

4 07 July 03 May(a) 08 June(a) 28 April 18 May

5 20 March(a) 02 May 19 June(a) 06 August(a) 24 June

6 06 September(a) 22 May 19 June(a) 06 August(a) 14 May

7 06 September(a) 19 July 16 May 16 August 11 May

Note: (a) Where dates occur twice the worst case result is occurring on the same day over multiple receptors. Bold text indicates consecutive days.


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Figure 16: Scenario 1 - Maximum modelled 24hr NO2 process contribution (98th %ile) (µg/m3)

Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2011 Met year data, contour

lines at increments of 2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North


366982 | 02 | B | March 2017

Figure 17: Scenario 1 - Maximum modelled 24hr SO2 process contribution (98th %ile) (µg/m3)

Note: Project boundary highlighted in purple. Block VI outlined in red Contour based on 2011 meteorological year data,

contour lines at increments of 2.5µg/m3. Coordinate system: UTM WGS1984 Zone 42 North


366982 | 02 | B | March 2017

Figure 18: Scenario 1 - Maximum modelled annual mean SO2 process contribution (µg/m3)

Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2012 meteorological year data,

contour lines at increments of 2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North


366982 | 02 | B | March 2017

Figure 19: Scenario 1 - Maximum modelled 24hr TSP and PM10 process contribution (98th %ile) (µg/m3)

Note: Project boundary highlighted in purple. Block VI outlined in red Contour based on 2011 meteorological year data,

contour lines at increments of 0.2µg/m3. Coordinate system: UTM WGS1984 Zone 42 North


366982 | 02 | B | March 2017

Figure 20: Scenario 1 - Maximum modelled annual mean TSP and PM10 process contribution (µg/m3)

Note: Project boundary highlighted in purple. Block VI outlined in red. Contour based on 2012 meteorological year data,

contour lines at increments of 0.1 µg/m3. Coordinate system: UTM WGS1984 Zone 42 North

Scenario 2 – 45% boiler load

Table 42 and Table 43 present the maximum ground level concentrations predicted within the

modelled grids and at discrete receptors for Scenario 2. Predicted impacts from Scenario 2 are

‘negligible’. The results show that the predicted impacts from Scenario 2 are ‘negligible’ and

process contributions from Scenario 2 are lower than those predicted from Scenario 1.


Scenario 2 are not significant.

Dispersion patterns associated with Scenario 2 are similar to Scenario 1. However, impacts are

predicted to be even less wide spread than Scenario 1 due to lower emission rates when

operating at low load.


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Table 42: Scenario 2 – Comparison with legislated Pakistan SEQS (µg/m3)

Pollutant Averaging period

Max PC PC as a % of SEQS

Impact magnitude AC PEC PEC as a % of SEQS

SEQS Receptor sensitivity

Impact descriptor

Significance

NO2 24 hr Max 8.4 10.5 Minor 0.8 9.2 11.5 80 Negligible Negligible Not Significant

24hr 98th %ile

6.3 7.9 Minor 0.8 7.1 8.9 80 Negligible Negligible Not Significant


SO2 24 hr Max 14.9 12.4 Minor 11.2 26.1 21.8 120 Negligible Negligible Not Significant

24hr 98th %ile

11.3 9.4 Minor 11.2 22.5 18.7 120 Negligible Negligible Not Significant


TSP 24 hr Max 1.2 0.2 Negligible 822.0

823.2

164.6 500 High Negligible Not Significant

24hr 98th %ile

0.9 0.2 Negligible 822.0

822.9


Annual mean 0.4 0.1 Negligible 411.0

411.4


PM10 24 hr Max 1.2 0.8 Negligible 432.6

433.8


24hr 98th %ile

0.9 0.6 Negligible 432.6

433.5


Annual mean 0.4 0.3 Negligible 216.3

216.7


PM2.5 24 hr max 0.1 0.2 Negligible 48.2 48.3 138.0 35 High Negligible Not Significant

24hr 98th %ile

0.1 0.2 Negligible 48.2 48.3 137.9 35 High Negligible Not Significant

Note: PC – Process contribution, SEQS – Government of Sindh’s Environmental Quality Standards, AC – Ambient concentration, PEC – Predicted environmental concentration. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m3. Bold indicates exceedance of Pakistan SEQS


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Table 43: Scenario 2 – Maximum modelled process contributions at discrete receptors (µg/m3)

Receptor NO2 SO2 TSP PM10 PM2.5

24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile Annual 24hr 98th %ile

Ranjho Noon 1.9 0.2 3.5 0.4 0.3 0.0 0.3 0.0 0.0

Yusuf Ji Dhani 1.2 0.1 2.1 0.2 0.2 0.0 0.2 0.0 0.0

Gangu Bhil Ji Dhani 1.2 0.1 2.1 0.3 0.2 0.0 0.2 0.0 0.0

Salar Ji Dhani 1.0 0.1 1.8 0.2 0.1 0.0 0.1 0.0 0.0

Jadhe Dhani 6.1 2.6 10.8 4.6 0.9 0.4 0.9 0.4 0.1

Murad Dhani 5.2 2.1 9.3 3.8 0.7 0.3 0.7 0.3 0.1

Mithe Ji Wand 2.5 0.8 4.5 1.5 0.4 0.1 0.4 0.1 0.0

Saleh Jhanihi 2.2 0.4 3.9 0.6 0.3 0.1 0.3 0.1 0.0

Bakhato Dhani 2.3 0.3 4.1 0.6 0.3 0.0 0.3 0.0 0.0

Bhitro Bhill 0.6 0.1 1.0 0.2 0.1 0.0 0.1 0.0 0.0

Munhan Tar 0.8 0.1 1.3 0.2 0.1 0.0 0.1 0.0 0.0

Mehun Linju 0.5 0.1 0.9 0.1 0.1 0.0 0.1 0.0 0.0

Mangu Bheel 0.4 0.1 0.7 0.1 0.1 0.0 0.1 0.0 0.0

Ramnia Bhil 0.3 0.1 0.5 0.1 0.0 0.0 0.0 0.0 0.0

Singharo 2.7 0.4 4.8 0.7 0.4 0.1 0.4 0.1 0.0

Bhilan Jo Goth 2.0 0.3 3.5 0.6 0.3 0.0 0.3 0.0 0.0

Aban Jo Tar 0.5 0.1 0.8 0.1 0.1 0.0 0.1 0.0 0.0

Achie Ji Dhani 2.2 0.7 3.9 1.3 0.3 0.1 0.3 0.1 0.0

Mangho Thakar Jo Tar 0.6 0.1 1.2 0.2 0.1 0.0 0.1 0.0 0.0

Pakistan SEQS 80 40 120 80 500 360 150 40 75

Note: Pakistan SEQS – Government of Sindh Environmental Quality Standards. Where values are below 0.0, the predicted modelled process contribution is between 0.0 and 0.5 µg/m3


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Table 44: Scenario 2 - Worst case 24 Hour meteorological conditions

Rank 2009 2010 2011 2012 2013

1 13 June 20 May 21 August 07 June(a) 31 May

2 12 May 21 June 12 June 04 August 19 June

3 07 July 22 May 28 April 05 March 08 June

4 21 June(a) 03 May 08 June 07 June(a) 16 May(a)

5 21 June(a) 02 May 07 July 05 July 24 June

6 13 July(a) 19 July(a) 19 June 11 June 16 May(a)

7 13 July(a) 19 July(a) 19 July 19 August 14 May

Note: (a) Where dates occur twice the worst case result is occurring on the same day over multiple receptors. Bold text indicates consecutive days


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7.5.2.3 Transboundary impacts

The Project is located approximately 60km east of the Pakistan and India border. As noted in

section 7.5.2, the largest predicted impacts from the Project occur approximately 3km north east

of the Project site. As demonstrated by the contours plots, presented in Figure 16 to Figure 21,

the process contributions from the Project drop off rapidly with increasing distance from the area

of maximum impact. Over 60km, it is expected the emissions from the Project will be well mixed

in the atmosphere and are likely to be undetectable at the border with India beyond the current

ambient concentration. Therefore, there are no anticipated transboundary effects due to the

location of the Project in relation to other countries.

7.6 Mitigation and enhancement measures


The following mitigation measures (which are in accordance with international best practice) for

controlling air quality impacts will be incorporated into the construction phase:

● Minimising dust from material handling sources, such as conveyors and bins, by using

covers;

● Minimising dust from open sources, including storage piles, by using control measures such

as appropriate locations, installing enclosures and covers

● Dust suppression techniques should be implemented, such as applying water or non-toxic

chemicals to minimise dust from vehicle movements

● Manage emissions from mobile sources as per the EHS Guidelines for Air Emissions and

Ambient Air Quality including:

– Contractors are required to use modern, well-maintained vehicles that comply with

applicable emission limits

– Introduce and enforce a ‘no idling’ policy

– Regardless of the size or type of vehicle, fleet owners / operators should implement the

manufacturer recommended engine maintenance programs

– Drivers should stick to demarcated and levelled construction routes

– Minimise speeds on site to <20kph

– Drivers should be instructed on the benefits of driving practices that reduce both the risk

of accidents and fuel consumption, including measured acceleration and driving within

safe speed limits

● No open burning of solid waste

● Planning land clearing, removal of topsoil and excess materials, location of haul roads, tips

and stockpiles, and blasting with due consideration to meteorological factors (e.g.

precipitation, temperature, wind direction, and speed) and location of sensitive receptors. For

example,

– minimise groundworks during periods of high wind (e.g. >20kph)

– vegetating exposed surfaces of stockpiled materials

● Ensure grievance mechanism is in place so if air issues such as dust occur, communities

can report them to the Project Company


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7.6.2 Operation impacts

In order to minimise dust and particulate matter from the handling and storage of coal the

following measures should be applied:

● Use of cleaning devices for conveyor belts to minimise the generation of fugitive dust

● Use of enclosed conveyors with well designed, robust extraction and filtration equipment on

conveyor transfer points to prevent emission of dust

● Use of wind fences in open storage of coal or profiling

● Use of machinery to compact coal in the coal yard

● Frequent utilisation of (treated) waste water to suppress coal dust on coal yard

No combustion mitigation measures in addition to those already accounted for within the

dispersion modelling are proposed. The following key design features have been accounted for:

● Abatement methods included to enable the Project to meet the guaranteed emission limits,

which are lower than the SEQS emission limits presented in Table 21, include:

– Low NOx burners and staged air injection

– Limestone injection into the combustion chamber for desulphurisation

– Electrostatic precipitators with particulate removal efficiency not less than 99.85%

● An exhaust stack height of 210m to ensure effective dispersion of emissions.

Monitoring of emissions and ambient air quality should be undertaken during the operation

phase using the following methods:

● Installation of a continuous emission monitoring system (CEMS) to monitor stack emissions

of PM10, SOx and NOx

● Annual stack emissions testing of the metals regulated by the SEQS

● Ambient monitoring of pollutants consistent with the SEQS, using a minimum of two

continuous ambient monitoring systems to measure concentrations at a maximum

impact/sensitive receptor location and a representative background location.

7.7 Residual impacts


construction activities are not significant.

As a result of the Project’s operation, there will be increases in ground level concentrations of

NO2, SO2 and PM although these changes are small at modelled sensitive receptors. The

impacts from the Project are not significant when assessed against the relevant Pakistan SEQS.


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8 Greenhouse gas

8.1 Introduction

This chapter considers the potential greenhouse gases (GHG) associated with the construction

and operation of the Project. The key source of GHG emissions is from combustion of fuel.

Combustion GHG emissions are calculated as well as the emissions intensity (emissions of CO2

per unit of heat and electricity).


The Kyoto Protocol was ratified by Pakistan in 2005, which recognised the general

commitments of the Protocol. However, as a developing county, Pakistan was not given any

binding emissions targets.

Pakistan’s National Climate Change Policy17 was drafted in 2011 and adopted in 2013, in

response to Pakistan’s increasing vulnerability to adverse effects of climate change. Its goal

was to “to ensure that climate change is mainstreamed in the economically and socially

vulnerable sectors of the economy and to steer Pakistan towards climate-resilient development”.

The Framework for Implementation of Climate Change Policy18 was developed later in 2013 and

addresses the main sectors contributing to Pakistan’s economy. The energy sector is identified

as contributing over half (51%) to Pakistan’s overall GHG emissions. Actions are focused on:

● Developing renewable energy technologies

● Developing/obtaining clean coal technologies to achieve low carbon growth

● Reducing overall energy demand.

The Prime Minister’s Committee on Climate Change (PMCCC) is an overarching body that

oversees climate change related issues both globally and domestically and provides climate

change guidance.

Pakistan last provided data to the United Nations Framework Convention on Climate Change

(UNFCC) for a national carbon assessment in 1994; however, it has produced updates to its

GHG emissions data, most recently in 2012.

8.3 Guidelines and policies

Pakistan published an EIA guidance for coal fired power stations – National Impact Assessment

Programme (NIAP) which outlines how to assess GHG emissions for EIA purposes. The

guidance suggests that the EIA should determine whether the Project may significantly change

GHG emissions, and define the scope of any necessary GHG assessment. The key areas that

should be addressed are whether the proposed Project will emit GHGs, and to assess the

relevant emissions.

The NIAP refers to the World Banks’ Strategic Framework for Development and Climate

Change, which outlines the criteria that a coal power plant should meet to obtain traditional

financing from the IFC and Multilateral Investment Guarantee Agency (MIGA) for example.

17 http://www.lead.org.pk/cc/attachments/Resource_Center/NAP/pakistan.pdf 18http://www.pk.undp.org/content/dam/pakistan/docs/Environment%20&%20Climate%20Change/Framework%20for%20Implementation%

20of%20CC%20Policy.pdf


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IFC EHS guidelines for Thermal Power Plants state that energy efficiency measures should be

in place to maximise energy output from fossil fuels, were new plant should aim to be in the top-

quartile of performance for the country or region for the same type of fuel and power plant size.

However, the guidance also notes that local circumstances must be considered in determining

the appropriate technology choice. This analysis is presented in chapter 3 of this ESIA.

The guidelines also present typical emissions rates for new thermal power planta. Typical

values for a lignite CFB plant are <909 gCO2e/kWh. Note these values do not account for

differences in coal specifications across the world but provide indicative performance levels.


8.4.1 Overview

This section details the methodology used for quantifying emissions associated with the

operational phase of the Project. The methods adopted are consistent with the guidance set out

in section 8.3 for this type of project.

8.4.2 Temporal Scope

GHG emissions have been considered for a typical one-year operational period of 7,000 hours.

This is based on the projected annual fuel consumption and energy production of the plant.

8.4.3 Spatial Scope

The assessment identifies the major potential sources of GHG emissions as a result of the

operation and construction of the plant. These are presented in Table 45.

Table 45: Potential sources of GHG emissions associated with the Project

Emission source Type of Emission Quantified in assessment?

Construction

Combustion plant Indirect – Scope 3 Yes

Transmission line Indirect – Scope 3 Yes

Operation

Two main boilers Direct - combustion - Scope 1 Yes

Transport of fuel to site Indirect – Scope 3 No

Switchgear Direct - Fugitive - Scope 1 No

Emissions associated with the construction of this type of project are insignificant compared to

those released from operation over the life of the Project. Additionally, data from construction

sources was not available at the time of this study so an indicative calculation of these

emissions is undertaken using a default value from the World Bank of 2.9 kgCO2e/MWh19.

The main source of direct GHG emissions is the combustion of fuel in the boilers which is

mostly CO2 (30%). A small amount of N2O is also emitted. Emissions have been calculated

based on the fuel combusted, and presented as net emission rates based on the electricity

produced after the plant’s own consumption is accounted for.

There will be some losses of electricity through the transmissions system. This means that of

the total amount of electricity generated, some of it will not be consumed by customers and is a

function of how the transmission systems operate. Any emissions associated with these losses

19 http://documents.worldbank.org/curated/en/269221468178766476/pdf/903670WP0Box380HGGuidanceNoteEnergy.pdf


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have not been considered separately in this assessment and the data reflects ‘as generated’

values.

GHG emissions from fugitive emissions of sulphur hexafluoride (SF6) insulated switchgear

during normal operation are expected to be insignificant compared to the other sources of GHG

associated with the Project and have therefore not been considered further in this assessment.

The coal will be delivered from the mine stockpile to the site by conveyor belts, which will be

owned and operated by the Developer.

8.4.4 Calculation approach

For each of the sources above which are to be calculated, the activity or consumption data was

multiplied by a published emissions factor from a recognised source:

Emissions (tCO2e) = rate of activity (unit) x emission factor (tCO2e/unit)

For each source the activity data and emissions factor are selected on the best available Project

data and emissions factors.

Direct emissions from the combustion of coal have been calculated based on the estimated fuel

consumption and the coal specification of the plant. The specification expected to be used for

the Project estimates the carbon content of the coal (through ultimate analysis) to be 30.12%

(as received).

The total coal consumed in a given scenario is multiplied by the carbon content on the

conservative assumption that all carbon is consumed in the combustion process and that this

consumption is at the lower heating value. It is assumed the plant operates for 7,000 hours per

year.

8.4.5 Project data

Activity data for the power station has been taken from a number of sources. Table 46 outlines

the activity data for the Project and the source of that data.

Table 46: Project activity data- combustion

Parameter Unit Output

Number of units Number 2

Total electrical output MW 660

Net calorific value (LHV) kJ/kg 10,232

Net Heat Rate (LHV) kJ/kWh 8,705

Fuel carbon content % 30.1

Net power output- total GWh/y 4,300

Note: Carbon content based on Project performance coal specification

Source: Performance coal specification Project Mass Balance calculation

8.4.6 Determining significance

It is good practice in an ESIA to assess the significance of impacts with reference to the

magnitude of the impact and the sensitivity of the receptor. GHG emissions are global in nature

and it is difficult to link the emissions of a single project to a specific receptor, unlike other

environmental impacts. In addition, GHG emissions are closely related to economic growth. In

international agreements, such as the UNFCC and the Kyoto Protocol, developing countries are


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given scope to increase their emissions. This is unlike developed countries which have high

levels of emissions already and which are expected to reduce their emissions.

The relationship of individual project emissions to global atmospheric emission, and uncertainty

about the global atmospheric response, is very complex and means that determining the

significance of project emissions on a local scale is not possible. The relationship between

emissions from individual projects and national or international emissions reduction targets is

also difficult to resolve as national and international policies contain provisions for growth and

development.

There are currently no published guidelines for determining the significance of project

greenhouse gas emissions in ESIAs. However, the guidance notes for the IFC PS3 suggest the

following criteria for evaluating project GHG emissions. This guidance does not recommend

how to assign significance to any of the impacts associated with a project, instead

recommending how to present the impacts. As such the methodology given in chapter 5 of this

ESIA does not apply to this GHG assessment.

Table 47: Suggested IFC criteria for assessing GHG emission impacts

IFC Criteria Comments

The project’s greenhouse gas emissions relative to the host country’s total national emissions

Discussed in the Residual Impacts Section (Section 8.8)

The project’s greenhouse gas emissions performance relative to good international performance or the host country’s national average performance

Discussed in the National Emissions Profile (Section 8.5.1)

The annual trend of the project’s greenhouse gas emissions performance over time

Discussed in the Impact Identification and Assessment (Section 8.6)

Opportunities to further improve the project’s greenhouse gas emissions performance.

Discussed in the Mitigation and Enhancement Measures section (section 8.7)

Source: Guidance Notes for IFC PS3

8.4.7 Baseline conditions methodology

Baseline data was collected via a desk review. The following principal sources were considered

in presenting the baseline assessment:

● World Resources Institute (WRI) – CAIT emissions data20

8.4.8 Assumptions and limitations

Wherever possible, Project specific data has been used in order to inform the assessment and

calculations.

Actual data on construction of the Project was not available at the time of this study, so an

assumption has been used based on the World Bank average for construction of power plants.

This is calculated based on the MWh generated over the Project lifetime of 30 years.

The combustion calculations were based on Project data for the heat and energy balances of

the plant, which document the fuel inputs and electricity generated. The coal specification for

the Project has also been used to calculate the GHG emissions per unit of coal consumed. This

is the coal that will typically be consumed at the site. It is stated in the Project Technical

Description that the plant would operate for 7,000 hours per year. Emissions are calculated

based on all of these sources of data and assumptions.

20 http://cait.wri.org/historical


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The actual emissions from the plant during operation would be based on how the plant

ultimately operates. There is therefore inherent uncertainty in what the actual GHG impact of the

Project might be. However the assessment has used a worse–case assumption in determining

the emissions by assuming that the plant would operate at the full loading of any given scenario

for 7,000 hours in a typical year which provides an upper limit on the total GHG emissions.


8.5.1 National emissions profile

Pakistan last reported its national GHG inventory in 2012, and these figures are published by

the WRI. This contains the latest available data on emissions by sector and is shown in Table

48 below.

Pakistan’s Kyoto Protocol submissions were last reported in 2003 to the UNFCCC, and only

covered emissions for 1994.

Table 48: Pakistan National GHG emissions by sector (MtCO2e)

Sector 1996 2000 2004 2008 2012

Energy 99 114 135 155 159

Industrial Processes 5 5 8 16 16

Agriculture 91 101 110 129 140

Waste 5 6 6 6 7

Bunker Fuels 0.4 0.5 0.7 1 1

Total net emissions 199 224 260 306 320

Source: World Resources Institute21

The data shows that between 1996 and 2012, total GHG emissions in Pakistan have increased

by approximately 121 MtCO2e, or 38%.

The National Economic and Environmental Development Study (NEEDS)22 for Pakistan predicts

that energy sector emissions will grow to 2730 MtCO2e by 2030, or from 50% of total emissions

to around 64%. Data on future emissions projections is not available for all sectors.

The grid average emission intensity for Pakistan is 416 kgCO2e/MWh23. This value is lower than

the expected emissions intensity of the Project. However, the grid average for Pakistan contains

hydro power stations which account for around a third of the electricity supply and have an

emissions factor of zero. If the grid average factor is adjusted to account for this, it would be

approximately 624 kgCO2e/MWh. This scenario contains oil and gas powered plants which have

a lower emissions value than coal.

21 http://cait.wri.org/historical/Country%20GHG%20Emissions?indicator[]=Total GHG Emissions Excluding Land-Use Change and

Forestry&indicator[]=Energy&indicator[]=Industrial Processes&indicator[]=Agriculture&indicator[]=Waste&indicator[]=Bunker Fuels&year[]=1996&year[]=1997&year[]=1998&year[]=1999&year[]=2000&year[]=2001&year[]=2002&year[]=2003&year[]=2004&year[]=2005&year[]=2006&year[]=2007&year[]=2008&year[]=2009&year[]=2010&year[]=2011&year[]=2012&country[]=Pakistan&sortIdx=NaN&sortDir=desc&chartType=geo

22 https://unfccc.int/files/adaptation/application/pdf/pakistanneeds.pdf 23 http://www.iea.org/publications/freepublications/publication/CO2EmissionsFromFuelCombustionHighlights2015.pdf


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The construction of the combustion plant site itself as well as the transmission line will lead to

indirect emissions of GHG through the use of materials, construction plant and construction

transport.

Emissions from these sources are considered ‘scope 3 (indirect)’ as the emissions do not occur

within the site boundary and are owned by others. For thermal power plants, the emissions

from these sources are generally considered to be small in comparison to the operational phase

combustion emissions.

The World Bank has provided an indicative emissions factor of 2.9 kgCO2e/MWh to be used as

a default value for embodied carbon in construction of power plants where actual data is not

available. Based on the expected amount of generation over 30 years, the construction

emissions are estimated to be around 370,000 tCO2e. Acknowledging the uncertainty in the

World Bank factor, the indirect emissions from construction are considered to be low in the

context of the operational lifetime of the power plant.

The key sources of emissions in the construction phase will include the use of concrete and

steel in all the major components of the Project, as well as impacts from the thermal power

components such as the boilers and ducting.

8.6.2 Operational impacts

This section presents the calculated GHG emissions for the operational phase based on the

approach and assumptions outlined in section 8.4.

These calculations are based on the input data presented in Table 46. Emissions associated

with the operational phase are presented in Table 49.

Table 49: Calculated emissions for the operational phase

Source Unit Output

Combustion emissions tCO2e 3,995,007

Electricity intensity (net) gCO2e/kWh 939

Total emissions from the plant are predicted to be approximately 4 MtCO2e in a typical year of

full-load operation. The emissions from the operation of the Project would represent a relatively

small part of national GHG emissions, at around 1% per year- assuming it is operating at full

load. Where the plant operates less than full load, annual emissions would be expected to be

lower. Emission intensity is predicted to be approximately 939gCO2e/kWh, which is around 4%

higher than the typical emissions rate for a subcritical CFBC power plant as presented in the

IFC Thermal Power Guidelines24 (>909gCO2e/kWh), and is above the prevailing grid-electricity

rate for Pakistan. As noted earlier, the IFC Thermal Power are indicative and do not take

specific account of regional variations.

24http://www.ifc.org/wps/wcm/connect/dfb6a60048855a21852cd76a6515bb18/FINAL_Thermal%2BPower.pdf?MOD=AJPERES&id=1323

162579734


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8.7.1 Construction phase

The construction phase will lead to potential indirect emissions due to the construction of the

Project and transmission line. These emissions will principally occur through the use of

materials and other products, from the transport of those materials and waste to and from the

site, and from the use of construction plant.

The following measures are suggested for implementation by the contractor in order to minimise

these sources of emissions as far as possible.

● Keep the carbon footprint of all new assets as small as possible to minimise the overall

amount of materials as far as possible.

● Use recycled materials in construction where possible, including reuse of materials won on-

site.

● Source construction materials from local area where possible to minimise the amount of

construction traffic movements, and consider whether certain items could be delivered by rail

rather than road.

● Establish sustainable construction management practices. This includes toolbox talks for

workers about switching off plant and equipment when not in use, and regular servicing of

plant and equipment.

8.7.2 Operational phase

An analysis of the Project alternatives is presented in chapter 3. This analysis identified the

following relevant to potential GHG emissions:

● There are alternative renewable technologies being explored in Pakistan, but there are

challenges to meeting an increasing energy demand and falling supply. Based on the

existing fuel supply in Pakistan, one of the key drivers for this Project is to provide stable

generation using an indigenous fuel source, reducing dependency on imported oil and gas.

● While the Project leads to GHG emissions, it will adopt CFB technology which offers higher

levels of efficiency compared to pulverised coal firing, consequently reducing GHG

emissions by a small amount.

One of the key factors in determining emissions for coal power plants is the coal quality. Less

high quality coal is required per unit of electricity generated compared to low-quality coals. The

plant should therefore aim to maintain the quality of the coal to ensure efficiency. In addition, the

plant should be well maintained in general terms to ensure it continues to run efficiently for its

whole life span.

8.8 Summary

The Project will lead to emissions of GHG, principally CO2 during the construction and operation

of the plant. These emissions mainly arise from the combustion of coal to produce electricity.

Indirect emissions from construction and the delivery of coal to the plant during operation are

very small in the overall context of the Project.

Like other thermal power technologies, during operation, the emissions from the Project would

represent a relatively small part of national GHG emissions, at around 1% per year- assuming it

is operating at full load. The emission rate is higher than the average for Pakistan at present

since the amount of coal generation is relatively low compared to oil and gas power generation


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and is around 4% above the typical rate of GHG emissions for a plant of this type. It is

recommended that measures are implemented to maintain operational efficiency and to keep

fuel quality as high as possible to limit the amount of GHG emissions.


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9 Noise and vibration

9.1 Introduction

This chapter presents an assessment of the potential environmental noise and vibration impacts

that are expected to arise during the construction, operation and decommissioning phases of

the Project. The purpose of the assessment is to identify potential impacts, sensitive receptors

likely to be affected and identify potential significant effects so that the scope to mitigate them

can be considered.


Temporary noise impacts are expected to arise during the construction phase due to:

● Site preparation works

● Excavation and foundation works

● Erection of steel structures and duct work

● Construction of buildings

● Delivery and installation of equipment.

Permanent noise impacts that are expected to arise during the operation of the Project include:

● Noise from turbine hall, stack, electrical substation

● Noise due to coal extraction and handling

● Noise due to ash disposal.

The key sensitive receptors are identified as:

● The settlement of Yusuf Ji Dhani at 0.9km to the west of the Project site

● Scattered settlements at more remote locations.

Noise and vibration impacts that have been scoped out of the assessment are:

● Vibration during construction and operation: Due to the distance between the site and the

closest receptors it is expected that vibration impacts during all phases of the Project will not

generate significant adverse effects at any receptors. It is assumed that blasting will not be

required.

● The Project is expected to be operational for 30 years. Decommissioning of the Project is

expected to comprise:

– End of life decommissioning works

– Temporary worksite decommissioning

– Existing infrastructure decommissioning.

The noise impacts associated with these works are likely to be similar in magnitude to those

generated during the construction phase but of shorter duration. Furthermore, it is expected that

the proximity of sensitive receptors to the Project during decommissioning will differ from those

described in the baseline. It is not meaningful to assess potential noise and vibration impacts so

far in advance as the requirements for mitigation cannot be adequately identified. Therefore, the

significance of effects due to noise and vibration during decommissioning has not been

assessed.


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9.2.1.1 EIA Guidance for Coal Fired Power Plants in Pakistan

The Government of Pakistan and the International Union for Conservation of Nature and Natural

Resources published EIA Guidance for Coal-Fired Power Plants in Pakistan25.

The guidance states: “Noise impacts should not exceed the levels represented in the Pakistani

NEQS…or result in a maximum increase in background levels of 3 dB at the nearest receptor

location off-site.”

NEQS have been replaced by the SEQS in Sindh Province as of 2014. The SEQS have been

reproduced in Table 50 and are applied in this assessment.

Table 50: SEQS for noise (2014)

Category of Area / Zone Daytime 06:00 to 22:00

dB LAeq

Night time 22:00 to 06:00

dB LAeq

Residential Area (A) 55 45

Commercial Area (B) 65 55

Industrial Area (C) 75 65

Silence Zone (D) 50 45

The guidance also states: ‘According to the Pakistani legislation, silence zones are zones that

are declared as such by the competent authority: an area comprising not less than 100m around

hospitals, educational institutions and courts. Note that mixed categories of areas may be

declared as one of the four above mentioned categories by the competent authority.’

The guidance states that where there are receptors within 500m of the Project then baseline

noise measurements should be made.

9.2.2 International requirements and guidance

9.2.2.1 World Bank Group / IFC Guidelines

The World Bank Group has developed a thorough programme of pollution prevention and

management to ensure that it funds projects which are environmentally and socially responsible.

These guidelines are adopted by many international funding agencies and banks. The IFC, a

member of the World Bank Group, has produced the EHS General Guidelines that apply to

investment projects in various industry sectors. The Guidelines note that “Noise impacts should

not exceed the levels presented in Table 1.7.1, or result in a maximum increase in background

levels of 3dB at the nearest receptor location off site”. Table 1.7.1 of the Guidelines is

reproduced in Table 51 overleaf.

25 Government of Pakistan and IUCN (2014). EIA Guidance for Coal Fired Power Plants in Pakistan.

http://cmsdata.iucn.org/downloads/niap___coal_fired_power_plants.pdf (accessed 19 August 2016)


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Table 51: IFC EHS noise level guidelines

Table 1.7.1 – Noise level guidelines*

One Hour LAeq (dBA)

Receptor Daytime 07:00 – 22:00 Nighttime 22:00 – 07:00

Residential; institutional; educational†

55 45

Industrial; commercial 70 70

* Guidelines values are for noise levels measured out of doors. Source: Guidelines for Community Noise, World Health Organization (WHO), 1999.

† For acceptable indoor noise levels for residential, institutional, and educational settings refer to WHO (1999).

9.2.2.2 World Health Organization

The World Health Organization (WHO) provides broad guidance on noise levels required to

protect individuals from harmful levels of noise within a range of environments, which is

described in ‘Guidelines for Community Noise (1999)’26. The guidelines are intended for the

long-term management of community noise to help meet the WHO’s core objective of “the

attainment by all peoples of the highest possible levels of health”.

This is an important reference which includes guideline noise values that are founded on the

results of scientific research into the effects of noise on the population. This forms the basis of

standards for noise used worldwide. The specific values that are considered appropriate to the

Project are given in Table 52.

Table 52: WHO Guideline values

Specific Environment Critical Health Effect(s) Guideline Noise Value

Outdoor living area Serious annoyance – daytime and evening

55 Leq,16 hours dB(A)

Dwellings – outside bedrooms (window open)

Sleep disturbance – night time 45 Leq,8 hours dB(A)

Industrial, commercial, shopping and traffic areas, indoors and outdoors

Hearing impairment 70 Leq,24 hours dB(A)

The Guidelines do not specify the hours of the day over which the time bases apply because

what is considered to be daytimes, evenings and night-times are expected to be dependent on

the social and cultural trends of a country and therefore vary around the world.

9.2.2.3 British Standard 5228 Code of Practice for Noise and Vibration Control on

Construction and Open Sites

British Standard 5228 ‘Code of Practice for Noise and Vibration Control on Construction and

Open Sites’ (2009+A1:2014) provides comprehensive guidance on construction noise and

vibration including details of typical noise levels associated with various items of plant or

activities, prediction methods and measures and procedures that have been found to be most

effective in reducing impacts. The guidance forms the basis for the majority of construction

noise assessments in the United Kingdom and is widely recognised internationally.

26 World Health Organization (1999). Guidelines for Community Noise.


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9.3.1 Overview

Noise and vibration impacts associated with the Project which can potentially result in effects to

sensitive receptors have been assigned significance using the impact evaluation matrix

presented in chapter 5. Under the impact evaluation, impacts of moderate and major magnitude

are considered significant impacts. Consequently, impacts evaluated as minor or negligible are

not significant.

9.3.2 Determining significance of impacts and effects

9.3.2.1 Sensitivity of receptor

The criteria for receptor sensitivity for noise and vibration are given in Table 53 to be compatible

with the SEQS.

Table 53: Criteria for determining receptor sensitivity

Sensitivity

High Silence zones (100 m around hospitals, educational institutions and courts)

Medium Residential area

Low Commercial area

Negligible Industrial area

9.3.2.2 Noise impacts during construction

The Example Method 2 – 5 dB(A) Change states: “Noise levels generated by site activities are

deemed to be potentially significant if the total noise (pre-construction ambient plus site noise)

exceeds the pre-construction ambient noise by 5 dB or more, subject to lower cut-off values of

65 dB, 55 dB and 45 dB LAeq,T from site noise alone, for the daytime, evening and night-time

periods, respectively; and a duration of one month or more, unless works of a shorter duration

are likely to result in significant impact. These evaluative criteria are generally applicable to the

following resources:

● residential buildings

● hotels and hostels

● buildings in religious use

● buildings in educational use

● buildings in health and/or community use.”

The criteria for the magnitude of impact for noise from construction are given in Table 54 and

are based on BS 5228 guidance.


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Table 54: Criteria for determining magnitude of impact – construction noise


Noise from construction alone LAeq,T dB

Magnitude of impact

Threshold Negligible Minor Moderate Major

Daytime

T = 06:00 to 22:00

Night time

T = 22:00 to 06:00

High and medium

65 45 Threshold not exceeded

Threshold exceeded by less than 5 dB for any duration

Threshold exceeded by 5 dB or more for less than one month

Threshold exceeded by 5 dB or more for one month or more

9.3.2.3 Noise impacts during operation

With reference to the criteria of the SEQS the magnitude of impact due to operational noise are

given in Table 55. The application of this would also ensure compliance with IFC Performance

Standards (PS).

Table 55: Criteria for determining magnitude of impact – operational noise


Operational noise LAeq,1h dB

Magnitude of Impact

Threshold Negligible Minor Moderate Major

Daytime Night-time Ambient level increased by any

amount

Ambient level increased by less

than 3dB

Ambient level increased by 3dB or more

High 50 45 Threshold not exceeded

Threshold exceeded by less than 3 dB

Threshold exceeded by 3 dB or more

Medium 55 45

Low 65 55

Negligible 75 65


The main limitations of the assessment are identified as follows:

● Details on the construction programme, working methods and the inventory of plant to be

used (type and quantity in each stage of work) are indicative at this stage. An inventory and

reference noise emission values have been assumed and stated in order to provide a

preliminary assessment of the potential impacts

● The hours of working during construction phase are not certain at this stage. For the purpose

of this noise assessment we have considered a worst case scenario of 24 hours a day,

seven days a week which will require three shifts and include night time construction works

● Noise emission details for specific items of operational plant are not available at this stage

● Details of road traffic associated with the Project during the construction and operational

phases are limited to a high level review of options at this stage.


Baseline noise measurements were undertaken by SGS on behalf of Mott MacDonald as part of

air quality monitoring for the Project27. Measurements were made in three positions between 6

and 11 June 2016. The results are summarised in Table 56.

27 SGS (2016). Ambient Air Quality Monitoring Report. Mott MacDonald Pakistan (Pvt.) Limited, Thar, Sindh. SGS Report No. 204/2016.


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Table 56: Summary of baseline noise levels measured by SGS in June 2016

Measured noise level dB(A)

Position Location of baseline noise measurement and position relative to the proposed Block VI site

06:00 to 22:00 22:00 to 06:00

1 Singharo ~ 6.4km to the south 49.4 41.5

2 Achle Ji Dhani ~5.6km to the north-east 51.3 41.4

3 Salar Ji Dhani at ~2.2km to the north 48.0 40.6



9.5.1.1 Overview

Construction is expected to take around 40 months to complete followed by a 6-week period of

commissioning before full commercial operation can begin. The main activities are as follows:

● Site preparation

● Excavation and foundation works

● Erection of steel structures and duct work

● Construction of buildings

● Delivery and installation of equipment and components.

9.5.1.2 Assessment of noise impacts during construction

Construction noise impacts will mainly be associated with operation of static and mobile items of

plant. The inventory of plant to be brought to site is not certain at this stage; however, a

representative list of items has been compiled in Table 57 with reference to BS 5228 –

1:2009+A1:2014 in order to assign reference noise levels for the calculation of noise impacts.

Table 57: Main items of noise emitting plant expected to be used during construction and reference noise levels for the prediction of impacts

Activity Main items of noise emitting plant

Reference noise level of a single item operating

continuously LAeq,10 metres dB

Site preparation Tracked excavator 78

Dozer 81

Dozer towing roller 81

Water pump 65

Dump truck 74

Excavation and foundation works Sheet steel piling – vibratory piling rig

88

Craneage for piling 67

Concrete mixer truck 80

Tracked excavator 78

Erection of steel structures and duct work

Tower crane 77

Generator for welder 57

Hand held welder 73

Angle grinder 80

Tracked mobile crane 71


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Activity Main items of noise emitting plant

Reference noise level of a single item operating

continuously LAeq,10 metres dB

Construction of buildings Tower crane 77

Tracked mobile crane 71

Diesel scissor lift 78

Delivery and installation of equipment and components

Lorry pulling up 70

Wheeled mobile crane 70

Telescopic chandler 79

The methodology for the calculation of noise impacts presented in BS 5228 – 1:2009+A1:2014

has been used to predict the level of noise during each of the five main activities within the

construction programme. The attenuation of sound between the Project site and the sensitive

receptors is assumed to be without the application of corrections given in BS 5228 –

1:2009+A1:2014 for attenuation due to ground absorption or any screening attenuation.

Therefore, the worst-case noise impacts are considered. Table 58 presents a summary of the

noise impacts during each stage based on the groups of plant operating shown within the

inventory of plant above.

Table 58: Summary of calculated noise impacts at key receptors during the construction phase

Sensitive receptors

Yusuf Ji Dhani Salar Ji Dhani Achle Ji Dhani

Distance from the Project site in metres 900 2,200 5,600

Activity Calculated noise level from construction alone dB LAeq

Calculated overall noise levels during site preparation works

46 39 30

Calculated overall noise levels during excavation and foundation works

50 42 34

Calculated overall noise levels during the erection of steel structures and duct work

44 36 28

Calculated overall noise levels during the construction of buildings

42 34 26

Calculated overall noise levels during delivery and installation of equipment

41 33 25

The highest received noise levels from construction works are predicted to be during the

excavation and foundation works. The received noise levels from the works alone are calculated

to be up to 50 dB LAeq free field at the closest receptor Yusuf Ji Dhani. In all cases, the lower

cut-off value of 65 dB(A) for daytime is not expected to be exceeded. However, the 45 dB(A)

cut-off value for night time is shown to be exceeded at the closest receptor. Table 59 presents

an assessment of the worst case noise impacts of during works with reference to pre-

construction noise levels for the scenario that works may be undertaken during the daytime or

night-time periods.


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Table 59: Assessment of noise impacts from the noisiest phase of construction works – daytime and night time


Noisiest phase of work Excavation and foundation works

Excavation and foundation works


Daytime works

Measured pre-construction ambient LAeq dB – daytime

48* 48 51.3

Calculated construction noise alone LAeq dB

50 42 34

Predicted ambient during construction LAeq dB – daytime

52.1 49.0 51.4

Change in ambient – daytime +4.1 +1.0 +0.1

Magnitude of impact for residential receptors – daytime

Negligible Negligible Negligible

Night time works

Measured pre-construction ambient LAeq dB – night time

40.6 40.6 41.4

Calculated construction noise alone LAeq dB

50 42 34

Predicted ambient during construction LAeq dB – night time

50.5 44.4 42.1

Change in ambient - night time

+9.9 +3.8 +0.7

Magnitude of impact for residential receptors – night time

Major adverse impact if night works generate

these levels of noise for one month or more

Negligible Negligible

* The baseline noise levels for Yusuf Ji Dhani are taken from those measured at Salar Ji Dhani on account that it is the closest of the three measurement positions used.

Table 60 presents an assessment of worst case construction noise impacts at Yusuf Ji Dhani in

the case that night works are undertaken in any phase and the duration works could be one

month or more.

The results show that the corresponding impacts at the Yusuf Ji Dhani sensitive receptor are

assessed as major adverse and therefore significant in the case that site preparation and

excavation and foundation work is undertaken during the night period and over a period of one

month or more.

At all other sensitive receptors, the impacts that are expected to arise due to noise impacts from

construction work are assessed as being rated as negligible and therefore not significant

during any phase and if works are carried out during the daytime or night time.


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Table 60: Assessment of noise impacts at Yusuf Ji Dhani during all phases of construction works if conducted at night time and duration of one month or more

Measured

pre-construction

ambient LAeq dB

Night time

Calculated constructio

n noise alone LAeq

dB

Predicted ambient

during construction

LAeq dB

Night time

Change in ambient

Night time dB

Magnitude of impact

Significance

Site preparation

40.6 46 47.1 +6.5 Major adverse if night works generate these noise levels for one month or more

Major adverse impact – Significant if night works generate these noise levels for one month or more


50 50.5 +9.9 Major adverse if night works generate these noise levels for one month or more

Major adverse impact – Significant if night works generate these noise levels for one month or more

Erection of steel structures and duct work

44 45.6 +5.0 Negligible Negligible – Not significant

Construction of buildings


Delivery and installation of equipment and components



9.5.2.1 Overview

The acoustic emissions of the individual items of plant to be installed are not sufficiently certain

at this stage. A comprehensive noise model of the proposed power plant will be developed at

detail design stage.

Mott MacDonald has conducted noise measurements over a range of distances from an

operating coal-fired power station with an output of 1,200MW, which is almost twice that of the

proposed Project.

The results of the measurements have been used to derive a noise characteristic as a function

of distance shown in Figure 21. The noise characteristic describes the overall, steady-state

noise impact of the power plant due to all the associated noise sources including turbines,

conveyors, stacks and fixed plant.


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Figure 21: Measured steady-state operational noise levels as a function of distance from a 1,200MW coal-fired power plant


The characteristic shown in Figure 21 has been used to estimate the noise levels received at

the closest receptors to the proposed plant. The closest sensitive receptor to the Project site is

at 900m which falls within the range of distances of measurements made to derive the

characteristic. Extrapolation is required to predict operational noise levels at more remote

receptors.

9.5.2.2 Assessment of noise impacts during power plant operation

Using the characteristic in Figure 21, the operational noise levels of the power plant are

predicted for each receptor and the change in ambient levels are also calculated. The results

are summarised in Table 61.

30

35

40

45

50

55

60

10 100 1000 10000

Me

as

ure

d L

Ae

q d

B

Distance from the centre of power plant (turbine hall) in metres


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Table 61: Assessment of noise impacts from power plant operation – daytime and night time


Distance from the Project site in metres

900 2,200 5,600

Daytime operational noise impacts

Measured pre-construction ambient LAeq dB – daytime

35.4 48 51.3

Predicted operational noise alone LAeq dB

42 39 35

Predicted ambient during operation LAeq dB – daytime

42.9 48.5 51.4

Change in ambient – daytime

7.5 0.5 0.1

Magnitude of impact for residential receptors – daytime


Night time operational noise impacts

Measured pre-construction ambient LAeq dB – night time

35.4 40.6 41.4

Predicted operational noise alone LAeq dB

42 39 35

Predicted ambient during operation LAeq dB – night time

42.9 42.9 42.3

Change in ambient - night time

7.5 2.3 0.9

Magnitude of impact for residential receptors – night time


* The baseline noise levels for Yusuf Ji Dhani are taken from those measured at Salar Ji Dhani on account that it is the closest of the three measurement positions used.

This shows that operational noise impacts due to the power plant are expected to be negligible

at all receptors. This is because the noise impact of the plant is below 45 dB(A) threshold at all

receptors. The corresponding impacts are assessed as not significant.


The assessment has identified that a risk of significant adverse effects is expected only at the

closest sensitive receptor to the Project site, Yusuf Ji Dhani residential area, due to worst case

noise impacts from construction (site clearance and excavation and foundation works stages)

and only if long–term works are carried out during the night-time. This can be avoided by limiting

the noisy works to the daytime periods only. Where night works are found to be necessary, this

should be limited to short periods (less than one month) and affected residents should be given

prior notice of the reason for, nature and duration of works.


The residual impacts are not expected to result in significant impacts provided noisy night time

construction works are avoided or kept to short–periods with prior notice given to the residents

of Yusuf Ji Dhani. Residual impacts are therefore assessed as not significant.


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10 Waste and materials

10.1 Introduction

This chapter outlines the proposed approach for managing the key solid waste streams likely to

arise during the construction, operation and decommissioning phases of the Project.

Waste management is a key aspect to be assessed by the Project in order to achieve

minimisation of raw material consumption, maximise opportunities for waste reuse and recycling

and ensure that any final treatment or disposal of wastes generated by the Project is conducted

in an environmentally sound manner, particularly for hazardous wastes, in line with international

standards and local regulations.

Specific details related to the management of hazardous raw materials from a health, safety and

environment perspective are also presented in this chapter given the similarities between their

management and the management of waste/hazardous waste. The objective of hazardous

materials management is to avoid their use or, when avoidance is not feasible, minimise

uncontrolled release of hazardous materials or accidents (including explosion and fire) during

their handling, storage and use.

The scope of this chapter is limited to material usage and all solid wastes and those liquid

wastes that are not treated via the onsite waste water treatment works.



10.2.1.1 Sindh Environmental Protection Act 2014

The SEP Act is applicable to a broad range of issues and extends to the handling of hazardous

wastes.

Under the SEP Act 2014, SEPA is an autonomous agency. For administrative purposes, it is

part of the Forest, Environment and Wildlife Department of the Government of Sindh and they

have the following management authority:

● Issue license for handling of hazardous substance

● Assist governments agencies in implementation of waste management schemes

● Review and approve mitigation plans and give guidance for clean-up operations

● Discharge of waste is prohibited based on Section 11 of SEP Act. Currently there is no

SEQS specific to solid waste.

10.2.1.2 Hazardous Wastes

Currently, there is no clear regulatory guidance or requirement pertaining to the disposal of

hazardous waste; however, PEPA drafted the “Hazardous Waste and Hazardous Substance

Rules” under section 13 and 14 of PEPA 199728. These rules are still referred to by SEPA and

regulate the handling, manufacture, storage and import of hazardous waste and hazardous

substances. Additionally, section 13 prohibits import of substances that might be chemically

28 http://environment.gov.pk/information-services/


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toxic, explosive, flammable, corrosive, radioactive and that have an adverse environmental

impact.

10.2.2 International requirements

In the absence of robust waste management practices in Sindh Province, the Developer will

follow GIIP identified by the IFC PS for waste management and minimisation and the European

Waste Catalogue (EWC) for segregation, handling and storage of hazardous wastes.

10.2.2.1 IFC PS (2012)

IFC PS3 on Resource Efficiency and Pollution Prevention requires reference to be made to the

relevant EHS Guidelines; these are technical reference documents with general and industry-

specific examples of GIIP. The EHS Guidelines contain the performance levels and measures

that are normally acceptable and applicable to projects.

The underlying principle of IFC PS3 is the minimisation and avoidance of pollution in the first

instance. In the context of waste management this means employing strategies and

implementing measures which avoid waste generation.

The following IFC EHS Guidelines contain relevant information related to all waste management

and hazardous materials management for the proposed Project:

● IFC EHS Guidelines for Thermal Power Plants (2008)

● IFC General EHS Guidelines (2007)

The IFC EHS Guidelines for Thermal Power Plants state that large volume coal combustion

wastes (CCW) can include fly ash, bottom ash and boiler slag. Low volume wastes from coal

fired power plants typically include also the wastewater treatment sludges.

An adequate waste management plan (WMP) should establish a clear strategy for solid wastes

that will be generated including options for waste elimination, reduction or recycling or treatment

and disposal, before any wastes are generated. A Project specific WMP documenting the waste

strategy, storage (including facilities and locations) and handling procedures should be

developed and should include a clear waste tracking mechanism to track waste consignments

from the originating location to the final waste treatment and disposal location

The IFC EHS Guidelines for Thermal Power Plants give recommendations and methods for the

prevention, minimisation and control to reduce the volume of solid wastes from thermal power

plants. These are best practice guidelines and should be followed in the development and

operation of all new plants.

In addition, IFC PS3 requires the Project to implement technically and financially feasible

measures for improving efficiency in the consumption of material. This applies across all Project

phases.

All three documents have been used to frame the materials usage and waste management

approach for the proposed Project and to assess the Project’s ability to meet GIIP.

10.2.2.2 European Waste Catalogue

In the absence of a national waste classification system, the EWC should be used during the

construction/installation, operation and decommissioning of the Project. The EWC classifies

waste materials and categorises them according to what they are and how they were produced.

Reference is made to this when describing the appropriate handling and storage methods

because of the absence of national legislation for waste classification.


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The assessment of impacts from waste generation has been conducted on the basis of a desk-

based review of Project information provided by the Project parties.

Waste impacts associated with the Project have been assigned significance using the

overarching framework presented in Chapter 5 of this ESIA report. Specific magnitude criteria

for waste impacts are presented in Table 62 and the sensitivity of receptors considered by the

assessment are described in Table 63. The overall impact evaluation matrix presented in

chapter 5 is used to determine significance.

Table 62: Criteria for determining magnitude

Category Description/examples

Major Mismanagement of waste generated and/or raw materials results in a significant incident which potentially causes a fundamental change to the specific environmental conditions assessed resulting in long term or permanent change. Impacts are typically widespread in nature (regional, national and international) and would require major intervention to return to baseline conditions.

Moderate Mismanagement of waste generated and/or raw materials results in an incident that potentially causes a detectable change to the specific environmental conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Mismanagement of waste generated and/or raw materials results in an incident that potentially causes a detectable but minor change to the specific environmental conditions assessed.

Negligible Mismanagement of waste generated and/or raw materials results in an incident that potentially causes no perceptible change to the specific environmental conditions assessed.

Table 63: Criteria for determining receptor sensitivity

Category Description/examples

High Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with little or no capacity to absorb proposed changes or has minimal opportunities for mitigation.

Medium Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with limited capacity to absorb proposed changes or has limited opportunities for mitigation.

Low Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with some capacity to absorb proposed changes or has moderate opportunities for mitigation.

Negligible Waste and/or raw materials handling related incident impacts on a vulnerable receptor (human or ecological) with good capacity to absorb proposed changes or/and has good opportunities for mitigation.

There is a range of impacts which can occur from the mismanagement of waste arising from

construction/installation, operation and decommissioning of the power plant. A waste and

materials handling impact assessment is primarily about identifying waste streams and adopting

the appropriate best practice management approach, which seeks to avoid generation of waste

in the first instance, rather than assessing and mitigating impacts. The sensitivity and magnitude

approach has been adopted in order to demonstrate the different expected outcomes and

impacts associated with waste generated in the non-management/management strategy

scenarios. After identifying the potential sources and, where possible, quantifying waste

generated, the assessment focuses on measures to eliminate, reduce, reuse and recycle, as

well as solutions available for waste disposal.


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Baseline information for this assessment has been collected through a desk-based review of the

Project area, utilising existing environmental and social reports prepared for the Thar Coalfields

and online secondary sources.



The temporal scope covers the potential impacts related to the consumption of raw materials

(including receipt, handling and storage) and subsequent management and disposal of waste

arising from the construction, operation and decommissioning phases of the Project.


In terms of considering the consumption of raw materials (including receipt, handling and

storage) and subsequent management and disposal of waste, the spatial scope of the Project

encompasses the proposed Project site, including the temporary construction laydown area and

ash disposal facility and a Project landfill to be established.


All generated and/or managed hazardous and non-hazardous materials and waste streams

presented in this chapter are based on current documents available for the Project. They are

subject to change once the exact construction methodology is determined.

As discussed in Section 10.4.3, the principal materials for construction have been identified and

include earthen materials, cement and steel; although, the exact quantities of each material

have not yet been calculated. Similarly, there are a number of other materials, including

lubricants, paints, plastics and timber that will also be procured directly by the EPC contractor;

at this stage the exact quantities of these materials required for the Project are not known;

detailed plans and procedures will be produced to include this information.

As discussed in 10.4.6.1, there are no approved landfill sites in close proximity to the Project

and licensed waste carriers are not available in the Project area.

The principal waste streams have been identified and therefore the waste management

protocols and philosophy presented in Section 10.6 of this chapter would not be expected to

change significantly as a result of potentially minor modifications to the actual waste streams

and quantities which are ultimately generated as a result of the Project.


10.4.1 Overview

This section presents the baseline characterisation of the Project area’s materials use and

waste management procedures, to enable comparison of the current situation with changes

anticipated to the identified social and environmental receptors as a result of the Project.

The Government of Pakistan has taken some action to improve their solid waste management

system. In 2005 PEPA introduced a draft Guidelines for Solid Waste Management29 and the

following year a National Sanitation Policy was announced by the Federal Government which

29 http://www.environment.gov.pk/EA-GLines/SWMGLinesDraft.pdf


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focuses on recycling, reduction and reuse of waste. No regional Sindh policy has been provided

to date. Based on these guidelines it is the local municipality’s responsibility to collect and

dispose of the generated waste. The government has been proactive in addressing the

challenges presented with the disposal of solid waste; there is currently no appropriate

management system in Pakistan and uncollected waste causes serious health problems by, for

example, providing breeding habitats for mosquitos that create risks of malaria and cholera.

The main issues regarding waste management in Pakistan are as follows:

● There is no formalised/controlled waste collection system outside of major cities

● Wastes are not segregated at collection

● There are few controlled landfill sites

● There is a limited overall waste management strategy, particularly with regards to the

recycling of waste

Traditionally wastes are not segregated and much of waste generated does not actually reach

landfill sites. In rural areas, greater segregation and reuse take place to maximise limited

resources.

The Province of Sindh, where the Thar Coalfield is located, is one of the provinces of Pakistan

with the largest population. Sindh Local Government Ordinance 2001 gives the responsibility of

solid waste collection and transfer to the Taluka Municipal Administration; responsibility for

treatment and disposal of solid waste is given to the City District Government Karachi (Rahman,

2013). Overall, the Sindh Province governing authorities have limited human resources,

financial resources or the machinery or technology to properly manage waste.

There is no disposal site and treatment facility for hazardous waste in Pakistan and most solid

waste is delivered to disposal areas with no classifications.

10.4.2 Materials use

The principal materials that are expected to be required/consumed as part of the construction

specific components of the Project are summarised in Table 64. This information is based on

current designs of the Project.

Material for site profiling will be sourced from the spoil generated by the mine excavations. It is

likely that cement will be sourced locally in Pakistan and steel will be sourced from China. Key

plant items will be sourced from China and transported by ship to the Port of Karachi, where

they will be unloaded and transported by heavy goods vehicles (HGV) to the Project site.

There will also be a number of other materials required/consumed during the construction of the

plant, including: lubricants, oils, fuel (diesel), paint, plastics, packaging materials (paper,

cardboard, timber) and food; the exact quantities of these materials are also not yet known.


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Table 64: Primary construction materials

Work Item Earthen Material (m3)

Steel (tons) Concrete (m3)

Comments

Generation Units

3,500 6,950 13,500

Stack 0 830 6,921 Based on Stack Height of 210m

Coal storage 500 39 4,181

Cooling towers 65,100 36 31,000

Waste water treatment facility

26,000 7 5,000

Site profiling 200,000 - -

TOTAL 295,100 7,862 60,602

Table 65 covers the activity and type of materials which are expected to be used during

operations. Within this table the materials considered to be of a hazardous nature are

highlighted, these will require bespoke consideration, particularly any final treatment or disposal

options. Some materials will have a known consumption and storage volume, whereas the

consumption and volume of other materials will be dependent on routine maintenance and

outage activities therefore it is difficult to give exact volumes for all materials.

During detailed engineering design stage, a detailed materials handling and storage plan will be

developed in accordance with the EPC contractors estimated material volumes for both

construction and operations and suitable materials storage facilities will be provided.


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Table 65: Materials and chemicals used during operations30

Material Activity Type Storage capacity

Coal fuel (270.6 t/h for each boiler)

Combustion Unit Non-hazardous 65,000 tonnes

Limestone (22.6 t/h for each boiler)

Combustion Unit Non-hazardous

Sand Combustion Unit Non-hazardous

Diesel fuel

Boiler start-up burners, auxiliary boiler, emergency diesel generator(s), diesel fire water pump

Site vehicles

Hazardous x2 overground oil storage tanks with a total volume of 800m3

Hydrochloric acid (HCl)

Water treatment / steam cycle Hazardous 420kg

Sodium hydroxide (Caustic Soda) (NaOH)

Water treatment Hazardous 250kg

Cement and concrete

Maintenance and outage activities Non-hazardous Minimal

Paints, oils and fuels, lubricants, cleaners, solvents

Maintenance and outage activities Hazardous Minimal

Ferrous and non-ferrous metals


Fluorescent tubes


Batteries


Wood and timber


Plastic


Glass


Paper and cardboard


10.4.3 Material storage

A number of materials storage facilities will be provided for the construction of the Project, which

includes:

30 Storage capacities to be defined in the operational site waste management plan


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● Storage facilities for cement, steel and other bulk construction materials

● Hazardous materials including oils and chemicals

● Dedicated fuel delivery, storage and handling area of fuel

● Covered and uncovered storage areas for general construction materials

10.4.4 Ash disposal

Through the coal combustion process both bottom ash and fly ash will be generated as

residuals and will be disposed of through the ash handling system. Information on the average

approximate production quantities are provided in section 10.5.3.3.

The Developer will be responsible for the transportation and disposal of ash, which is expected

to be located at the Block VI mine site. The ESIA will identify whether there are other pre-

existing appropriate ash disposal areas. Discussions with the Developer and relevant

stakeholders will be undertaken to ascertain whether there is a potential for commercial use for

the fly ash (eg cement manufacturing) and bottom ash (eg road construction) within Pakistan.

10.4.5 In-pit and out-of-pit dumps

Based on the choice of mining method there will be an in-pit dump with maximum waste dump

height of 205m and berm width of 18m, and an out-of-pit dump with maximum waste dump

height of 120m and berm width of 30m. The earthen material will be stripped and transferred to

the in-pit dump by an excavator or to the out-of-pit dump by trucks. The out-of-pit dump will

receive waste material that does not fit in the in-pit dump space.

The most significant waste stream (in terms of volume), which will be generated as a result of

the construction phase of the Project is spoil due to excavation of the Project area during the

site preparation and construction phases. It is expected that a substantial amount of earthen

materials will be used to raise the level of the Project site, including the development of

foundations for the boilers and steam turbine generator. A spoil management plan will need to

be developed to ensure that the pits are appropriately managed including control of slope

stability and control of erosion.

During detailed engineering design stage, detailed estimated material volumes for both

construction and operations will be provided.

10.4.6 Solid waste

Wastes will be generated during both the construction and operational phases of the Project

and will likely include solid, liquid, hazardous, non-hazardous, and inert wastes.

Potential hazardous waste types generated during the construction and operational phases

across the Project may include: waste oils and solvents, lubricants, and contaminated soils

(potentially from leakage and spillage).

For the purposes of the construction phase it is envisaged that there will be the following Project

staff quarters/facilities and maintenance/construction areas which will result in the generation of

waste:

● Construction worker camp

● Site offices and other site facilities, which will include a concrete batching plant and mixing

plant and main stores

Considering the proposed facilities and construction works, the following waste streams are

expected to be generated as part of the construction phase:


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● Excavation spoil associated with site levelling and site profiling activities

● Concrete and concrete washings from concrete batching plants required for the construction

of the plant

● Iron and steel scrap

● Non-ferrous scrap

● Waste oil and lubricants from turbine installation and vehicle maintenance/repair

● Oil contaminated cloths from turbine installation and vehicle maintenance/repair

● Oily debris from shop sumps and spill clean-ups

● Packaging and pallets from deliveries

● Domestic waste, including glass, plastics, paper and cardboard

● Batteries

● Fluorescent tubes

● Organic household waste

● Paints and chemicals

● Tyres

● Medical waste (arising from medical facilities at the construction worker camp)

10.4.6.1 Hazardous and non-hazardous wastes

Table 66 presents the hazardous and non-hazardous wastes that are likely to be produced on

site during both the construction and operation phases of the Project. The quantities of these

hazardous waste materials are not anticipated to be high; as part of the site waste management

plan (SWMP) an estimate of waste materials to be produced will be calculated based on

assessment of the materials requirements.

There are two general classifications of wastes namely non-hazardous wastes and hazardous

wastes. Each waste stream has been identified as belonging to one of the following

classifications:

● Non-hazardous wastes are wastes that include but are not limited to concrete, glass, wood,

common garbage, office wastes, construction wastes that are not burnable such as boxes

● Hazardous wastes are materials classified as exhibiting characteristics such as explosive,

flammable, spontaneous combustion potential, oxidising potential or corrosive


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Table 66: Predicted hazardous and non-hazardous waste streams

Hazardous Non-hazardous

Oils and lubricants and contaminated cloths

Fly ash and bottom ash Excavation spoil Paper and cardboard

Oily debris from workshop sumps/spill clean-ups

Concrete Timber General domestic waste

Batteries Concrete washings Woody debris Organic household waste

Fluorescent tubes Iron and steel scrap Bricks and tiles

Paints and chemicals Non-ferrous scrap Pallets

Contaminated material Packaging Glass

Medical waste Plastics Tyres

There are no approved landfill sites in close proximity to the Project. It is the intention of the

Developer to construct and operate a landfill site for the disposal of construction and municipal

waste, which is engineered with an impervious protective membrane (as a minimum for

hazardous waste), and a support layer of clay which will utilised form the mine overburden and

readily available within Block VI, to prevent ground contamination. Construction of the landfill

site must be undertaken in accordance with national legislation and permitting requirements.

The landfill site shall be equipped with a leachate collection/processing area.

Disposal of any medical waste must be undertaken at licensed facilities. The EPC contractor will

be required to identify suitable sites with adequate medical waste disposal facilities (ie hospital

incinerators); details will be provided in the SWMP. Licensed waste carriers are not available in

the Project area; therefore it will be responsibility of the Developer and the EPC contractor

handle and transport medical waste.

Regarding the recycling of non-contaminated waste material (ie paper, glass, metals and

plastics) and in the absence of registered waste contractors, a local community recycling

program could be put in place to take materials from the EPC contractor. These materials could

be used locally or transported to Karachi for recycling.

10.4.7 Liquid waste

Liquid waste will be generated from the acid cleaning of the waste heat boiler every 3 to 5 years

and will be discharged to the outdoor waste liquid pond.


10.5.1 Introduction

This section presents the identification and assessment of the potential adverse impacts from

materials and waste during the Project’s construction and operational phases.

The following sections discuss the potential environmental impact and proposed

handling/storage and disposal methods for each of the materials and waste streams, which may

arise during the two phases of the Project. Measures to mitigate the likely adverse impacts and

enhance the beneficial impacts of the Project are presented in Section 10.6.


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10.5.2.1 Overview

This section aims to characterise the raw materials to be consumed and the waste streams

which are envisaged to arise from construction activities associated with the development of the

Project. The same types of wastes and material are anticipated to be generated/used during

decommissioning phase and are also addressed here.

10.5.2.2 Material use

The main materials that are expected to be required/consumed as part of the construction

phase will principally comprise the items of equipment for the Project, as well as materials used

for site preparation such as rods for piling and buildings, concrete for foundations and auxiliary

structures, steel for buildings and materials for fitting out the interiors of buildings.

There will also be a number of other materials (hazardous and non-hazardous) used during the

construction/installation of the Project, including: lubricants, oils, fuel (diesel), paint, plastics,

packaging materials (paper, cardboard, timber) and food among others. Smaller quantities of

other materials will be used throughout construction. Mitigation proposed to minimise the use of

materials is discussed in Section 10.6.

The principal potential impacts which can arise from the generation of waste from the

construction phase of the Project are as follows:

● Use of potentially finite and/or scarce resources

● Ineffective spoil/excavated material handling, storage and disposal causing contamination of

the environment

● Contamination of environments due to leakage and spillage of materials (such as fuel, oils

and chemicals) from poor materials handling and storage arrangements

● Occupational health and safety from exposure to hazardous materials

● Elevated dust levels and other emissions to air as a result of the operation of the concrete

batching plant at the construction site

● Embedded CO2 associated with the chemical process and heat input required for its

production

● Transportation of construction materials to site resulting in GHG emissions and nuisance

effects (noise and dust)

10.5.2.3 Waste generation

Table 67 summarises waste streams that are expected to be generated during the construction

phase of the Project as well as their potential impacts, how they will be handled/stored and the

method of disposal for each waste stream. Each waste stream has been identified as belonging

to one of the following classifications:

● Inert construction wastes are wastes that are solid and when disposed of are not expected to

undergo physical, chemical or biological changes to such an extent as to produce

substances that may cause an adverse impact. Such wastes include but are not limited to

excavated spoil, concrete, glass, ceramic materials, unpainted scrap metal, and dry timber or

wood that has not been chemically treated.

● Non-hazardous wastes are all wastes that are not hazardous wastes and are not inert

construction wastes. This includes common garbage, office wastes, construction wastes that

are burnable such as boxes, and treated sewage effluent and sewage sludge.


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● Waste materials are classified as hazardous wastes when they exhibit one or more of the

characteristics shown below or are hazardous by definition: explosive, flammable,

spontaneous combustion potential, oxidizing potential, toxic and corrosive.

Table 67: Construction wastes: Potential impact, proposed handling / storage and offsite disposal methods

No. Type of waste Source Potential unmitigated impacts

Mitigation and management

Non-Hazardous

1.1 Excavation spoil Associated with site preparation works and the excavation of the Project area

Contamination of receiving environments

Fugitive dust emissions

Disposal of spoil and excavation material which occupies large amounts of land

Visual amenity associated with disposal sites

Transportation resulting in GHG emissions and nuisance effects

Spoil disposal site- handling, transfer and disposal to be undertaken by EPC contractor in accordance with the procedure detailed in the framework SWMP (refer to Vol IV)

Development of in- pit and out-of-pit dumps and spoil management plan

1.2 Concrete Associated with the construction of the Plant

Fugitive dust emissions

Additional pressure on the use of existing landfill, where waste reuse or recovery is not feasible

Transporting waste materials from the Project site resulting in GHG emissions and nuisance effects

Waste concrete can be crushed and used as road material or fill, or where possible, buried in the proposed Project landfill site. Soils contaminated by cement can also be used as landfill cover.

1.3 Concrete washings Associated with the construction of the plant


Concrete wash water to be reused on site wherever possible.

On site concrete batching should include wash water recirculation.

Remaining wash water to be stored and allowed to evaporate.

Any remaining wash water to be fully treated (fine solids removed by filtration or settlement and pH corrected to 6-9) before being discharged into adjustment pool only if properly permitted (i.e. not to bare ground).

1.4 Iron and steel scrap

Non-ferrous scrap

Packaging

Plastics

Paper and Cardboard

Timber

Woody debris

Bricks and tiles

Pallets

Glass

Tyres

Associated with the construction of the Plant

The use of Project landfill, where waste reuse or recovery is not feasible

Visual amenity impacts associated with poor storage of waste

Transporting waste materials from the Project site resulting in GHG emissions and nuisance effects

Scrap metal will be sold for recycling, as appropriate.

1.5 General domestic waste

Kitchen and worker facilities

The use of landfill, where waste reuse or recovery is not feasible

Wastes to be segregated and opportunities will be identified for composting biodegradable waste


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No. Type of waste Source Potential unmitigated impacts

Mitigation and management


Windblown litter and potential odour and health risks by attracting vermin

If there are no licensed disposal sites31, segregation of recyclable waste and composting of the organic waste are recommended

Hazardous

1.6 Oils and lubricants and contaminated rags



Improper handling, storage, and collection of hazardous waste, where reuse, recovery recycling is not feasible

Recovery and re-use options to be fully explored. Where recovery and re-use is not feasible disposal of waste to the proposed Project landfill

1.7 Batteries

Fluorescent tubes

Paints and chemicals



Improper handling, storage, and collection of hazardous waste, where reuse, recovery recycling is not feasible

Handling, transfer and disposal to be undertaken by EPC contractor in accordance with the procedure detailed in the framework SWMP (refer to Vol IV)

1.8 Medical waste First aid and on-site medical facility


Health and safety: risk of infection and exposure to diseases

Further assessment required by the EPC contractor to identify suitable facilities for the disposal of medical waste

1.9 Contaminated material

Oily debris from worksite and spill clean-ups

Spills and leaks on site including accidental spillage and leakage of chemicals, fuels, oil and lubricant from on-site fuel storage tanks and equipment maintenance

Improper handling, storage, and collection of hazardous waste

Improper transportation of hazardous materials to the designated treatment/disposal facilities may pose a risk of contamination to the land, groundwater and surface water

To be disposed of to the proposed Project landfill

1.10 Used solvents Contamination of environments

Collected in bunded, segregated drums and suitably stored on a temporary basis within a waste management area.

Reuse solvents as far as possible or returning them to the supplier. All remaining solvents will be incinerated

The environmental impacts of generated wastes associated with the construction phase of the

Project will be short term and mostly reversible. These potential impacts will be effectively

managed through establishment of detailed waste management plans in line with the framework

waste management plan as outlined in the ESMP. The specific details of such waste

management plans will be prepared by the EPC contractor, the key elements of which are

summarised in Section 10.6.2.


10.5.3.1 Overview

The operation of a large-volume coal combustion plant will generate relatively large quantities of

waste, including fly ash; bottom ash and boiler slag. Within the Project these unavoidable waste

31 The EPC contractor will be responsible for identification of these companies and arranging to use their services and facilities.


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streams will be treated in recovery and / or abatement systems, recycled where possible, sold to

external users or in the last resort will be disposed of as waste.

10.5.3.2 Impacts from operational material use

Exact quantities of materials used during operations will depend on the optimised operating

regime of the Plant; the likely quantities of each key material have been presented in the

following sections.

The primary environmental impacts associated with material use during operations are:

● Contamination of environments due to leakage and spillage of materials (such as fuel, oils

and chemicals) from poor materials handling and storage arrangements

● Surplus materials requiring disposal ie out of date, excess to requirement, damaged

● Disposal of packaging waste

● Occupational health and safety from exposure to hazardous materials

● Transportation of materials to site resulting in GHG emissions and nuisance effects

Lignite

The main material used during the operation phase of the Project will be lignite. The Thar

Coalfield has one of the world’s largest lignite reserves with approximately 175 billion tonnes of

capacity. There will be an open pit near the centre of Block VI. The initial mine development and

production will be completed by truck and shovel due to lack of electrical power. Once full

production is achieved, crushed overburden and lignite will be transported by conveyors.

The coal from conveying system will be delivered to the boiler through the feeder at the top.

Coal storage will have four bunkers with the total volume of 625m3. There will be in total eight

coal feeders for one boiler.

There will be two coal storage yards for the Project, and the total capacity will be 65,000 tonnes.

It will provide sufficient coal for five days for two sets of boilers. Coal will be conveyed from the

storage area to a crusher and then onto the CFB boilers for combustion. To control fugitive

particulates, dust collection systems are provided at the coal transfer points. The coal storage

yard will be located at the northern point of the site. The coal stockpile height will be restricted to

a certain level (5-6m) to prevent dust issue in a strong wind environment.

Typical environmental impacts associated with coal are as follows:

● Contamination of receiving environments due to runoff associated with poor handling and

storage arrangements

● Fugitive emissions, such as dust associated with the handling and storage of the coal

● Visual amenity impacts associated with poor storage

Limestone

During operation, limestone will be used to reduce the levels of sulphur dioxide in flue gases

released via the stack. This will be achieved by injecting pulverised limestone into the CFB

boiler where it will react with the sulphur during combustion to form calcium sulphate. The

limestone demand will depend on the sulphur content of the coal and coal consumption.

The required quantities of limestone for the Plant are approximately 200,000 tonnes per annum

for one boiler. Limestone will be transported to site by trucks and stored in a limestone powder

silo, and will be transferred to the boiler by a covered pneumatic conveying system.


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Fugitive emissions, such as dust associated with the handling and storage of the limestone, are

considered to be the only likely environmental impact associated with limestone.

10.5.3.3 Waste management

It is expected that waste material will be generated as a result of routine maintenance and

equipment outages. The exact type and quantity of the waste arising will be dependent upon the

nature of those activities. Waste streams typically associated with a major outage for a coal fired

power plant are similar to those encountered during construction. Provision for the identification

of suitable management of these waste streams will be required prior to any significant outage

activities being carried out.

Waste streams that will arise during operation will include:

● Furnace bottom ash and fly ash

● Oily contaminated materials, such as oily rags

● Lubricating and auxiliary oils

● Trace contaminants in the fuel (introduced through the ash-handling wastewater discharges)

● Empty chemical containers

● Solvents, paints

● Spent filters and ion exchangers

● Delivery packaging

● Waste clean-up collected as a result of spills, leakages and/or accidental discharge

Fly ash and bottom ash

One of the most significant waste by-product streams which will be generated during the

operation of the Project will be bottom ash and fly ash. Together they are considered to be coal

combustion wastes, as defined by the IFC EHS Guidelines for Thermal Power Plants.

Table 68: Overview of the operational phase fly ash and bottom ash production amounts

Waste Average production

Bottom ash ~883 t/day (280,000 per annum)

Fly Ash ~1320 t/day (420,000 per annum)

TOTAL ~2,203 t/day (700,000 tonnes per annum)

Fly ash is the result of the combustion of coal and is ash which has become entrained in the flue

gases which emanate from the units. The Project will install ESPs which serve to remove fly ash

particles from the flue gases thereby lowering the particulate concentration prior to emission to

air via the exhaust stack. The dust will fall down into hoppers which collect the ash. Fly ash will

be collected from the hoppers and transported to the ash disposal area via trucks. There will be

two types of fly ash; dry and slurry type.

Bottom ash is produced from the non-combustible material that settles to the bottom of the

boiler and remains in the form of unconsolidated ash. Bottom ashes extracted from the boiler

are mainly agglomerated. Bottom ash will be disposed of with fly ash. Commercial uses for both

fly and bottom ash will be explored, such as block making.

Typical environmental impacts associated with ash production are the same as that associated

with coal but also includes the use of landfill, where waste re-use or recovery is not feasible,

which is a finite resource.

Discussion on the selection of a suitable site for the ash disposal site is provided in section 10.6.


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10.5.3.4 Summary

Table 69 presents the high-level waste handling strategy for the operational phase of the

Project. It includes the expected source of each waste stream, the potential environmental

impact which could occur, along with the expected disposal / final removal method.

Table 69: Overview of the operational phase waste handling strategy for the Project

Waste Source Potential environmental Impact

Disposal method

Bottom ash

Associated with routine and on-going maintenance in the facility and outages

Potential contamination of receiving environment

Fugitive emissions

Visual amenity impacts

Increased waste miles

Non hazardous

Collected, transported and disposed of to the ash disposal site to be located within the Block VI mine site within a lined area.

Options for commercial ash use to be periodically reviewed.

Fly ash



Fugitive emissions


Increased waste miles

Non hazardous

Collected, transported and disposed of to the ash disposal site to be located within the Block VI mine site within a lined area.

Options for commercial ash use to be periodically reviewed.

Sludge from boiler feed water unit

Power plant Hazardous


Collected and disposed of in accordance with the procedure detailed in the framework SWMP (refer to Vol IV).

Oil contaminated sludge

Oily contaminated materials e.g. oily rags

Lubricating / auxiliary oils

Water treatment sludge

Empty chemical containers

Solvents, paints

Spent filters and ion exchangers

Spent resins


Hazardous


Recovery and re-use options to be fully explored. Where recovery and re-use is not feasible then disposal of in the proposed Project landfill.

Contaminated packaging

Primarily associated with any chemical deliveries

Hazardous

Unknown contaminants and potential contamination of receiving environments

Use of finite landfill resource

Disposal of waste in the proposed Project landfill.

Effluents collected as a result of spills, leakages and/or accidental discharge.


Hazardous

Potential contamination of receiving environments


Fluorescent tubes Associated with routine and on-going maintenance in facilities and workshops

Hazardous

Fluorescent tubes contain mercury



Waste oil


Hazardous



Waste electronics and electrical equipment (WEEE)

Maintenance and replacement of electrical equipment

Hazardous


Recycling options to be fully explored. Where recycling is not feasible then disposal in the proposed Project landfill.


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Waste Source Potential environmental Impact

Disposal method

May contain heavy metals depending on the item

Concrete Associated with outages and maintenance

Recovery potential




General domestic waste Kitchen and workers’ facilities

Potential contamination of receiving environment.




Paper and cardboard

Plastic

From packaging and deliveries


Visual amenity impacts Glass Maintenance, deliveries,

workerss facilities

Iron and steel scrap

Non-ferrous scrap

Associated with outages and maintenance


Visual amenity impacts.

Recycling potential.

Where recycling is not feasible then disposal in the proposed Project landfill.

Pallets Associated with deliveries



Timber Associated with routine and on-going maintenance in the facility and outages

Recycling potential.

10.5.4 Decommissioning

The principal pieces of infrastructure which will require removal as part of the decommissioning

phase are as follows:

● Powerhouse equipment and buildings

● Fuel storage tanks

● Wastewater treatment structures

● Coal handling storage facilities

● Ash silos

From a waste management perspective, the principle waste stream likely to be generated

during decommissioning are the large volumes of concrete associated with the different

buildings and structures.

Advanced planning will be required in order to categorise each waste stream and identify a

potential re-use/recovery option. This will be particularly important for concrete and metal given

the large quantities likely to be generated.

Prior to the eventual decommissioning of the Project, a decommissioning environmental

management plan (DEMP) will be prepared detailing the best practice approach that will be

adopted. The DEMP will include a section on waste management detailing the environmental

protection controls that will be put in place for the storage, safe handling arrangements of each

waste stream and the recovery/re-use/recycling pathways, or disposal methods for those

wastes which can be recovered, re-used or recycled.


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10.5.5 Impact significance

The Project will be operated under best practice methods for storing and disposing of materials

and waste. Table 70 provides a summary of the impact significance associated with material

handling and waste management.

Table 70: Summary of impact significance

Activity Potential impact Sensitivity Magnitude Impact evaluation

Construction/decommissioning

Use of raw materials

Use of potentially finite and / or scarce resources.

Medium Moderate Moderate adverse – significant

Waste generation, handling and storage

Contamination of environments due to leakage and spillage of wastes associated with poor waste handling and storage arrangements.


Fugitive emissions, such as dust, associated with the handling and storage of some waste streams.


Visual amenity impacts associated with poor storage of waste.

Low Moderate Minor adverse – not significant

Spoil handling and disposal

Disposal of spoil and excavation material which results in land take.

Low Low Negligible – not significant

Choice of final waste disposal option

The use of landfill, which is a finite resource

Medium Moderate Moderate adverse - significant

Increased waste miles from transporting waste materials from the Project site.

Low Negligible Negligible - not significant

Operation

Use of raw materials

Use of potentially finite and / or scarce resources.

Medium Major Major adverse –significant

Waste generation, handling and storage

Contamination of receiving environments due to leakage and spillage of waste streams from the operation of the Project.

Medium Moderate Moderate adverse –significant

Fugitive emissions associated with the handling and storage of operational waste streams

Medium Moderate Moderate adverse –significant


The use of landfill, which is a finite resource

Medium Minor Minor adverse – not significant

Increased ‘waste miles’ from transporting waste materials from the Project site.

Low Minor Minor adverse – not significant


10.6.1 Overview

General waste management and overall management of hazardous materials will be managed

for the construction and operational phases as follows:

● Detailed construction phase materials storage, handling and use plan and waste

management plan and which will form part of the construction ESMP.

● Operational phase materials storage, handling and use procedures and a waste

management procedure which will both form part of an overall environmental and social


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management system (ESMS). The waste management procedure will be required to include

a SWMP.

● Detailed construction phase hazardous materials storage, handling and use plan and waste

management plan.

● The use of material safety data sheets (MSDS) will be used for all hazardous chemicals and

substances during the construction and commissioning phases of the Project.

● Best practice waste management begins with waste prevention and minimisation which is

achieved through the efficient storage, handling and use of raw materials. To achieve this

aim for the Project in both construction and operational phases, the following material use

and handling measures will be considered and imbedded into the construction ESMP and

operational phase procedures as appropriate:

– Re-using materials on site wherever possible. The most significant opportunity in the

construction phase is with respect to excavated spoil.

– Instituting good housekeeping and operating practices, including inventory control to

reduce the amount of waste resulting from materials that are out-of-date, off-specification,

contaminated, damaged, or excess to plant needs.

– Instituting procurement measures that recognise opportunities such as ordering the

correct amount of materials to be delivered when needed, reducing the amount of

packaging used by suppliers and establishing a take-back system with suppliers.

– Seeking ways to reduce raw material consumption through efficiency audits in the

operational phase.

– Substituting raw materials or inputs with less hazardous or toxic materials wherever

economically and technically feasible.

10.6.2 Materials storage, handling and use

This section presents mitigation measures for the use of materials during the construction and

operation of the Project.

To achieve best practice waste management during the construction and operational phases,

the following material use and handling measures will be embedded in the Project ESMP:

● Re-using materials on site wherever possible; the most significant opportunity in the

construction phase is with respect to excavated spoil and the overburden from the mine that

will be used for site levelling

● Establishing good housekeeping and operating practices, including inventory control to

reduce the amount of waste resulting from materials that are out-of-date, off-specification,

contaminated, damaged, or excess to plant needs

● Implementing procurement measures that recognise opportunities such as ordering the

correct amount of materials to be delivered when needed, reducing the amount of packaging

used by suppliers and establishing a take back system with suppliers

● Seeking ways to reduce raw material consumption through efficiency audits in the

operational phase

● Substituting raw materials or inputs with less hazardous or toxic materials wherever

economically and technically feasible

A materials handling and storage plan will be developed for the Project which will identify

storage areas to be established during the construction phase and will require these to be

specifically designed giving due consideration to the following requirements:


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● Located away from sensitive receptors

● Not at risk from theft or vandalism

● Protection from the elements

● Easily accessible in a safe manner

● Well ventilated

● Unlikely to be damaged

● Bunded and with spill kits provided close by (as necessary for hazardous liquids)

The construction and operational procedures will include reference to the control measures in

order to minimise the likelihood of incidents associated with materials storage, handling and

use. This will include the following:

● Identification of the necessary bunding and spill kit requirements

● Details of the correct procedure for handling and storing any hazardous materials

● A map showing the material storage locations

● Vehicle and equipment fuelling to only be undertaken in designated areas on impermeable

surfaces with adequate spill protection in place

● Training requirements (as necessary) with respect to materials handling procedures, use of

PPE, spill procedures and emergency response procedures

● The correct procedure for reporting any environmental incidents related to spills/ leakages.

10.6.2.1 Ash disposal

Sites for the ash disposal facility to serve the plant are currently being investigated and the

following options are considered:

● Spoil disposal site in the mine

● Disposal with the overburden from the mine

● Industry re-use

For the selected site, an ash management plan will be produced prior to operations

commencing and will include the following:

● Appropriate impermeable layers of the landfill site using clays available on the site

● Quantitative balance of ash generation

● Disposal, utilisation and reuse quantities/locations

● Cell structure and their protocol within site

● Size of ash disposal site

● Information on leachate collection and drainage

● Ash transportation arrangements (open and closed rail wagons/tank trucks depending on

wet/dry ash) and expected number

● Monitoring required (groundwater/noise/leachate) during operations

● Access/security arrangements

● Design of the ash disposal site in accordance with international best practice.

10.6.3 Construction and operational waste management plans

This section presents the waste management measures designed to manage the solid waste

generated on the Project site during the construction and operational phases.


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10.6.3.1 Temporary waste storage and handling

Temporary waste storage facilities are expected to be provided for the construction and

operational phases. It is envisaged that these will be scaled down once the Project moves into

the operational phase. These are intended as a secure, short-term storage for all waste streams

generated on site prior to being collected by relevant waste collectors for treatment and/or final

disposal. They will be designed to include the following:

● Separate storage areas for hazardous and non-hazardous wastes

● Separate skips for each waste stream to allow segregation in order to maximise reuse and

recycling opportunities

● All skips to have suitable coverings

● Liquid wastes/oil/chemicals to be stored in tanks or drums located in bunded areas which

can hold 110% of capacity of the largest tank or drum or, for multiple drum storage, 25% of

the total volume of material stored

● Spill kits to be provided in proximity to hazardous material and waste storage areas and to

be regularly inspected and replenished so as to be fully available at all times

● Store hazardous waste in closed containers away from direct sunlight, wind and rain in

designated storage areas

● Provide adequate ventilation where volatile wastes are stored

● Handling and storage shall be carried out by trained staff

● Provide readily available information on chemical compatibility to workers including labelling

each container, demarcation of the area (eg on a facility map/site plan)

● Conduct periodic inspections of waste storage areas and document the findings

● Prepare and implement spill response and emergency response plans to address an

accidental release and leakage

10.6.3.2 Wastewater management

The EPC contractor will be responsible for the complete wastewater collection and

neutralisation system. The treatment system will collect several process discharges from the

entire power plant and auxiliary facilities such as boiler, coal yard and chemistry process

systems. The consumption of water will be minimised through recycling and reuse of treated

wastewater in activities such as dust suppression and ash handling. The end disposal route for

wastewater is still to be confirmed.

10.6.3.3 Construction waste management strategy

The SWMP will identify predicted waste streams, appropriate handling, reuse and recycle

opportunities and, as a last resort, disposal methods. The SWMP will be prepared in

accordance with national waste regulations and the IFC General EHS Guidelines (2007) and the

EWC.

The construction SWMP will include the following mitigation measures;

● The best practice waste handling and final treatment options (ie reuse, recycling, recovery or

disposal) for each waste stream

● The procedures for the reduction of waste production

● The correct methodology for establishing the spoil disposal sites (ie topsoil, overburden, and

low quality materials will be properly removed, stockpiled near the site, and temporarily

preserved for any necessary site rehabilitation)


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● A description of the control measures at each spoil disposal site (such as spot checking of

spoil loads)

● Contractor training requirements with respect to waste handling procedures

● Waste generation data collection for each waste stream by volume. This will include the

proportion of each waste stream going for reuse, recycling or disposal. Any unusual waste

volumes will be investigated

● Any waste monitoring as deemed to be necessary

● An audit schedule which details the frequency of waste management audits and those

responsible for undertaking them

● The correct procedure for reporting any environmental incidents related to waste

● The specific regulatory reporting requirements as they relate to waste.

10.6.3.4 Operational waste management strategy

For the operational phase, the production of a detailed waste management procedure for all

operations at the Project is going to be fundamental to ensuring best practice waste

management is undertaken and becomes embedded into the operational philosophy of the

Project. The waste management procedure will highlight the relevant policy and legislation and

include a SWMP, which will contain:

● The establishment of a waste management hierarchy philosophy that considers prevention,

reduction, reuse, recovery, recycling, removal and finally disposal of wastes

● A map showing each waste storage location for the Project

● A description of each waste generated by the operation of the facility, the appropriate

handling methodology, the correct approach for storage and the correct route for

removal/disposal off site

● Staff training requirements with respect to waste handling procedures

● Waste generation data collection for each waste stream by volume, according to the EWC.

This will include the proportion of each waste stream going for reuse, recycling or disposal;

any unusual waste volumes will be investigated

● Any waste monitoring as deemed to be necessary

● An audit schedule which details the frequency of waste management audits and those

responsible for undertaking them

● A section related to continuous improvement and corrective actions where audit findings can

be recorded and incorporated into the waste management procedure; this will also highlight

any new and feasible reuse or recycling opportunities which may arise over time

● A mechanism by which to routinely track waste consignments from the originating location to

the final waste treatment and disposal location

● The correct procedure for reporting any environmental incidents related to waste

● The specific regulatory reporting requirements as they relate to waste

It is expected that the control measures described herein will be largely sufficient in avoiding the

potential environmental impacts typically associated with waste generation.

10.6.3.5 Wastewater mitigation

The waste management plan should include details on the management of wastewater during

construction and operation. All liquid waste collected in a covered outdoor waste liquid pond

should be tested for pH, chemical oxygen demand (COD) and biochemical oxygen demand


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(BOD) before being released to the environment. At the time of writing the waste water disposal

regime was yet to be defined. However, it is understood that the Government of Sindh will

provide a water disposal option for all Blocks in the Thar Coalfield.

10.6.4 Proposed monitoring

Waste management monitoring for the Project will be undertaken by the EPC contractor /

Developer as part of the construction and operational waste management plans detailed in the

ESMP. Monitoring data will be analysed and reviewed at regular intervals and compared with

the operating standards so that any necessary corrective actions can be taken.


The mitigation measures identified above will ensure that the vast majority of waste generated

as a result of the Project will be managed according to environmental best practice and the risk

to the environment is significantly reduced. Following application of the mitigation measures the

resultant residual impacts are presented in Table 71.


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Table 71: Summary of residual waste and materials impacts

Activity Potential impacts Sensitivity Magnitude Impact significance

Residual impact evaluation

Residual impact

Construction

Use of raw materials Use of potentially finite and / or scarce resources.

Medium Moderate Moderate adverse Minor adverse Not significant

Waste generation, and storage

Contamination of environments due to leakage and spillage of wastes associated with poor waste handling and storage arrangements


Fugitive emissions, such as dust, associated with the handling and storage of some waste streams



Low Moderate

Minor adverse

Negligible Not significant

Spoil handling and disposal

Disposal of spoil and excavation material which results in land take.

Low Low Negligible Negligible Not significant


The use of landfill, which is a finite resource should be final recourse



Low Negligible Negligible Negligible

Operation

Use of raw materials Use of potentially finite and / or scarce resources.

Medium Major Major adverse Moderate adverse Significant

Waste generation and storage

Contamination of receiving environments due to leakage and spillage of waste streams from the operation of the Plant.


Fugitive emissions associated with the handling and storage of operational waste streams



The use of landfill, which is a finite resource should be final recourse

Medium Minor Minor adverse Minor adverse Not significant


Low Minor Negligible Minor adverse Not significant

Decommissioning Prior to decommissioning, a DEMP will be prepared.


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11 Hydrology, hydrogeology and flood risk

11.1 Introduction

This chapter presents the baseline conditions and the assessment of impacts on water

resources and flood risk associated with the construction and operation of the Project.



The Sindh Environmental Protection Act 2014 provides powers to the SEPA to issue standards

for protection of the environment. The SEPA issued the Sindh environmental industrial waste

water, effluent, domestic, sewerage, industrial air emission and ambient airs, noise for vehicles,

air emissions for vehicles and drinking water quality standards in December 2014. Table 72 sets

out the effluent standards relevant to the Project.

Table 72: Sindh Environmental Quality Standards for municipal and liquid industrial effluents

S.No Parameter Standards (mg/l unless otherwise defined)

Into Inland Waters

Into Sewage Treatment1

Into Sea2

1 Temperature 40oC or Temperature increase3 ≤3oC ≤3oC ≤3oC

2 pH value (H+) 6-9 6-9 6-9

3 Biochemical Oxygen Demand (BOD)5 at 20oC4 80 250 805

4 Chemical Oxygen Demand (COD)4 150 400 400

5 Total Suspended Solids (TSS) 200 400 200

6 Total Dissolved Solids (TDS) 3,500 3,500 3,500

7 Oil and grease 10 10 10

8 Phenolic compounds (as phenol) 0.1 0.3 0.3

9 Chloride (as Cl-) 1,000 1,000 SC6

10 Fluoride (as Fl-) 10 10 10

11 Cyanide (as CN-) total 1.0 1.0 1.0

12 Anionic detergents (as MBAS)7 20 20 20

13 Sulphate (SO42-) 600 1,000 SC6

14 Sulphide (S2-) 1.0 1.0 1.0

15 Ammonia (NH3) 40 40 40

16 Pesticides8 0.15 0.15 0.15

17 Cadmium9 0.1 0.1 0.1

18 Chromium (trivalent and hexavalent)9 1.0 1.0 1.0

19 Copper9 1.0 1.0 1.0

20 Lead9 0.5 0.5 0.5

21 Mercury9 0.01 0.01 0.01

22 Selenium9 0.5 0.5 0.5

23 Nickel9 1.0 1.0 1.0

24 Silver9 1.0 1.0 1.0

25 Total toxic metals 2.0 2.0 2.0

26 Zinc 5.0 5.0 5.0

27 Arsenic9 1.0 1.0 1.0


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S.No Parameter Standards (mg/l unless otherwise defined)

Into Inland Waters

Into Sewage Treatment1

Into Sea2

28 Barium9 1.5 1.5 1.5

29 Iron 8.0 8.0 8.0

30 Manganese 1.5 1.5 1.5

31 Boron9 6.0 6.0 6.0

32 Chlorine 1.0 1.0 1.0

Source: SEPA, 2014

1. Applicable only when and where sewage treatment is operational and BOD = 80 mg/l is achieved by the sewage

treatment system.

2. Provided discharge is not at shore and not within 10 miles of mangrove or other important estuaries.

3. The effluent should not result in temperature increase of more than 3oC at the edge of the zone where initial mixing

and dilution take place in the receiving body. In case zone is not define, use 100 m from the point of discharge

4. Assuming minimum dilution 1:10 discharge, lower ratio would attract progressively stringent standards to be

determined by the Federal Environmental Protection Agency. By 1:10 dilution means, for example that for

each one cubic meter of treated effluent, the recipient water body should have 10 cubic meter of water for

dilution of this effluent.

5. The value for industry is 200 mg/l

6. Discharge concentration at or below sea concentration (SC)

7. Methylene Blue Active substances assuming surfactant as biodegradable

8. Pesticides include herbicides, fungicides, and insecticides

9. Subject to total toxic metals discharge should not exceed level given at S. No. 25

Notes:

1. Dilution of liquid effluents to bring them to the Standards limiting values is not permissible through fresh water mixing

with the effluent before discharging into the environment.

2. The concentration of pollutants in water being used will be subtracted from the effluent for calculating the Standards

limits.

Table 73: Sindh Standards for drinking water quality

Properties/parameters Standard values for Pakistan WHO Guidelines

Bacterial1

All water intended for drinking (e.Coli

or Thermotolerant Coliform bacteria)

Must not be detectable in any 100ml sample


Treated water entering the distribution

system (E.Coli or thermo-tolerant

coliform and total coliform bacteria)



Treated water in the distribution

system (E.coli or thermo-tolerant

coliform and total coliform bacteria)

Must not be detectable in any 100ml sample in case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.

Must not be detectable in any 100ml sample in case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.

Physical

Colour ≤15 TCU ≤15 TCU

Taste Non-objectionable/Acceptable Non-objectionable/Acceptable

Odour Non-objectionable/Acceptable Non-objectionable/Acceptable

Turbidity <5 NTU <5 NTU

Total hardness as CaCO3 < 500mg/l

TDS < 1000 < 1000

pH 6.5 – 8.5 6.5 – 8.5

Chemical – Essential Inorganic mg/litre mg/litre


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Properties/parameters Standard values for Pakistan WHO Guidelines

Aluminium (Al) < 0.2 0.2

Antimony (Sb) < 0.005 (P) 0.02

Arsenic (As)2 < 0.05 (P) 0.01

Barium (Ba) 0.7 0.7

Boron (B) 0.3 0.3

Cadmium (Cd)2 0.01 0.003

Chloride (Cl) < 250 250

Chromium (Cr) < 0.05 0.05

Copper (Cu) 2 2

Chemical - toxic inorganic mg/litre mg/litre

Cyanide (CN)2 < 0.05 0.07

Fluoride (F)* < 1.5 1.5

Lead (Pb)2 < 0.05 0.01

Manganese (Mn) < 0.5 0.5

Mercury (Hg) < 0.001 0.001

Nickel (Ni) < 0.02 0.02

Nitrate (NO3)* < 50 50

Nitrite (NO2)* < 3 (P) 3

Selenium (Se) 0.01 (P) 0.01

Residual chlorine 0.2-0.5 at consumer end

0.5-1.5 at source

-

Zinc (Zn)2 5.0 3

* Indicates priority health related inorganic constituents which need regular monitoring

Chemical - organic

Pesticides mg/l PSQCA No. 4639-2004, Annex II Page No. 4 Table No. 3 Serial No. 20-58 may be consulted***

Phenolic compounds (as Phenols) mg/l < 0.002

Polynuclear aromatic hydrocarbons (as PAH) g/l

0.01 (By GC/MS method)

Radioactive

Alpha emitters bq/l or pCi 0.1 0.1

Beta emitters 1 1

*** PSQCA: Pakistan Standards Quality Control Authority

Proviso:

The existing drinking water treatment infrastructure is not adequate to comply with WHO guidelines for Arsenic, Lead, Cadmium and Zinc due to existing contaminants and urban water infrastructure. However, NEQs confirm for bottled water WHO limits for Arsenic, Lead, Cadmium and Zinc will be applicable and PSQCA Standards for all the remaining parameters.

Notes:

1. Most Asian countries also follow WHO standards

2.Standard for Pakistan similar to most Asian developing countries


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Source: Sindh Environmental Protection Agency, 2014

The NEQS (Self-Monitoring and Reporting by Industry) Rules 2001 (SRO 528(1)/2001) (as

amended by SRO 114(1)/2005) – the NEQ S.M.A.R.T. system for industrial self reporting on

monitoring of liquid or gaseous emissions to the Federal Agency (Environment) Liquid effluents

and gaseous emissions from coal fired thermal power plants, and gas production (category A)

require environmental monitoring reports to be submitted monthly.

The NNEQS (Certification of Environmental Laboratories) Regulations 2000 (SRO258(1)/2000)

prescribe procedures for certification of laboratories where tests may be conducted to check

compliance with NEQs. The proposed Project laboratory will require certification in order to

comply with the self-monitoring of effluent discharges against NEQS.


11.2.2.1 IFC Performance Standards

The IFC PSs provide guidance on how to identify risks and impacts, and are designed to help

avoid, mitigate, and manage risks and impacts as a way of doing business in a sustainable way.

The following IFC PSs are relevant to this assessment.

IF PS3 Resource efficiency and pollution prevention

Water consumption: ‘When the project is a potentially significant consumer of water, in

addition to applying the resource efficiency requirements of this Performance Standard, the

client shall adopt measures that avoid or reduce water usage so that the project’s water

consumption does not have significant adverse impacts on others.’

Pollution prevention: ‘The client will avoid the release of pollutants or, when avoidance is not

feasible, minimise and/or control the intensity and mass flow of their release. This applies to the

release of pollutants to air, water, and land due to routine, non-routine, and accidental

circumstances with the potential for local, regional, and transboundary impacts.’

IFC PS6 Biodiversity conservation and sustainable management of living natural resources

The objectives of this standard are:

● To protect and conserve biodiversity

● To maintain the benefits from ecosystem services

● To promote the sustainable management of living natural resources through the adoption of

practices that integrate conservation needs and development priorities

Water resources, both quantity and quality, are fundamental to maintaining habitats and

ecosystem services. The potential effects of changes in water management by the Project on

biodiversity and ecosystem services are assessed in chapter 14.

11.2.2.2 World Bank Group EHS guidelines

General EHS Guidelines

The following sections of the General EHS Guidelines are relevant to this assessment:

● 1.3 Wastewater and ambient water quality

● 1.4 Water conservation

● 1.5 Hazardous materials management


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● 3.1 Water quality and availability

The following industry sector EHS Guideline is applicable in this case:

Industry Sector EHS Guidelines – Thermal power plants

The Guidelines set specific limit values for direct discharges of treated effluents to surface

waters for general use. These levels should be achieved, without dilution, at least 95 percent of

the time that the plant or unit is operating, to be calculated as a proportion of annual operating

hours.


11.3.1 Area of influence for water resources and flood risk

The spatial scope of the assessment of the Project includes surface water and groundwater

features within 500m of the Project site, except where there is clearly no hydraulic connectivity,

as outside this distance it is unlikely that direct impacts upon the water environment will be

attributable to the Project. The 500m scope has been developed using professional judgement.

The Government of Sindh is working with developers in the Thar Coalfield by providing

infrastructure for a dedicated supply of surface water (100 cusecs) to the area. It is understood

that the Block VI developer has requested an allocation of 38 cusecs. It is assumed that this

allocation of water requested by the Project from the new Vejhiar reservoir approximately 15km

north east of the site does not require an extension of the study area. Vejhiar reservoir will itself

be fed from the existing Chotiari reservoir by canal and pipeline.

As discussed in chapter 2, the Project is to be constructed adjacent to a large new lignite mine

within Block VI. This mining operation will have a number of impacts on local water resources

and flood risk as described and assessed in the mining project ESIA. When the Project and the

mine are considered in combination the study area is extended to cover the mine workings or

the associated mine waste water disposal facilities.

11.3.2 Desktop review

Previous reports undertaken as part of the development of the Thar Coalfield and other projects

in the region have been reviewed and included:

● Feasibility Study, Interim Report 5 Phase II Water Management Study for the Thar Block VI

Project (SRK Consulting, 2011) including as an Annex:

● RPS Aquaterra Feasibility Study Hydrogeological Assessment Report

● RPS Aquaterra Thar Block VI water supply and disposal (February 2017)

● Block VI lignite mining project ESIA (Hagler Bailly, 2013)

● Pakistan Thar Block VI 2×330MW Coal-Electricity Integrated Project Feasibility Study (China

Power, 2014)

● Thar Coal Block II Power Project ESIA (Hagler Bailly, 2014)

● Environmental and social study for Thar Coalfield (Mott MacDonald, 2013)

● Block VI Lignite mining project ESIA (Wardell Armstrong, 2016)


An appraisal of the water features has been undertaken through desk study to provide

information against which to predict levels of potential impact and assess significance of such


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impacts. The water features which are likely to be affected by the scheme have been evaluated

in terms of the short and long-term consequences to help assess the relative significance of the

development (See Table 74 below). The magnitude of impact and the likely significance of any

effects of the project on water features of the area have been assessed using the criteria in

chapter 5.

Table 74: Water feature sensitivity criteria

Sensitivity Typical characteristics Identified receptors

High Surface water or groundwater body with little or no capacity to absorb proposed changes or minimal opportunities for mitigation.

Receptor at high risk of flooding outside normal flood plain, affecting significant region or large population

Receptor used for regional water supply source or conveyance

Surface water receptor at high risk of non-localised alignment change

Receptor at high risk of depletion (surface waters levels falling or drying out; groundwater levels / yields falling) or pollution

Large areas of soil and agricultural land use may be affected by flooding / change in hydrological conditions permanently

None identified

Medium Surface water or groundwater body with some capacity to absorb proposed changes.

Receptor at high risk of flooding outside normal flood plain, affecting a small district

Receptor used for local village water supply source or conveyance

Surface water receptor at high risk of localised alignment change

Receptor at medium risk of depletion (surface waters levels falling or drying out; groundwater levels / yields falling) or pollution

Small areas of soil and agricultural land use may be affected by flooding / change in hydrological conditions permanently

Shallow aquifer

Village wells

Traditional water capture/storage systems in inter-dune areas that extend seasonal water use

Low Surface water or groundwater body with considerable capacity to absorb proposed changes

Receptor at some risk of localised flooding outside normal flood plain, with limited local consequences for the environment

Receptor used for seasonal water supply for livestock

Soil and agricultural land use may be affected by flooding / change in hydrological conditions occasionally

Deep aquifer

Middle aquifer

Natural ephemeral waterbodies in inter-dune areas

Low/ Negligible Soil and agricultural land use not sensitive to some change in hydrological regime

-

Professional judgement was used to vary the predicted impact where appropriate for example

where an impact of major magnitude on a highly sensitive receptor may not be of critical

significance if it is considered unlikely to occur.


All aspects of water use, water treatment and water discharge presented in this chapter are based

on current plans available for the Project and/or for the adjacent coal mine development. These

details are subject to change once the plant design is finalised.


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Since the method of disposal of waste water from the Project has not yet been confirmed, it is

assumed that there will be no discharge to the environment that has not received appropriate

treatment to ensure that it will meet the Sindh environmental standards for effluent discharge.

No field investigations have been carried out for this ESIA, the baseline makes use of the results

of field investigations across Block VI reported in the documents set out in section 11.3.2 above.


11.4.1 Current baseline

11.4.1.1 Climate

The Thar Desert has a semi-arid climate with between 100mm and 200mm rainfall annually;

over 80% of this falls during the monsoon (mid-June to mid-September). Rainfall is variable

from one year to the next - it can be as high as 500mm, but also fails once every four to six

years. There have been major droughts in every decade since the 1950s typically each lasting

two to three years.

The area is also characterised by extremes of temperature with the hottest period between April

and June (24°C - 41°C) and the coldest between December and February (9°C - 28°C). For

almost half of the year the prevailing wind direction is from the north or northeast but during the

summer monsoon season the direction reverses to south-westerly and the winds become much

stronger.

Table 75: Estimated mean monthly climatic parameters for the Project area

Month Temperature ºC Relative humidity

(%)

Precipitation

Wind

Maximum Minimum (mm) Rain days

Speed (m/s)

Direction

January 26.5 5.4 45.5 0.6 0.1 1.7 N

February 29.2 8.7 44.5 2.0 0.3 1.9 N

March 34.5 14.3 42.6 4.6 0.3 2.4 W

April 39.1 20.1 42.7 3.5 0.3 3.8 SW

May 41.5 24.5 46.8 3.0 0.2 5.9 SW

June 39.7 27.2 56.4 19.7 0.9 5.5 SW

July 36.2 26.8 67.2 79.0 3.4 5.1 SW

August 34.5 25.7 70.2 74.5 3.0 4.6 SW

September 35.7 23.9 64.8 23.0 1.1 3.3 SW

October 37.1 18.5 50.8 2.1 0.2 1.9 SW

November 33.0 11.9 44.6 3.6 0.2 1.5 NE

December 28.0 6.6 46.8 0.9 0.1 1.4 NE

Annual 34.5 17.8 52.1 222.0 10.0 - -

Note: A day is defined as a rain day if the total amount of rainfall for that day exceeds 2.5 mm

Source: Hagler Bailly, 2013


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Table 76: Estimated mean monthly climatic parameters for the Project area

Month Temperature Relative humidity (%)

Precipitation Wind

Maximum Minimum (mm) Rain days

Speed (m/s)

Direction

January 26.5 5.4 45.5 0.6 0.1 1.7 N

February 29.2 8.7 44.5 2.0 0.3 1.9 N

March 34.5 14.3 42.6 4.6 0.3 2.4 W

April 39.1 20.1 42.7 3.5 0.3 3.8 SW

May 41.5 24.5 46.8 3.0 0.2 5.9 SW

June 39.7 27.2 56.4 19.7 0.9 5.5 SW

July 36.2 26.8 67.2 79.0 3.4 5.1 SW

August 34.5 25.7 70.2 74.5 3.0 4.6 SW

September 35.7 23.9 64.8 23.0 1.1 3.3 SW

October 37.1 18.5 50.8 2.1 0.2 1.9 SW

November 33.0 11.9 44.6 3.6 0.2 1.5 NE

December 28.0 6.6 46.8 0.9 0.1 1.4 NE

Annual 34.5 17.8 52.1 222.0 10.0 - -

Note: A day is defined as a rain day if the total amount of rainfall for that day exceeds 2.5 mm

Source: Hagler Bailly, 2013

11.4.1.2 Hydrology

There are no perennial river courses close to the Project area, although there are small

ephemeral channels that capture runoff during and after large rainfall events. The runoff collects

in inter-dune areas and rapidly dries out by evaporation and infiltration into the shallow aquifer.

11.4.1.3 Hydrogeology

The entire Thar region is underlain by a relatively flat lying sedimentary basin that rests

unconformably on crystalline basement. The generalised stratigraphic sequence is shown in

Table 77; it comprises granitic bedrock, shallow marine sands and younger coal-bearing strata

of the Bara Formation, alluvial deposits and dune sands.

Table 77: Summary of on-site geology

Formation name

Age Thickness (m) Typical description

Dune sand Recent Typical: 50 m

Range: 30 m – 110 m

Sand, Silt, Clay

Alluvial deposits Sub-Recent Typical: 80 m

Range: 11 m – 127 m

Sandstone, siltstone and claystone

Bara formation Palaeocene to Early Eocene

Range: 50 m – 150 m Claystone, shale, sandstone and coal

Basement complex

Pre-Cambrian - Granite and Quartz Diorite

Source: SRK, 2011

Groundwater recharge is low (as a result of the low rainfall and high evapotranspiration) and

there are no perennial streams. Water is scarce and the groundwater is brackish to saline.

However, following monsoon rains, fresh water can accumulate in the inter-dune areas creating


366982 | 02 | B | March 2017

temporary fresh water ponds (termed Taraies), which provide an important short-term water

supply to the local community. These monsoon rainfall events also provide recharge to the

shallow and perched aquifers throughout the Thar Desert region.

Three main aquifers and two aquitards have been identified in the Thar region. These units

comprise from the surface downwards an upper shallow aquifer, which is located in the base of

the dune sands, a fine grained siltstone aquitard, a middle alluvial sand aquifer of sub-recent

age, a claystone and lignite aquitard in the top part of the Bara Formation and a deep aquifer of

marine sands belonging the bottom part of the Bara Formation.

The Shallow or Top aquifer (dune sand) is unconfined and is sustained by recharge from the

surface during the monsoon rains. The mean hydraulic conductivity (K) of this aquifer is 2.6E-02

m/d (Singh et al, 2010). The saturated thickness is typically 5m, but because of the undulating

nature of the erosive contact with the Sub-Recent siltstones, the incidence and thickness of this

aquifer is quite patchy. The water quality is also highly variable (TDS = 1,500mg/l – 15,000mg/l)

depending on the inter-connectivity of the aquifer and the frequency with which it is flushed by

fresh recharge water. Despite these limitations, the dune aquifer is a very important source of

water to the community for livestock and potable use.

The Middle aquifer is confined beneath the Sub-Recent siltstone. It comprises alluvial sands

originally deposited in a deltaic and fluvial setting and appears to be heterogeneous and

variable in thickness across the region. It is typically 5m to 10m thick, but locally may be as little

as 2m. Previous studies indicate that the K of this aquifer ranges between 1.0E-03 m/d and 5

m/d (Singh et al, 2010). The water quality is brackish with a typical TDS of 5,000mg/l.

The Deep aquifer sits at the very bottom of the sedimentary sequence above the granite

basement and confined below the Bara claystone and lignite horizons. It is the largest aquifer in

the region in terms of thickness, lateral extent and yield, with the K ranging between 5m/d and

23m/d (Singh et al, 2010). The water quality is generally brackish to mildly saline with a TDS

concentration ranging between 5,000mg/l and 10,000mg/l.

RPS Aquaterra undertook a field investigation in Thar Block VI between October 2010 and

February 2011 in order to obtain site specific information on the properties of the three main

aquifers.

The field programme included:

● Installation of four test and observation wells in each of the aquifers

● Test pumping of the installed test wells

● Collection of groundwater samples from each of the test wells

● Groundwater level monitoring

A summary of the detailed water quality results is given in Table 78, further results are

presented in SRK 2011 (SRK report Annex 1, Appendix F).


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Table 78: Summary of aquifer water quality results in Block VI

Parameter Units Aquifer

Deep

SCE34_DTW

Middle

SCE34_MTW1

Middle

SCE31_MTW2

Shallow

SCE34_STW

Non-metals and other species

Temperature oC 37.9 33.7 33.7 33.2

Dissolved Oxygen (DO) mg/l 3.74 3.96 3.59 4.91

Odour TON 1.5 2.0 3.0 5.0

Taste - ND ND ND ND

Colour PtCO 5.0 10.0 6.0 10.0

pH 7.14 6.96 6.49 6.68

Biochemical Oxygen Demand (BOD) mg/l 6.4 16.4 6.8 5.6

Chemical Oxygen Demand (COD) mg/l 14.0 42.0 17.5 12.0

Cyanide (CN) mg/l <0.001 <0.001 <0.001 <0.001

Phosphorous (P) total mg/l 0.86 0.72 0.39 2.48

Ammonia (NH3) mg/l <0.001 <0.001 1.06 1.24

Hardness Total as CaCO3 mg/l 796 1910 1602 998

Solids

Suspended Solids (total) mg/l 23.72 46.84 24.27 19.26

Total Dissolved Solids (TDS) mg/l 4,390 6,352 6,010 3,720

Electrical Conductance (EC) ms/cm 7.70 12.28 11.22 7.36

Microbiology

Escherichia coli (E-coli) Cfu/ml 25 45 28 65

Major Anions

Chloride (Cl-) mg/l 2,304 3,544 3,246 1,949

Sulphate (SO42-) mg/l 248 280 270 126

Carbonate (CaCO32-) mg/l <1.0 <1.0 <1.0 <1.0

Bicarbonate (HCO3-) mg/l 213.8 246.0 305.0 311.0

Nitrate (NO3-) mg/l 0.28 0.01 0.3 <0.01

Phosphate (PO4-) mg/l 0.39 0.28 0.14 1.83

Fluoride (F-) mg/l 2.86 <0.02 0.29 1.87

Major Cations

Sodium (Na+) mg/l 1347 1639 1610 976

Potassium (K+) mg/l 16.48 32.46 24.85 17.92

Calcium (Ca2+) mg/l 152.5 348.0 336.8 198.3

Magnesium (Mg2+) mg/l 99.6 252.0 185.2 122.7

Metals

Cobalt (Co) total mg/l 0.0685 <0.01 0.0392 <0.01

Nickel (Ni) total mg/l <0.01 <0.01 <0.01 <0.01

Copper (Cu) total mg/l 0.0482 <0.01 <0.01 0.0286

Cadmium (Cd) total mg/l <0.01 <0.01 <0.01 <0.01

Lead (Pb) total mg/l <0.001 <0.001 <0.001 <0.001

Arsenic (As) total mg/l 0.003090 0.001826 0.003057 0.004716

Chromium (Cr) total mg/l 0.00998 0.01390 0.006 <0.001

Chromium ((Cr) VI mg/l 0.00475 0.01250 0.00274 <0.001

Chromium (Cr) III mg/l 0.00523 0.0014 0.00326 -

Zinc (Zn) total mg/l 0.0082 0.5372 0.1793 0.0853


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Parameter Units Aquifer

Deep

SCE34_DTW

Middle

SCE34_MTW1

Middle

SCE31_MTW2

Shallow

SCE34_STW

Mercury (Hg) total mg/l <0.00001 <0.00001 <0.00001 <0.00001

Boron (B) mg/l 4.6 3.85 2.8 1.26

Iron (Fe) total mg/l 6.208 1.708 0.9854 0.7099

Vanadium (V) total mg/l <0.01 <0.01 <0.01 <0.01

Selenium (Se) total mg/l <0.00001 <0.00001 <0.00001 <0.00001

Organics

Polyaromatic Hydrocarbon (PAH) µg/l <0.001 <0.001 <0.001 <0.001

Cyclohexane (C6H10O) µg/l <0.001 <0.001 <0.001 <0.001

Hydrocarbon Extractable µg/l 0.002084 <0.001 <0.001 <0.001

Total Petroleum Hydrocarbons µg/l 0.007226 0.003182 0.009116 <0.001

Purgable Organics µg/l 0.000948 0.000417 0.001853 <0.001

Source: SRK, 2011 (RPS Aquaterra)

TDS for the Shallow Aquifer was 3,270mg/l and village wells sampled at the same time gave

values ranging from 1,620 to 3,720mg/l. the aquifer is brackish and slightly less saline than the

regional values reported by Singh (Singh et al, 2010).

TDS for the two Middle Aquifer boreholes were 6,010mg/l and 6,352mg/l, indicating that this

aquifer is slightly saline.

TDS for the Deep aquifer was 4,390mg/l indicating that this aquifer is brackish.

11.4.1.4 Flood risk

Whilst the Project site has an arid climate and no perennial watercourses, the area can receive

significant storm rainfall during the summer monsoon season. The flood runoff collects in inter-

dune areas and is soon lost to evaporation and infiltration.

In 2011 Sindh, and particularly the Thar Desert, experienced an extreme monsoon as shown in

Table 79, the season total of 1,348mm at Mithi and 552mm at Chhor set new records32. The

table demonstrates that July was much drier than normal but the rest of the season was

unusually wet.

Table 79: Monsoon rainfall in Thar Desert (mm) in 2011

Parameter Badin

1931-2011

Chhor

1931-2011

Mithi

2004-2011

July

● Actual 31.4 8.0 9.0

● Normal 67.6 79.3 78.2

● Highest 302.9 (2003) 354.3 (2003) 303.8 (2009)

August

● Actual 331.2 276.0 562.8*

● Normal 92.5 69.3 150.7

● Highest 459.0 (1979) 356.1 (1990) 346.3 (2006)

32 Arif Mahmood, Nadeem Faisal and Akhlaq Jameel (Jan, 2012), Special Report on Pakistan‟s Monsoon 2011 Rainfall, Pakistan

Meteorological Department, Ministry of Defence, Government of Pakistan.


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Parameter Badin

1931-2011

Chhor

1931-2011

Mithi

2004-2011

September

● Actual 284.0 268.0 776.1*

● Normal 27.1 37.3 58.6

● Highest 347.7 (1970) 381.6 (1998) 220.0 (2006)

July-September

● Actual 646.6 552.0* 1347.9*

● Normal 187.2 185.9 287.5

● % Departure 245% 366% 369%

● Highest 806.3 (1994) 521.0 (2003) 669.8 (2006)

* New record, Normal=1961-1990 or averaged over the available record.

Source: Arif Mahmood et al., 2012

Figure 22 shows the pattern of daily rainfall over the 2011 monsoon season at Mithi. Three days

recorded totals close to or above 300mm.

Figure 22: Maximum rainfall in any 24 hour period Mithi meteorological station – July, August and September 2011

Source: Hagler Bailly Pakistan, 2013

There is no monitoring of local storm runoff in the Project area to inform the design of flood

protection measures for the Project.


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11.4.1.5 Water use

Village settlements abstract (pump/draw) water from hand dug wells, tapping the Top (Dune

Sand) aquifer, across the Thar Desert region. The volume of water abstracted is generally

relatively small and is used to meet drinking water requirements as well as all other daily

domestic water needs.

SRK report anecdotal evidence from the local villagers in the Block VI area which suggests that

village wells within Khario Jani, Ranjhan Noon and Singhario abstract approximately 4,000-

7,500 litres per day from each active hand dug well. It is reported that approximately 100 to 150

bucket loads (each bucket has a 40-50 litre capacity) are removed from each well per day, but

that the well goes dry after taking approximately 50 to 60 bucket loads continuously and needs

to be rested for two to three hours to allow water levels to recover prior to resuming pumping.

SRK report describes that local villagers suggest that water quality in the village wells improves

following significant rainfall events reflecting rapid recharge.

The SCA has a number of active and proposed wells abstracting water from the Deep Aquifer

across the region. The water abstracted is treated by the RO plant and used to meet municipal

drinking water supply requirements. There is one such deep well and RO plant currently in

operation in Islamkot.

11.4.2 Future baseline

Committed development

As discussed in chapter 2, the Project is to be constructed adjacent to a large new coal mine

within Block VI. This mining operation will have a number of impacts on local water resources

and flood risk as described and assessed in the mining project ESIA (Hagler Bailly, 2013,

Wardell Armstrong, 2016). Key impacts of relevance to the Project are:

● Localised disruption of surface drainage pattern changing spatial characteristics of storm

runoff

● The impact of dewatering on groundwater flow and levels in the zone of influence of the

mining operation creating a cone of depression centred on the pit affecting groundwater

levels up to 1km away

● Impact of disposal of dewatering volumes on Shallow aquifer water levels and quality at the

discharge location – a location sufficiently distant and hydraulically down gradient from the

dewatering operations not to create cycling of water

● Resettlement of villages, loss of historic agricultural lands and destruction/abandonment of

wells leading to new patterns of water usage by the local community based on supply from

the mine

● Creation of a new lined landfill for hazardous waste.

The proposed Block VI coal mine will form part of the baseline for the operation of the Project.

The potential cumulative effects arising from the adjacent mine workings in relation to water

resources and flood risk have been considered as part of this assessment of the construction

and operation of the Project.

Climate change

Current projections to the 2080s indicate that climate change may affect the future baseline

against which the impacts of the Project on surface water and groundwater resources have

been assessed. There may be changes in the flow and water quality characteristics of surface

water and groundwater bodies as a result of changes in climate.


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Current projections indicate that there will be more variability in the monsoon season affecting

the start date, the overall duration, the daily and monthly distribution and thus greater inter-

annual variation. The probability and severity of surface water flooding could therefore increase

leading to more recharge to shallow groundwater and an improvement in water quality (lower

salinity). Conversely the frequency and severity of failures of the monsoon could increase

leading to reduced recharge and poorer water quality. Given the current high variability of

rainfall, these changes are not considered to result in significant changes to the reported effects

from the Project.

11.4.2.1 Hydrogeology – future situation

To extract coal safely the open pit must be kept dry (dewatered). The dewatering volume will

increase over time as the open pit grows in size and is predicted to result eventually in a cone of

depression in groundwater levels extending up to 1km from the pit.

One of the challenges facing the mining project is what to do with the large volumes of

groundwater that will be produced by the dewatering operation. The water must be disposed of

in such a way that it cannot re-enter the dewatering area, represented by the area of the cone of

depression around the pit. As this ‘mine floodwater’ is a composite of captured flows from the

three aquifers it will also have poor water quality compared to the Shallow Wquifer receptor for

these discharges if they were to be disposed to ground by infiltration. The Sindh standards

specifically forbid the blending of effluent to improve its quality.

Investigations undertaken to date identify that between 2,000-3,000 litres per second of water

may be produced from dewatering of the mine, although this may be affected by dewatering

activities at adjacent blocks. Whilst some water will be required for the Project and mine, there

will be a significant surplus. A feasibility study undertaken by RPS Aquaterra identified four

options, which are presented in Table 80 along with the conclusions of the feasibility study.

Table 80: Surplus water disposal options

Water disposal option Feasibility study conclusions

Construction of a soakaway and / or evaporation pond There is insufficient space available on Block VI for the construction of soakaways and / or evaporation ponds.

Reinjection of the surplus water into the third aquifer some distance from Block VI.

Reinjection would require a large area of land away from the Block and its feasibility is unknown. The cost of reinjection would be considerable more than the cost of the original dewatering/depressurisation pumping. The long-term efficiency of a reinjection wellfield would not be guaranteed

Disposal of the water to a remote reservoir (yet to be constructed and the responsibility of the Government of Sindh), south of the block blocks adjacent to the Rann of Kutch.

This option would require a separate environmental and social impact assessment to be completed.

Utilisation of some water for agriculture either with or without treatment.

There is some scope for this option. An area of 84km2 could be irrigated based on the estimated dewatering rates. It was identified that irrigation would generated some return water which would require management.

Source: RPS Aquaterra, 2017

All mine floodwater for disposal to ground and thus to the Shallow aquifer will be pre-treated by

RO to reduce its salinity sufficiently to meet the NEQS.

The Project will use mine flood water as its main source of supply, but there is also a proposal

to bring surface water from the Indus River system by way of the Nara Canal, Chotiari

Reservoir, a new canal and pipeline, and a new reservoir (Vajihayr Reservoir). This long

distance transfer is small (0.85 m3/s) but any disposal to ground by the Project of waste water


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from this fresher water source will have an impact on the existing Shallow aquifer conditions

particularly in the non-monsoon period.

11.4.2.2 Water use – future situation

The coal mine project will resettle the inhabitants of the villages directly affected by the mine

workings. The resettlement will include provision of new, better quality water supply for domestic

use and for some agricultural uses (livestock watering). For the future baseline, it is therefore

assumed that there will be no communities depending on Shallow groundwater for domestic use

within the study area for the Project.



11.5.1.1 Overview

This section presents the identification and assessment of the following potential impacts of the

Project during the construction phase based on the description of the proposed construction

activities given in section 2.4. Construction impacts will include:

● Abstraction of water for construction camp and for use in construction (concrete batching

plant, vehicle washing, dust suppression, etc)

● Disruption of local drainage network by earthworks

● Mobilisation of sediment from earthworks and stockpiles to ephemeral surface water

features impacting water quality

● Contamination arising from inadequate treatment and disposal of waste and wastewater

from work compounds and yards

● Spillage of oils and chemicals, including cement, in relation to groundwater and surface

water

Temporary facilities for water supply and waste water treatment will be provided for the power

plant (see section 2.4) while the permanent works are being constructed and commissioned.

11.5.1.2 Water use by the Project during construction

Water will be obtained from the adjacent mine development – initially from a purpose drilled

borehole in the Deep aquifer and, from the end of year 1 or 2 of the mine development, from

dewatering wells and sumps. It is understood that the mine dewatering system will consist of

boreholes drilled to capture water from the Shallow, Middle and Deep aquifers – the proportions

coming from each aquifer will vary over time as the pit deepens. Except where it will be used for

dust suppression all groundwater will need to be treated before use because of poor water

quality (high salinity). Depending on the sequencing of construction activities at the mine and for

the Project it may be necessary to provide bottled water for the construction workforce for a

period before groundwater treatment is commissioned on site.

The mine will resettle local villages in Block VI providing them with an alternative water supply to

their existing use of the Shallow aquifer and ephemeral surface water bodies.

During the construction phase, the Project water requirement is expected to be smaller than the

dewatering volume necessary to allow development of the coal mine over the same period so

the mine will have to dispose of the excess. The Developer intends to install an early dewatering

well which would provide raw water for the mine and power plant and an RO plant to provide


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potable water for the mine accommodation. During the construction phase of the Project, there

will be some lowering of existing water levels in the Shallow aquifer close to the pit due to the

mine dewatering.

The Shallow aquifer is categorised as medium sensitivity, the magnitude of the impact

attributable to the Project during construction is negligible resulting in a negligible impact, which

is not significant.

The Middle aquifer is the most saline of the three and is categorised as low sensitivity, with a

negligible magnitude resulting in a negligible impact, which is not significant.

The Deep aquifer is a very large waterbody of relatively poor water quality as such it is

categorised as low sensitivity. During construction, abstraction from this resource is assessed to

be negligible magnitude resulting in a negligible impact, which is not significant.

Based on the findings of the mine ESIA (Hagler Bailly, 2013, Wardell Armstrong, 2016) the mine

activities within Block VI development are also deemed not to have a significant impact on water

resources during the period of construction for the Project.

11.5.1.3 Storm drainage and flood risk

Construction of the Project infrastructure will require earthworks that will change the micro-

topography and local drainage patterns which are generally aligned draining from northeast to

southwest. The temporary freshwater ponded areas have been classified into two types

depending on whether they have been modified by traditional water capture systems or are

natural. The former are treated as of higher sensitivity/value in the current baseline but are

considered medium when their role in community water supply is reduced by the mine

resettlement programme, the natural areas are categorised as low. The magnitude of

construction impacts on both types is considered to be minor. The resulting impact of

construction is a minor adverse impact for the natural areas and moderate adverse for

traditional water capture systems (and is therefore significant).

11.5.1.4 Contamination of shallow aquifer

During construction of the Project infrastructure, there is the potential for incidents leading to

contamination of the underlying Shallow aquifer. The main risks to water quality arising from

construction activities relate to direct discharges or potential spillage of fuels, lubricants,

concrete spills and chemicals from the construction site and the inadequate treatment and

disposal of waste and wastewater from work compounds.

The Shallow aquifer has been classified as a medium sensitivity/value receptor. The magnitude

of construction impacts is considered to be minor adverse, resulting in an minor adverse impact

and therefore is no significant.


The operation of the Project will include a number of activities that have the potential to impact

on the water environment. These include:

● Impact on water resources of supplying industrial and domestic water needs

● Discharge arrangements for storm water runoff

● Disposal of brines from RO plant, and disposal of waste water from industrial processes

where not recycled within the Project

● Acid leachate from fly ash dump


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● Disposal of sewage and domestic waste water (kitchens, laundry, etc)

● Fire fighting system and disposal of contaminated fire water after use

11.5.2.1 Operational water usage

The Project, as described in chapter 2, will have two sources of raw water:

● Groundwater abstracted from the Deep aquifer or delivered from the mine dewatering

system (and therefore coming from a combination of Top, Middle and Deep aquifers)

● Transfer from the Indus River via the Nara Canal, Chotiari Reservoir, and Vejhiar Reservoir

The main source will be groundwater based on a supply from the adjacent mine dewatering

system supported by direct abstractions. The water is saline and requires pre-treatment. The

proposed pre-treatment in the raw water treatment plant is RO. Water for domestic use is to be

further treated by activated carbon filtration and disinfection to meet drinking water standards.

During normal operation, the total consumption for the plant and associated domestic

requirements has been estimated as 1,861 m3/hr of which some 105m3/hr will be internally

recycled within the Project site leaving an operating water demand of 1,756m3/hr (0.49m3/s). A

consumption of 1,756m3/hr equates to 15 million m3 per annum. The raw water treatment plant

will have a capacity to treat 1,756m3/hr.

Table 81: Water balance for the Project in operation

No Item Water requirement (m3/hr)

Reclaimed water (m3/hr)

Water consumption (m3/hr)

1 Cooling tower evaporation loss 1,160 0 1,160

2 Cooling tower drift loss 38 0 38

3 Blowdown losses of cooling water system 349 63 286

4 Boiler make-up water treatment system 45 8 37

5 Water for oil area 2 1 1

6 HVAC system make-up 15 0 15

7 Vehicle wash water 3 2 1

8 Turbine house wash water 3 2 1

9 Boiler house wash water 3 2 1

10 Cooling water for hydrogen generator station 20 20 0

11 Moistening water for dry ash 20 0 20

12 Bottom ash system make-up water 10 0 10

13 Coal dust suppression 31 0 31

14 Spray water for ash disposal area 10 0 10

15 Raw water treatment plant 85 0 85

16 Industry waste water treatment system 1 0 1

17 Oily waste treatment system 1 0 1

18 Potable water system 10 7 3

19 Sanitary sewage treatment system 1 0 1

20 Greening water for plant area 6 0 6

21 Unforeseen consumption 48 0 48

TOTAL 1,861 105 1,756

Source: China Power, 2014


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The main use of water is for cooling. The design incorporates a natural draft cooling and

circulating system. The system is capable of circulating some 25m3/s. Evaporation losses from

the cooling towers are estimated to be 1,160m3/hr with an additional drift loss of 38 m3/hr. It is

estimated that a further 286m3/hr is lost to blowdown procedures, this is not lost to evaporation

but is separated such that 63m3/hr is recycled and the rest passed to the central monitoring

basin and waste outfall.

Process water will be recycled and a proportion diverted to the coal storage yard and ash

disposal area for dust suppression.

During the operation phase, cooling losses will account for 68% of the Project’s total

consumption or around 10 million m3/annum. This evaporation is a loss of water resources from

the three aquifers, however without detailed modelling of the mine dewatering as the pit

develops it is impossible to quantify the proportion of the Project raw water supply coming from

each of the aquifers at any particular time over the operational lifetime of the Project. During

monsoon rains the proportion coming from the Shallow aquifer will increase, with some

contribution from rainfall collected by the pit drainage system. In years when the monsoon fails

the Shallow aquifer will make a limited contribution.

The dewatering volume will increase over time as the open pit grows in size and is predicted to

result eventually in a cone of depression in groundwater levels extending up to 1km from the pit.

During the operation phase of the Project, water levels in the Shallow aquifer close to the pit will

be maintained at the minimum due to the mine dewatering. Arrangements for final disposal of

the mine and Project waste waters is yet to be determined by the Government of Sindh but if to

the Shallow aquifer, this would be over 1km away from and hydraulically down gradient of, the

pit.

The net change in aquifer volume would therefore still be relatively small compared to the

overall resource of the Shallow aquifer in the Thar Desert.


attributable to the Project during operation is minor and therefore the impact is assessed as of

minor significance and therefore is not significant.

The Middle aquifer is categorised as low sensitivity due to high salinity, with a negligible

magnitude on the regional aquifer the operation phase impact attributable to the Project is

assessed negligible and therefore is not significant.

The Deep aquifer is a very large waterbody of relatively poor water quality as such it is

categorised as low sensitivity. During operation, abstraction from this resource is assessed to

be negligible magnitude and the impact is assessed as negligible and therefore not significant.

Based on the findings of the mine ESIA (Hagler Bailly, 2013, Wardell Armstrong, 2016), the

Block VI development is also deemed to have an impact on water resources of minor

significance during the period of operation for the Project.

11.5.2.2 Disposal of waste waters

The main sources of waste water are:

● Brine from the RO plant processing the raw water supply from the mine

● Sewage effluent

● Drainage from the coal storage yard

● Wash water from various operations within the plant frequently contaminated by oils and

grease


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● Drainage from roads and hard standing including refuelling area

If these waste streams were allowed to discharge directly to ground and then into the Shallow

aquifer untreated there would a slight beneficial impact in terms of the net abstraction but an

adverse impact in terms of water quality. The Shallow aquifer is categorised as medium

sensitivity, the magnitude of the impact attributable to the Project during operation is moderate

adverse, resulting in a moderate adverse impact, and is therefore considered as significant.

Natural ephemeral surface waterbodies are categorised as having low sensitivity, the magnitude

is assessed as minor adverse resulting in a negligible impact, which is not significant.

As part of a strategic approach to the Thar Coalfield, the Government of Sindh and the Sindh

Engro Coal Mining Company are developing an effluent pipeline (capacity 50 Cusecs) is under

construction from Block II to a location some 32km to the south of Islamkot at Gorano where a

reservoir is being constructed to receive the waste water. There is no outfall planned for this

Reservoir. To date, it is understood that approvals are outstanding for the works but it is

expected that all blocks within the Coalfield will utilise this provision from the Government of

Sindh. The Government of Sindh, as developer of this infrastructure would be responsible for

understanding an assessment separate to this ESIA and obtaining the necessary approvals.

11.5.2.3 Potential pollution

A number of chemical processes are required in order to bring the raw water to the necessary

standard for different uses within the plant and for the treatment of waste water streams from

these different uses to prepare for recycling within the Project or for discharge. Some of these

chemicals are hazardous (eg hydrochloric acid, sodium hydroxide, hydrazine) and their storage

and handling presents a risk of a pollution incident that would affect the shallow aquifer beneath

the site.

The plant will generate large quantities of fly ash. Exposure to rainfall or to water applied for

dust suppression will lead to acid leaching of saline percolates and metals from the fly ash

deposits, this seepage could affect the quality of the underlying Shallow aquifer.

The plant has been designed with a comprehensive monitoring and fire response system. In the

event of a fire there is a pollution risk to the Shallow aquifer from the use of fire

retardant/suppression chemicals infiltrating the ground during and after fire incident.


attributable to the Project during operation is minor and therefore the impact is assessed as of

minor significance and not significant. Natural ephemeral surface waterbodies are categorised

as low sensitivity, the magnitude is assessed as minor adverse resulting in a negligible impact

and thus, not significant.

11.5.3 Decommissioning phase

On closure of the Project and closure of the mine, abstractions from the three aquifers would

cease and this would lead to a recovery in water levels in the previously dewatered area around

the pit.

Other potential impacts are similar to those in the construction phase and relate to possible

contamination during decommissioning and demolition works.

There is a potential for impacts to natural ephemeral surface water bodies and the Shallow

aquifer if the mine landfill or the fly ash deposit deteriorate once active management ceases

such that contaminated seepage can reach these receptors.


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11.5.4 Cumulative impacts

Other blocks have been identified for coal mining in the Thar Coalfield. The development of

these other blocks are individually likely to have impacts on the surface water and aquifer

systems similar to those of the mine and power station proposed for Block VI. How similar will

depend on the mining approach and power generation and cooling technologies chosen for

each block.

The three aquifers (Top, Middle and Deep) are regional in extent underlying the Thar Desert so

cumulative impacts are inevitable if all the blocks are developed. Much depends on the timing of

each block’s development and the period over which all six might be operating simultaneously.

The strategic studies for the That Coalfields have identified the need for a regional water

resources study with detailed groundwater modelling to allow cumulative impacts on water

resources to be assessed under different coal block development scenarios. The Government

of Sindh is preparing a water management plan for the Thar Coalfield. Their studies will

establish the baseline for all water resource across the whole area and then will model all new

developments to assess the cumulative changes in water use and potential impacts on water

resources both quantity and quality. The water management plan will contain all the measures

to be taken to minimise potential impacts area-wide.


11.6.1 Avoidance measures incorporated in project design

The design of the Project has taken into account issues of sustainable water management and

minimising flood risk in particular:

● Use of mine flood water (dewatering) as main source of supply

● The selection of closed-cycle cooling system with natural draft cooling towers over

alternatives (refer to chapter 3) to minimise water requirements

● Treatment of mine floodwater by reverse osmosis prior to use as process water and

domestic supply

● Dust from the two coal storage yards will be controlled by a permanently mounted water

sprinkler system using recycled process water

● Water drainage system including treatment will be provided in the coal yards and the ash

disposal facility

● Provision of Project sewage treatment plant and oily waste water treatment

● Provision of storm drainage ditches and infiltration areas to divert storm runoff away from

the Project site and maximise recharge to the Shallow aquifer away from the cone of

depression created by ongoing mine dewatering

Facilities incorporated in the Project design will ensure that all waste water to be discharged to

the natural environment meets the NEQS requirements. The Project drainage system will also

prevent the discharge of any contaminated runoff, whether from storm rainfall or from a fire

incident, to the environment without passing through the Project waste water treatment facilities.

The Government of Sindh has responsibility for the final discharge of waste waters from all

development blocks in the Thar Coalfield. Arrangements for disposal are not yet agreed for

Block VI. The Government of Sindh is proposing a 50 cusec capacity channel to take waste

water from the adjacent Block II towards the south, so potentially some or all of the Block VI

waste water could be disposed of via this channel.


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11.6.2 Generic mitigation measures

Best practice hazardous materials storage, handling and use will be employed in both the

construction and operation of the Project. This will include the following:

● Bunding of storage areas to contain any spills and provision of spill kits for clean up

● Vehicle and equipment fuelling to only be undertaken in designated areas on impermeable

surfaces with adequate spill protection in place

● Training of workforce on correct handling of hazardous materials and response in case of an

incident

Further details are given in the accompanying ESMP (Volume IV).


Monitoring is designed to:

● Provide the basis for ongoing impact management during the construction, operation and

decommissioning phases

● Involve assessment of compliance and adherence to environmental standards and

guidelines

● Establish the effectiveness of the prescribed mitigation measures and the occurrence and

magnitude of impacts

● Provide an `early warning ‘system for harmful trends

In particular, the monitoring is a requirement of the NEQ Self-Monitoring and Reporting by

Industry Rules (see section 11.2.1).

The Project includes a laboratory for chemical testing during the operation phase.

In the operation phase all discharges to the environment will be regularly sampled at the outlet

of the relevant waste treatment facility to confirm compliance with the NEQS. Where appropriate

the monitoring should be continuous, for example for pH and conductivity. For parameters

requiring laboratory analysis the sampling interval may range from daily to weekly.


Table 82 and Table 83 summarise the assessment with and without mitigation in the

construction and the operation phases.

Without mitigation, most of the Project’s impacts are considered to be not significant (minor and

negligible) because of the poor quality of the aquifer resources.

The most significant impact is that on the local villages whose fields and wells will be occupied

by the Project and the adjacent mine, however, as they will be resettled with a replacement

water supply which will be more reliable and better quality, the impact on their water use after

mitigation is assessed as being negligible and therefore not significant.

11.7.1.1 Construction phase

During construction water requirements for the Project will be low and met from several sources

in small quantities (bottled water, Deep aquifer borehole, dewatering from the Shallow and

Middle aquifers), and resettlement with replacement water supplies by the mine, will minimise

the overall impact. All potential construction impacts will be prevented and mitigated by the


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effective implementation of industry standard practices for safe environmental management and

pollution control on construction sites.

Consequently, the impact on water resources and flood risk attributable to the Project during the

construction phase is deemed to have a negligible significance. The impact from the Block VI

development is deemed to be not significant.

11.7.1.2 Operation phase

The Project has adopted water minimisation technologies and recycling for generation

processes and cooling leading to reduced raw water requirement. Supply is 1,756m3/hr of which

1,198 m3/hr will be lost by evaporation and drift from the cooling tower. Waste water treatment is

comprehensive and no discharges will be made to the ground or Shallow aquifer without prior

treatment to achieve NEQS standards. Hazardous waste such as brine from the RO plant will

be disposed of in the lined hazardous waste landfill to be built by the mine.


operation phase will have a minor adverse impact on the Shallow aquifer and therefore is not

significant .

11.7.1.3 Decommissioning phase

All potential decommissioning impacts will be prevented and mitigated by the effective

implementation of industry standard practices for safe environmental management and pollution

control on construction sites.


decommissioning phase is deemed to be not significant.


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Table 82: Summary of Project impacts on water resources and flood risk before and after mitigation

Receptor Potential impacts Sensitivity Impact magnitude

Impact evaluation

Mitigation Residual impact evaluation and significance

Construction

Shallow aquifer

The mine flood water supplied as raw water to the Project will contain some water from the Shallow aquifer

Medium Negligible Negligible None Negligible, not significant

Disposal of waste water into aquifer Medium Minor Minor Treatment to meet NEQS prior to disposal Negligible, not significant

Contamination caused by spills/leaks/fire incidents

Medium Minor Minor GIIP for incident response and clean up Negligible, not significant

Middle aquifer The mine flood water supplied as raw water to the Project will contain some water from the Middle aquifer

Low Negligible Negligible None required Negligible, not significant

Deep aquifer

Water supplied from the mine as raw water to the Project is largely drawn from the Deep aquifer

Low Negligible Negligible None Negligible, not significant

Disposal of waste water into aquifer Low Negligible Negligible Treatment to meet NEQS prior to disposal Negligible, not significant


Loss of sites – built over or cut off from storm runoff by new diversion channels

Low Moderate Minor Construct new drainage channels and infiltration areas to divert storm runoff around the Project site and to maintain recharge to Shallow aquifer and continue provision of pools for wildlife and livestock watering.

Negligible, not significant

Disposal of waste water Low Minor Negligible On site drainage designed for complete separation of clean storm water and waste water. Treatment of waste water to meet NEQS prior to disposal.



Low Minor Negligible GIIP for incident response and clean up Negligible, not significant



Medium Moderate Moderate Village resettlement and provision of compensatory replacement water supply by the mine mean loss of any such systems on the Project site is either fully addressed by the mine mitigation or will be compensated by the Project.


Source: Present study


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Table 83: Summary of Project impacts on water resources and flood risk before and after mitigation

Receptor Potential impacts Sensitivity Impact magnitude

Impact evaluation

Mitigation Residual impact and significance

Operation

Shallow aquifer

The mine flood water supplied as raw water to the Project will contain some water from the Shallow aquifer

Medium Minor Minor None Minor, not significant

Disposal of waste water into aquifer

Medium Moderate Moderate Treatment to meet NEQS prior to disposal Negligible, not significant


Medium Minor Minor GIIP for incident response and clean up Negligible, not significant

Middle aquifer The mine flood water supplied as raw water to the Project will contain some water from the Middle aquifer

Low Negligible Negligible None required Negligible, not significant

Deep aquifer

Water supplied from the mine as raw water to the Project is largely drawn from the Deep aquifer

Low Minor Negligible None Negligible, not significant

Disposal of waste water into aquifer

Low Minor Negligible Treatment to meet NEQS prior to disposal Negligible, not significant



Low Moderate Minor Construct new drainage channels and infiltration areas to divert storm runoff around the Project site and to maintain recharge to Shallow aquifer and continue provision of pools for wildlife and livestock watering.


Disposal of waste water Low Minor Negligible On site drainage designed for complete separation of clean storm water and waste water. Treatment of waste water to meet NEQS prior to disposal.



Low Minor Negligible GIIP for incident response and clean up Negligible, not significant



Medium Moderate Moderate Village resettlement and provision of compensatory replacement water supply by the mine mean loss of any such systems on the Project site is either fully addressed by the mine mitigation or will be compensated by the Project.


Source: Present study


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12 Landscape and visual

12.1 Overview

This chapter considers the potential landscape and visual impacts associated with the

construction and operation of the Project. The purpose of the landscape and visual assessment

is to recognise, understand and interpret the character and value of the landscape setting of the

Project. The assessment identifies the predicted impacts of the proposed project design on the

landscape resource and views and assesses their significance.

12.2 Assessment methodology

Landscape and visual impacts associated with the Project which could potentially result in

effects on sensitive receptors, have been assigned significance based on the overarching

framework presented in chapter 5. Specific magnitude and sensitivity criteria for landscape and

visual impacts are presented in Table 84 to Table 86.

The methodology for the landscape and visual impact assessment (LVIA) was developed using

the IUCN guidance document “Environmental Impact Assessment Guidance for Coal Fired

Power Plants in Pakistan” (EIAG) published in 2014 and ‘Guidelines for Landscape and Visual

Assessment’ (GLVIA) produced by the Landscape Institute (LI) and Institute of Environmental

Management and Assessment (IEMA) in 2013 (Third Edition) which is recognised as good

practice.

This assessment is based on the review of existing mapping, field surveys, baseline site

photography and aerial imagery.

12.2.1 Landscape

The baseline study identified the existing character of the landscape, its constituent elements,

features and its geographical and historical context. It assesses the condition of the landscape,

the way it is experienced, the value attached to it and its susceptibility to change.

The evaluation of the sensitivity of the landscape resource is based on factors and attributes

which affect the value of the landscape and its susceptibility to the type of change arising from

the proposed development. These criteria are set out in Table 84.

Table 84: Landscape sensitivity criteria

Sensitivity Criteria Examples

High National designation or importance Protected landscape recognised by international and national designation, reflecting aesthetic, cultural or religious significance. A landscape with high wilderness quality and limited human activity. A high susceptibility to change due to the type of development proposed.

Medium Regional – locally important landscapes or features

Areas of open landscape with some human activity evident. Regionally or locally important, may be designated reflecting aesthetic, cultural or religious significance. A moderate susceptibility to change due to the type of development proposed.

Low Common or degraded landscapes Areas of urban influences or uncontrolled development in the landscape. A low susceptibility to change due to the type of development proposed.

Source: Mott MacDonald 2016


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12.2.2 Visual amenity

In accordance with the outline methodology in GLVIA, the baseline study identifies the people

who might be affected by the Project within the study area. The sensitivity of different visual

receptors varies according to the interest they take in their visual environment, their distance

from the site, viewing opportunity and the duration of the view. Visual receptors are categorised

into groups reflecting their proximity to the site and viewers’ expectations, as set out in below

Table 85.

Table 85: Criteria for assessing visual sensitivity

Visual receptors Sensitivity

Residents of local settlements with direct views towards the Project area. Visitors to internationally and nationally recognised landscapes, cultural and religious sites

High

Local people working in predominantly outdoor occupations (such as farmers or herders). Residents of local settlements with partially screened views towards the Project area.

Medium

Travellers through the area Low


12.2.3 Identification of potential impacts

Impacts on the landscape resource may arise from changes to overall landscape character or to

individual elements or features. Factors that may affect the magnitude of change to the

landscape resource and visual amenity include:

● The extent of the loss of existing landscape elements and change to the view due to the

loss/addition of features

● The degree to which aesthetic or perceptual aspects of the landscape are altered by the

introduction of new landscape components

● The scale and appearance of the proposed power plant and the degree of

contrast/integration with the existing view

● The scale of the geographical area affected by the Project

● The distance of the visual receptor from the development and the angle/position of view

● The duration and reversibility of the impact

The impact magnitude criteria are identified in Table 86.

Table 86: Landscape and visual magnitude criteria

Magnitude Criteria

High Total loss or fundamental alteration to key landscape elements and key views and/or addition of new features that substantially alter the character of the landscape, visual amenity and views.

Medium Partial loss or alteration to key landscape elements and key views and/or addition of new features that form prominent new elements that are largely characteristic of their setting, but alter the character of the landscape, visual amenity and views.

Low Minor loss or alteration to landscape elements and key views and/or addition of new features that form largely inconspicuous elements in the landscape, resulting in a detectable change in the character of the landscape, visual amenity and views.

Negligible No change to, or very minor loss of landscape elements and key views and/or additions of new features that do not alter the character of the landscape, visual amenity and views.



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12.2.4 Significance of impacts

In accordance with the outline methodology in GLVIA, effects are evaluated by combining the

assessment of both magnitude and sensitivity and by using the impact evaluation matrix

presented in Table 87. This impact evaluation matrix has been adapted for the LVIA and is

based on the matrix included in chapter 5. Those effects that are moderate or major are

significant effects. Impacts are beneficial, adverse or neutral.

Table 87: Impact evaluation matrix adapted for the LVIA



12.2.5.1 Assumptions concerning the baseline environment

Where appropriate, visual receptors were grouped rather than identified individually for the

purposes of the assessment.

It has been assumed that the Kharo Jani settlement will have been resettled prior to the

commencement of construction activities for the Project.

12.2.5.2 Assumptions concerning the prediction of impacts

In quantifying impacts, the assessment process aims to be as objective as possible. However,

whilst in some instances changes to a view can be factually defined, or direct loss of features

quantified, the evaluation of landscape character and visual impact frequently requires

qualitative judgements to be made. This is generally considered acceptable if based on

'professional expertise', supported by clear evidence, reasoned argument and informed opinion.

The conclusions of this assessment combine objective measurement with informed professional

interpretation.

12.2.6 Area of influence

The modeled zone of theoretical visibility (ZTV) was used to establish the spatial scope of the

study area and as a tool for assessing the visual impact following both EIAG and GLVIA

guidelines. The ZTV is defined as the approximate area from which the Project will be

theoretically visible from the eye level of a person standing on the ground. The ZTV was

generated using a viewshed analysis generated by modelling the potential visibility of the

Project elements within a 30km radius from the Project. This approach is based on best practice

Se

ns

itiv

ity

Magnitude

Adverse Beneficial

High Medium Low Negligible Low Medium High

High Major Major/

Moderate

Moderate/

Minor

Minor/

Negligible

Moderate/

Minor

Major/

Moderate Major

Medium Major/

Moderate Moderate Minor Negligible Minor Moderate

Major/

Moderate

Low Moderate/

Minor

Moderate/

Minor

Minor/

Negligible Negligible

Minor/

Negligible

Moderate/

Minor

Moderate/

Minor

Negligible Minor Minor/

Negligible Negligible Negligible Negligible

Minor/

Negligible Minor


366982 | 02 | B | March 2017

guidance for assessing the visual impact of tall elements in the landscape from Scottish Natural

Heritage33. As the viewshed analysis was based on the ‘Bare Earth Model’ it is recognised that

the initial ZTV will define a more extensive area of theoretical visibility than would be

experienced in the field as built elements and existing tree cover will screen some views.

The south west – north east alignment of the prominent sand dunes contains the theoretical

visibility of the Project as indicated in the ZTV illustrated in Figure 35. The ZTV was modelled

using ESRI’s ArcGIS for Desktop ArcMap 10.4 Application. A viewshed analysis was

undertaken using the visibility tool in ArcMap. Each cell or pixel within the raster digital terrain

Model (DTM) is assessed for visibility to each point feature of a structure and is given a value

representing the number of points it can see. The result is a colour map of areas where

structures are predicted to be visible or not. The data used for the analysis is the SRTM Global

1 Arc-Second dataset. The analysis carries assumptions as follows:

● Bare Earth Model was used - topography of the underlying terrain without trees, buildings, or

other features

● 30km Visible Range - the distance at which visibility modelling has been considered

sufficient and stopped

● Observer Height at 1.5 metres -the assumed average eye-level height of an observer.

● Refractivity Coefficient 0.13 -The coefficient describing the light refracting properties of the

atmosphere

● Curved Earth - the model accounts for the curvature of the earth

Point Features - the structure outlines are represented by points along their footprint with 5m

spacing. Structures are assumed to have flat tops

12.2.7 Temporal scope

The temporal scope of the assessment assesses site preparation and construction of the

Project (both assessed under the ‘construction’ phase which is expected to be approximately 40

months in total) and operation which will be for a minimum of 30 years. The base case year is

assumed to be 2017.


12.3.1 Overview

This section presents the baseline characterisation of the landscape and visual amenity of the

Project area to enable comparison of the current situation with changes anticipated to the

landscape character and visual amenity of the area as a result of the Project. Key sources of

baseline information include a number of secondary resources, including studies undertaken for

the Block VI mine and the plant in Block II. In addition, aerial photography has also been used

to inform the assessment. A field survey was undertaken by a Mott MacDonald specialist to

supplement and support the secondary data. No landscape character assessment data is

available at national, regional or local level.

There are a number of small villages and settlements throughout the Project study area located

both inside and outside Block VI. Located within Block VI are the small villages of Salar Ji

Dhani, Gangoo Ji Dhani, Yousuf Ji Dhani, Yaqoob Ji Dhani, Kharo Jani and Ranjho Noon.

There are two larger villages in Block Vl – Kharo Jani with a population of 1,200 lies just

northwest and Ranjho Noon, with 1,400 people is in the southwest corner of Block VI. However,

33 Visual Representation of Windfarms Good Practice Guidance, 29 March 2006 – note currently under review.


366982 | 02 | B | March 2017

Kharo Jani is expected to be resettled as a result of the mine activities within Block VI. Just

outside Block VI are the villages of Jadhe Dhani, Bhitro Bhill, Singharo, Sanalba, Kanhea Ji

Dhani, Mangu Bheel, Mehun Linju and Munhan Tar. The Project location and settlements are

illustrated in Figure 23.


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Figure 23: Project location and settlements in Block VI

Source: Mott MacDonald Pakistan Ltd


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12.3.2 Landscape and visual baseline

The Project site is located in the southeast corner of the Sindh Province of Pakistan at the Thar

Desert area in Block VI adjacent to Block II coalfield and covers an area of approximately

66km2. Block VI is situated approximately 380km northeast of Karachi, 20km northeast of

Islamkot and 77km east of Mithi. There are a number of local roads that enter the desert from

the city of Mithi and the town of Islamkot leading to the Project site, the most significant is the

S71004 road from Islamkot.

Block VI is situated within the District of Tharpakar which is a sub-district of Mithi. Two main

villages Ranjho Nun and Kharo Jani are located within Block VI, with other small villages located

in and around Block VI.

The study area is in a desert location with sand dunes that extend up to 3km in length and

200m in height above sea level. The dunes are set in a wider partially cultivated plain and the

relative height varies between 20m and 55m above the plain. The younger dunes are a dynamic

system, in continual motion and take on changing shapes and sizes. Older dunes however are

in a semi-stabilised condition. Playas (saline lake beds), locally known as dhands, are scattered

throughout the southern region of the district. Tree/scrub cover is sparse but typically present

along the dunes and the plain is largely cultivated. The nucleated settlements consist largely of

mud and thatch dwellings located between the dunes.

Sindh Province has approximately 1,310,000 hectares of protected areas which, includes the

Kirthar National Park, located in Karachi and Jamshoro District. Given the distance of this

national park from the Project site, it is not considered further in this assessment. The Sindh

Wildlife Department is planning to establish Karoonjhar Hills National Park that will include

whole of the Tharparkar District and some parts of Badin and Thatta districts.

The Rann of Kutch was declared a RAMSAR site under the Convention on Wetlands of

International Importance and is particularly noted for its waterfowl habitat. Within the district, this

extends from Nagaparker in the southeast to the western boundary and northwards as far as

Diplo, including the southern section of the wider coalfields.

A parallel area to the north of this, which includes Mithi and Islamkot, has also been declared a

Wildlife Sanctuary by the Government of Sindh under Clause 14 of the Sindh Wildlife Ordinance

1972. This includes the four most southerly designated coalfield blocks. The designated sites

are indicated in Figure 24 below.


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Figure 24: Natural Habitats in Sindh Province

Source: MM Pakistan (Pvt) Ltd (September 2012) Fauna Report - Thar Coal, Section II Biological Baseline: Fauna

Survey


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Figure 25: Key settlements in Block VI



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12.3.3 Landscape character

Tharparkar and its surroundings have a rich past, with indigenous culture, customs and

traditions mostly dating back to the Buddhist and Jain period. The district contains a large

number of sites of archaeological, cultural, historical and religious significance. Some of the

prominent sites are:

● Thario Halepoto (6km from Block VI boundary) – the site is located at Islamkot near the

proposed Thar coalfield. The ruins date back to the Buddhist period (unprotected)

● Ruins of Paari Nagar (65km from Block VI boundary) – the ruins at Paari Nagar comprise

Jain temples and settlements near Nagar Parkar town (unprotected)

● Gori Temple – a Jain temple in Nagar Parkar taluka of Thar Parkar (unprotected)

These sites fall outside the modelled ZTV and are not considered further in this assessment.

The Project area is characterised by mostly desert and consist of sand dunes covered with

thorny bushes. The undulating dunes are separated by sandy plains and low barren hills, which

rise abruptly from the surrounding plains. The ridges are irregular and roughly paralleled often

enclosing sheltered valleys, above which they rise to a height of up to 55m. These valleys are

moist enough to allow cultivation and when not cultivated they yield crops of rank grass.

The only mountains in the district are in Nagarparkar on the northern edge of the Rann of Kutch.

Karoonjhar Mountains form the 19km long principal range and rise to a height of 305m. Smaller

hills rise in the east, which are covered with sparse tree cover and grassland. There are no

rivers or streams in Tharparkar district, except, two perennial springs named Achleshwar and

Sardharo, and two non-perennial streams known as Bhetiani and Gordhro River. The Rann of

Kutch is a large flat land in the south of Tharparkar district. It is almost at sea level with a

number of salt lakes (thick layers of salt are formed in these lakes).

Thar is one of the most densely populated deserts of the world with over 91,000 inhabitants.

Approximately ninety five percent (95.65%) of the population in Tharparkar district is classified

as rural and 4.35% as urban. The urban population is located in three main towns ie Mithi,

Islamkot and Diplo.

The wider landscape surrounding the Project site has a largely homogenous character

consisting of sand dunes with sparse tree cover, cultivated plains and scattered settlements. A

single character area has been defined:

● Settled desert landscape character area (LCA) – This LCA is characterised by an open

landscape with areas of small scale agricultural cultivation and sparsely vegetated dunes.

Settlements are in harmony with the landscape, located between the large dune formations

with locally sourced building materials - typically mud and thatch. The overall condition of the

landscape is good, with little evidence of detracting elements. The LCA is not a protected

landscape. The LCA has a medium sensitivity to change.

The photographs in Figure 26 to Figure 31 illustrate the typical landscape of the LCA.


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Figure 26: Settled desert LCA Figure 27: Settled desert LCA

Source: Mott MacDonald 2016 Source: Mott MacDonald 2016

Figure 28: Jusuf Ji Dhani village Figure 29: Security hut near Jusuf Ji Dhani village illustrating typical building materials


Figure 30: Kharo Jani village Figure 31: Jusuf Ji Dhani village



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12.3.4 Visual amenity

The visual baseline study identified a limited number of potential visual receptors (people with a

view of the Project). The topography within the study area is characterised by the presence of

the stabilised dunes which contain and screen views from the plain areas immediately adjacent.

Long views within the study area are possible across the top of the dunes, from the areas where

dunes are lower and from the areas where there is little screening vegetation.

Residents living within the study area, people using the local roads and local people working

and walking in the landscape are potential visual receptors. These are listed with an

assessment of their sensitivity in Table 101. The location of the villages is presented in Figure

26.

Figure 32: View from Jadhe Dhani looking south west towards the Project site



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Table 88: Visual receptors

Receptor View Approximate distance from site

Sensitivity

Residents of Jadhe Dhani (see Figure 33)

The village is located on at the western end of sand-dune valley with open cultivated land to the north and west. The land is relatively flat and sparsely vegetated. Open direct views to the Proposed site.

3km High

Residents of Bhitro Bhill (see Figure 34)

This village is located within a wide, relatively flat area of scrub. Open cultivated land to the north and south of the village and the scrub extends to the east and west. Views north-west (towards the Project site) are largely screened by the undulating sand-dune in the foreground.

5km Medium

Residents of Kharo Jani

Village to be resettled therefore not included in the baseline or assessment.

2.5km N/A

Residents of Singharo

Two large dunes sit between the village and the Project site. The Project would be screened and the receptor is not considered further

6km Low

Residents of Ranjho Noon

Ranjho Noon is a larger village located on the S71004 road to the west of the proposed site. The village sites within an area of flat cultivated land with sand-dunes to the east. The vegetation around the village is more sparse than that found within the sand-dune valleys closer to the proposed site.

The Project would be screened and the receptor is not considered further

5.5km Low

Residents of Mangu Bheel

Two large dunes sit between the village and the Project site. The Project would be screened and the receptor is not considered further

6km Low

Residents of Yaqoob Ji Dhani

This village sits at the foot of a relatively gently sloping dune with open cultivated land to the north. Views to the east (towards the Project site) are largely screened but from the higher part of the village, direct views are possible.

2km High

Residents of Yusuf Ji Dhani (see Figure 35)

The village sits on the western end of a dune. Views to the south (towards the Project site) are largely screened by the dune.

1.5km High

Residents of Gangoo Ji Dhani

This village sits at the entrance to a low sand-dune valley with farmland cultivated land to the north and west. Abundant tree and shrub vegetation is present within the valley and the undulating sand-dune topography partly screen some views from this receptor to the Project.

1.5km High

Residents of Salar Ji Dhani

This village sits at the foot of a low sand-dune valley with farmland to the north and west. Tree and shrub vegetation within the valley and the undulating sand-dune topography screen views to the Project site. Abundant tree and shrub present within the valley and views from this receptor to the proposed site are largely screened by undulating sand-dune topography.

2km Low

Residents of Munhan Tar

This village is located on the northern edge of a wide area of cultivated land, with undulating sand-dunes to the north. Views south to the proposed Project site are across the open farmland in the foreground but framed by sand-dunes further the south.

3.5km Medium


Ranijo Noon is a larger village located on the S71004 road to the west of the proposed site. The village sites within an area of flat farmland with sand-dunes to the east. The planting around the village is more sparsely planted than that found within the sand-dune valleys closer to the proposed site.

Views from this receptor towards the proposed site are obscured by topography and existing vegetation within the dune valleys.

6km Low



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Figure 33: View from the dune immediately to the west of Bhitro Bhill village looking west towards the Project site – the village is on lower ground behind the dune


Figure 34: View from the dune immediately south of Yusuf Ji Dhani looking south east towards the Project site



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12.4 Likely impacts and assessment of significance

12.4.1 Overview

This section identifies and assesses the potential beneficial and adverse landscape and visual

impacts of the Project during construction and operation. The IUCN guidance document

“Environmental Impact Assessment Guidance for Coal Fired Power Plants in Pakistan”

published in 2014 outlines the following elements as potential impacts. These have been

considered within the following assessment:

● Impacts on visual resources and landscapes;

● Impacts on visibility

● Increases in light contamination.

Landscape and visual impacts will arise during construction from:

● The removal of vegetation within the footprint of the power plant and the construction site

● The presence of temporary construction compounds and plants

● Construction activities associated with the Project and associated infrastructure

● Vehicle movements including large machinery such as cranes

● Presence of artificial lighting

● Demolition of residential properties, other buildings and bridges

● The movement of excavated earth and changes in the landform on site

● Loss of tranquillity in the surrounding landscape

Landscape and visual impacts will arise during operation from:

● The presence of the power plant and 2 x 330MW generation units and 210m exhaust stack

● The presence of the coal yard

● Access roads within Block VI

● The presence of on-site accommodation, office facilities, fire station, workshop and open

materials storage area

● Emissions generated from combustion and from the water vapour plume caused by the

cooling towers

● Presence of artificial lighting

● The permanent loss of vegetation within the footprint of the development

Measures to mitigate the likely adverse impacts and provide enhancements for landscape and

visual amenity are discussed in section 12.5. This assessment is based on the findings of the

site visit undertaken in 2016. However, the Project would be realised with the context of the

zoning of the whole area for industrial development associated with the Thar coalfields

developments. The mitigation measures discussed are focussed and proportionate to the likely

significant effects associated with the Project in this industrial context.


12.4.2.1 Landscape character

Construction activity, including construction traffic on local roads, will decrease levels of

tranquillity. The presence of large scale earthworks, construction plant including cranes,

generators and other equipment, storage areas and artificial lighting will introduce incongruous

urbanising elements into a rural landscape setting. The presence of construction activities,


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although temporary in nature, will result in a partial alteration to key landscape elements of the

settled desert landscape LCA and introduce structures which will form prominent new elements

within the landscape. The magnitude of change is considered to be medium. Given the medium

sensitivity of the landscape and medium magnitude of change, the predicted effects of the

construction works will be moderate adverse on landscape character and therefore significant.

12.4.2.2 Visual amenity

The activities associated with the construction of the Project will be visible to the settlements

extending from the villages of Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Jadhe

Dhani on the north west and northern border of Block VI and Munhan Tar to the west. Cranes

and construction associated with the taller Project elements will be noticeable from the closer

settlements given the undeveloped landscape setting. The plant and machinery including tall

cranes, compounds, storage areas, new roads and construction traffic will be visible from

nearest settlements, as discussed in Table 89


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Table 89 and from the ridges of the nearby dunes.

Potential intrusive light sources from night time working during the construction period would

represent a substantial change from the existing domestic scale lighting in the settlements but

may be influenced by future developments in the Thar Coalfield blocks.

Although temporary in nature, the construction works will introduce prominent new elements into

local views resulting in major adverse impacts or receptors in Jadhe Dhani, which is a significant

impact.


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Table 89: Summary of significance assessment of potential impacts on visual receptors – construction phase

Potential Impact

Receptor Magnitude Sensitivity Impact Evaluation Impact significance (prior to mitigation)

Construction lighting

Cranes and construction activities

Residents of Jadhe Dhani

High High Construction activities would be prominent in the view. Additionally, ‘sky glow’ and potentially glare from artificial lighting when used will represent new features that form prominent new elements effecting visual amenity and views

Major adverse – significant



Residents of Bhitro Bhill

Low Medium The sand dune formation would largely screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views

Minor adverse – not significant




Low High The sand-dune formation will largely obscure views of construction activity. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. Direct views from some outlying dwellings towards the Project may be possible. There will be a detectable change in visual amenity and views.




Residents of Yusuf Ji Dhani

Low High The sand dune formation would largely screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views.





Low High The sand dune formation would largely screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views.





Low Low The sand dune formation would largely screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views.





Medium Low The distant sand dune formation would largely screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views.





Low Low The distant sand dune formation would partly screen the construction activities. However, tall plant such as cranes and potentially ‘sky glow’ from artificial lighting when used will be visible. There will be a detectable change in visual amenity and views.




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12.4.3.1 Landscape character

The Project built elements comprises two cooling towers up to 130m in height, a crusher house

35m tall, boiler house 70m tall and turbine hall 35m in height, extensive areas for ancillary

facilities including coal storage areas and a 210m stack. The key components of the Project at

the site include:

● Coal yard

● 2 x 330MWe generation units

● One 210m exhaust stack

● Cooling water system

● Ash yard (temporary storage)

● Ash disposal area (within Block VI)

● Access roads within Block VI

● On-site accommodation, office facilities, fire station, workshop and open materials storage

area.

During the operational phase, the plume from the stack and steam from cooling towers will be

also evident in the wider landscape. The Project and especially the stack will constitute a focal

point within the open landscape of the desert.

The presence of the Project introduces large scale, urbanising elements that will be incongruous

in a rural landscape resulting in a change in landscape character of the area. Existing built

elements are inconspicuous in the wider landscape where the scrub covered dunes are the

dominant features. Due to the large scale of the new structures, the Project elements will be

prominent elements in the landscape. The landscape is considered to have some capacity to

accommodate change due to the presence of the strong dune formations and the absence of

recognised landscape designations. The Thar Coalfield area has been zoned for industrial use

and the Project would be realised in the context of associated developments.

The magnitude of change is considered to be medium resulting from the addition of new

features that will be prominent new elements in the landscape that alter its character. Overall,

given the medium sensitivity of the local landscape and medium magnitude of change, impacts

are considered to be moderate adverse and therefore significant.

12.4.3.2 Visual amenity

The ZTV shown in Figure 35, which has modelled on the operational footprint of the Project

illustrates the ZTV indicating theoretical visibility of the power station buildings, cooling towers

and stack. The strong dune landform, rising out of the relatively level plain formation, will limit

the visibility of the low level Project elements. Taller Project elements including – cooling towers,

and stack will be noticeable elements from the closer settlements, given the undeveloped

landscape setting and over a wider area up to 10km from the site and extending potentially to

20km to the north and east. It should be noted that the ZTV uses a ‘bare earth model’ such that

the extent of theoretical visibility will over estimate what will be experienced in the field through

the presence of screening elements. provides a summary of the impacts on visual amenity

during the operational phase.


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Figure 35: ZTV indicating theoretical visibility of the buildings and cooling towers



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Table 90: Summary of significance assessment of potential impacts on visual receptors – operational phase

Potential Impact

Receptor Magnitude Sensitivity Impact Evaluation Significance (prior to mitigation)

New large buildings and stack

Plume from stack and cooling towers


High High Addition of new features that form prominent new elements effecting visual amenity and views. Additionally, ‘sky glow’ and potentially glare from artificial lighting when used will represent new features that form prominent new elements effecting visual amenity and views





Medium Medium

The majority of the power plant structures will be screened by the dune in the foreground. Tall elements such as the cooling towers, stack and associated plumes will form new features that form prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views

Moderate adverse – significant




Medium High The majority of the power plant structures will be screened by the dune in the foreground. Tall elements such as the cooling towers, stack and associated plumes will form new features that form prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views





Medium High The majority of the power plant structures will be screened by the dune in the foreground. Tall elements such as the cooling towers, stack and associated plumes will form new features that form prominent new elements in the view. Additionally, ‘sky glow’ from artificial lighting may affect views





High High The proximity to the site and scale of development will result in the addition new features that substantially alter the visual amenity and views. Additionally, ‘sky glow’ and glare from artificial lighting may affect views





Low Low The sand dune formation in the foreground would largely screen the power station buildings. However, tall elements including the stack and plume may be visible together with potential ‘sky glow’ from artificial lighting when used.





Medium Low The distant sand dune formation would partially screen the lower elements. However, tall plant including the cooling towers and the stack and plume will be visible. Potentially ‘sky glow’ from artificial lighting when used will be visible.





Low Low The dune formations will largely screen the Project and only the stack, associated plume and potentially ‘sky glow’ from artificial lighting will be detectable in the view.



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12.4.3.3 Summary of impacts

A summary of the potential impacts during construction and operation on landscape character is

shown in Table 91.

A summary of the potential impacts during construction on visual receptors is shown in Table

89. The residents of one of the closest settlements to the Project, Jadhe Dhani will have

relatively open views towards the construction activity which together with potential intrusive

light emmissions from artificail sources will form promient new elements in the view. Other

settlements would be partially screened by the presence of interveining dune formations.

However cranes and construction activities associated with the taller structures would be visible

above the dunes.

A summary of the potential impacts on visual receptors during the operational phase is given in

Table 90. Residents in the closest settlements of Jadhe Dhani, Yaqoob Ji Dhani, Yusuf Ji Dhani

and Gangoo Ji Dhani have relatively open views towards the Project. Jadhe Dhani residents

would have the most unimpeded views towards the Project. The addition of new features would

form prominent new elements effecting visual amenity and views. ‘Sky glow’ and potentially

glare from artificial lighting, when used, could be potentially intrusive.

Table 91: Summary of significance assessment of potential impacts on landscape character

Potential Impact

Receptor Magnitude Sensitivity Impact Evaluation Significance

Construction phase

Construction lighting, cranes, buildings and activities

Settled desert landscape

Medium Medium New and uncharacteristic elements in the landscape that will alter the landscape character


Operational phase

New large buildings including the stack and cooling towers


Medium Medium New and uncharacteristic elements in the landscape that will alter the landscape character



Table 92 provides a summary of mitigation and enhancement measures for impacts identified in

this assessment. The buildings and structures of the Project will be large scale. It is therefore,

not possible to screen these due to their size and the relative openness of the surrounding

landscape. However, Table 92 identifies areas where mitigation measures are proposed to

alleviate, to some extent, the potentially significant impacts.


Residual impacts are those significant impacts that remain after the application of mitigation

and/or enhancement measures. A summary of impacts considered significant after application

of all mitigation and/or enhancement measures included in Table 92 is presented in Table 93.


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Table 92: Mitigation and enhancement measures for impacts on landscape character and visual amenity

Type of Measure Impacts mitigated or enhanced

Detail

Construction

Land take Impacts on landscape character and visual amenity

Minimise the amount of land take required.

Traffic management Impacts on landscape character and visual amenity

Maintaining strict requirements for vehicles to remain on roads at all times. Management through a traffic management plan.

Lighting Impacts on landscape character and visual amenity

Site lighting should be restricted outside normal working hours, to levels acceptable for safe working conditions.

Where temporary lighting is required outside of normal working hours, this should be task focussed, down lit and shielded to reduce light spill and background sky glow.

Programming and management

Impacts on landscape character and visual amenity

Tracks or temporary site roads should be constructed at the beginning of the construction period to minimise disturbance of other ground. Movement of vehicles should be confined to these routes to avoid soil compaction.

Reinstatement Impacts on landscape character and visual amenity

Reinstate vegetation where construction areas and access tracks are no longer required.

Design considerations Impacts on landscape character and visual amenity

In line with guidance in the EIAG:

● Locate facilities to take advantage of both topography and vegetation as screening devices.

● Design and locate structures and roads to minimise and balance cut and fill.

● Low-profile structures should be chosen whenever possible to reduce their visibility.

● Design facilities, structures, roads and other Project elements to match and repeat the form, line, colour and texture of the existing landscape.

● Design natural looking earthwork berms and vegetative or architectural screening where screening topography and vegetation are absent.

● Paint grouped structures the same colour to reduce visual complexity and colour contrast.

● Plant vegetative screens to block views of facilities.

Operation

Lighting Impacts on landscape character and visual amenity

In line with guidance in the EIAG, illumination of the Project and its immediate vicinity should be minimised by including use of motion detectors or other controls to have lights turned off unless needed for security or safety.

If lighting is required, this should be task focussed, down lit and shielded to reduce lighting overspill and background sky glow.

Design development Ensure that the design development of the facility aims to reduce the overall bulk and scale of the built elements for example accommodating facilities into smaller buildings rather than a single large unit and incorporating a more articulated building profile

The lower parts of the Project buildings and ancillary structures should be painted in neutral colours representative of the surrounding landscape – ie shades of sandy browns and greys. Surfaces should be a matt finish to reduce the reflection of sunlight.



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Table 93: Residual impacts

Likely impact Receptor Magnitude Sensitivity Impact evaluation Residual impact evaluation

Statement of significance

Landscape

New large buildings, stack and plumes


Medium Medium The Project will introduce large scale, new elements in the landscape that will alter the landscape character. Mitigation measures through sensitive design will reduce the impacts of the development but for operational considerations, the scale is likely to be relatively unchanged.

Moderate adverse

Significant

Visual amenity

New large buildings and stack in views

Plume in views


Medium High Due to operational considerations, the scale of the cooling towers and stack are likely to remain unchanged. Controlling light pollution will have a positive effect. Screening is unlikely to be effective given the scale of the Project elements, however, screening planting close to the village could offer some screening and filtering of views with potential benefits of a managed fuel source if suitable conditions are present.

Moderate adverse

Significant


Plume in views


Low Medium Controlling light pollution will have a positive effect. Screening is unlikely to be effective given the scale of the Project elements, however, enhancing existing scrub along the dune formation close to the village could offer some screening and filtering of views.

Minor adverse Not significant


Plume in views


Medium High Controlling light pollution will have a positive effect. Orientation of built elements and design of the structures could reduce the apparent bulk of the development. Screening is unlikely to be effective given the scale of the Project elements.

Moderate adverse

Significant


Plume in views



Moderate adverse

Significant


Plume in views



Moderate adverse

Significant


Plume in views


Low Low Controlling light pollution will have a positive effect. Enhancing existing scrub along the dune formation close to the village could offer additional screening



Plume in views


Medium Low Controlling light pollution will have a positive effect. Screening is unlikely to be effective given the scale of the Project elements.

Moderate adverse

Significant


Plume in views


Low Low Controlling light pollution will have a positive effect. Enhancing existing scrub along the dune formation close to the village could offer additional screening



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13 Ground conditions

13.1 Introduction

This chapter considers the potential impacts on ground conditions associated with construction,

operation and decommissioning of the Project. Specific objectives of this assessment are to

assess:

● Potential impacts of the Project on geology and soils, from the construction phase,

subsequent operation and the decommissioning phase.

● Potential impacts on geology, soils and groundwater from existing contaminated land if

present in the Project area and future contamination which may result from Project activities.

Appropriate mitigation measures to avoid or reduce any identified significant impacts are also

presented.

Each phase of the Project –construction, operation and decommissioning– has the potential to

impact on soils, with subsequent potential implications on soil quality and land use. In addition,

there is potential to affect groundwater quality if mobilisation of contamination occurs. The

geology and soils of an area can also impose constraints on the construction, particularly if

contaminated or unstable lands are present. Such constraints will be considered in both the

Project design as well as in construction and operational procedures. Sensitive receptors

associated with ground conditions comprise key features, such as designated (regionally,

nationally or internationally) important geological sites or agriculturally or ecologically valuable

soils. There is also potential for secondary impacts from existing or future contaminated ground

to sensitive receptors that may be nearby, such as human health (farmers, contractors and

site/maintenance workers), wildlife and livestock.

Based on the perceived connectivity between the above receptors and the ground conditions,

the effects on these receptors with respect to impacts from contaminated ground are discussed

in this chapter.

13.2 Methodology criteria

The methodology for assessment of ground conditions is broadly consistent with the general

ESIA methodology for the Project outlined in chapter 5. Specific criteria for determining

sensitivity of ground conditions and the magnitude of the impacts are presented below.

Table 94 presents the criteria for determining the sensitivity of geological and soil receptors.

This has predominantly been reviewed with regard to the agricultural value of the soil, which is

considered the most likely sensitive potential use for soils in the area and sites of local and/ or

international geological importance.

The potential for secondary impacts to human health receptors, as a result of contamination of

soil, are also assessed in this chapter. Human health receptors are considered to be of high

value.


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Table 94: Sensitivity criteria

Importance/ value of feature

Definition

High Agricultural land (soil of excellent quality with no limitations, can support a very wide range of agricultural crops); or nationally or internationally important for its geology.

Medium Agricultural land (soil of good quality with minor limitations, can support a wide range of agricultural crops); or regionally important for its geology.

Low Agricultural land (soil of good to moderate quality with moderate to moderately severe limitations, can sometimes support a wide range of agricultural crop, or cereals, pasture and scrubland); or locally important for its geology.

Negligible Agricultural land (soil of poor quality with severe limitations, supports mainly scrubland); or not important for its geology.

Table 95 presents the criteria for determining the magnitude of impacts on geology and soils.

Areas of land affected have been reviewed qualitatively rather than with absolute figures with

regards to the relative availability of similar soil types in the region.

Table 95: Magnitude criteria

Magnitude of impact

Major Results in loss of feature.

The Project (either on its own or with other projects) may result in physical removal or degradation (including loss of structure and contamination) of a large area of soil relative to the availability of similar such soil type in the area.

Moderate Results in impact on integrity of feature or loss of part of feature.

Physical removal or degradation (including loss of structure and contamination) of a moderate area of soil relative to the availability of similar such soil type in the area.

Minor Results in minor impact on feature.

The impacts result in the physical removal or degradation (including loss of structure and contamination) of a minor area of soil relative to the availability of similar such soil type in the area.

Negligible Results in an impact on feature but of insufficient magnitude to affect the use or integrity.

The impact would lead to no observable change in the features.

The significance criteria used for the assessment is in line with the significance matrix provided

in chapter 5.


The evaluation of baseline conditions uses a variety of sources, including information on

geology, soils, hydrogeology and the existing contamination status of the soils and groundwater

in proposed construction areas of the Project. Baseline conditions for the site have been

assessed based on the following information:

● The SESA completed by Mott MacDonald on behalf of the Coal and Energy Development

Department of the Government of Sindh (November 2014)

● Revised Implementation Plan, Thar Coalfield Block VI completed by SRK (August 2015)

● ESIA for the Block VI Lignite Mining Project completed by Wardell Armstrong and Hagler

Bailly (April 2013)

● Thar Coal Block II Power Project ESIA undertaken by Hagler Bailly (January 2014)


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The temporal scope of the assessment assesses site preparation and construction of the

Project (both assessed under the ‘construction’ phase which is expected to be 40 months in

total) and operation which will be for a minimum of 30 years.

Impacts relating to contamination will be assessed based on information on potential historical,

current and future sources of contamination. For historical sources this is based on soil testing

data and, in the absence of this, information available regarding historical and current land use.


For this assessment, the study area includes the land within the boundary of the Project area,

which comprise the power plant, access road and the surrounding area within a maximum

distance of 500m from the boundary of the Project areas. Provided suitable mitigation is

incorporated, operations associated with Project activities are unlikely to significantly affect

overall, geology and soils outside of the Project area and no contamination impacts are

envisaged at distances greater than 500m from the site boundary.

13.2.3 Assumption and limitations

To the extent that some of the assessment is based on information obtained in ground

investigations of other studies, persons using or relying on this report should recognise that any

such investigation can examine only a fraction of the subsurface conditions. As such,

unexpected ground conditions may be present that have not been identified at this stage of the

Project. Furthermore, suitable mitigation measures will be in place, detailed in the construction

environmental management plan, to manage unexpected contamination if identified during the

construction works.


13.3.1 Landscape and topography

The geomorphology of Block VI is typical of much of the Thar Desert in having an undulatory

relief with areas of higher ground consisting of elongated (20 to 50m high) sand dunes, parallel

to the prevailing north-easterly winds interspersed, with areas of very flat plain being

approximately 75 to 85m above mean sea level (amsl).

There are no river courses close to the Project area, although there are small ephemeral

(transient) channels that capture run–off during and after large rainfall events. Significant

temporary water bodies exist along the southern margins of the Thar Desert, particularly in the

Great Rann of Kutch, 60km to the south of Block VI. Refer to chapter 11 and chapter 14 for

further detail.

13.3.2 Geology

The Block VI concession area is located in the eastern part of the Thar Coalfield, where the

overburden and waste rock cover is less than 200m thick. Geological studies extensively carried

out for the Thar coalfields have indicated four major divisions of stratigraphic sequences. In

descending stratigraphic order, these are: recent dune sands, a sub–recent formation and the

tertiary bara formation.


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● The bara formation contains the main lignite horizons which are interbedded with

carbonaceous clays and underlain with two thick sand layers of 4m and 40m separated by a

thin lignite horizon and carbonaceous clay

● The sub–recent age sediments overlie the bara formation and consist of red–orange silts,

clays and sands. The base of this formation is marked by a loose 5–10m sand layer with

varying silt content

● The recent dune sand occurs above this and is generally a 60m thickness of fine to

moderately grained and unconsolidated sands.

In Block VI, the main lignite seam occurs at 130 to 160m below surface and varies in thickness

from 10 to 23m. The main seam is split by a major parting to the east and thins to the north and

western parts of the basin. A series of thinner lignite horizons, varying in thickness from 0.5 to

4m, occur in the 20m above this main horizon and also occur in below the main seam

sporadically below the main lignite seam for 7 to 20m.

The main lignite seam as referred to in Block VI comprises of multiple layers. The thinner seams

vary in continuity and thickness across the license (0.3 to 4.7m). The total coal thickness within

Block VI decreases to the north of the licensed area and dips towards the south and west,

forming the depocentre of the coal basin.

No large scale faulting or folding has been identified within the sediments and small scale

faulting cannot be characterised. The lignite seams occur at depth and have not been subject to

surface weathering or alteration.

There are three aquifers of significance in the Project area:

● The top aquifer is at the base of the recent sand dune deposits and comprises mainly fine

grained sands

● The middle aquifer is confined from above by the sub–recent siltstones and below by the

claystones and shales of the bara formation

● The bottom aquifer is confined from above by the bara formation claystones and lignites.

13.3.3 Soils

In Tharparkar there is lack of thick top soil with appreciable organic components available.

According to World Reference Base (WRB) for Soil Resources classification system, the soil of

Thar is predominantly classified as arenosols. Regosols, leptosols and solonchaks are the soil

types present in association and / or inclusion with the arenosols. All soil types present in

Tharparkar show that the soil is of poor quality. Similarly, according to the soil classification of

Thar by the Agricultural Research Council (Islamabad), all the categories come under poor

quality soil. The soil of the district primarily comprises unconsolidated mineral material, loamy

sand to coarser textured with low water holding capacity and high permeability to water. It is

susceptible to soil erosion, shifting sand dunes and long periods of drought.

The Project area is mostly covered with desert consisting of sand dunes and fine sand

materials. The soils are generally infertile and because of severe wind erosion, are overblown.

The area is covered not only by sheets of sand but also rocky projections of low elevations

which constitute the older rocks. The soil remains dry for much of the year and is prone to wind

erosion. High velocity winds blow soil from the desert causing shifting sand dunes.

When there is rainfall, the soils are moist enough to allow cultivation and when not cultivated

they yield crops of grass. The salinity of the subsoil causes consequent shortage of portable


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water and generates salt lakes. Due to the short span of the monsoon and inconsistent rains,

agricultural activities are at subsistence level.

As part of the mine ESIA, surface soils samples were collected and were assessed. The

following observations can be made:

● Selected heavy metals (calcium, cobalt, nickel, copper, lead, total chromium, zinc, iron,

vanadium) were detected at concentrations above the laboratory limit of reporting (LOR) in

the samples analysed.

● Other analytes including cyanide, total petroleum hydrocarbons and purgeable organics

results were below the laboratory LOR.

13.3.4 Seismicity

Pakistan lies along the contact between the Indian and Eurasian Plates. It is situated in the

north–western corner of the Indian Plate. To its south–east is the Indian Plate and to the north

the Asian/Karakoram Continental Plate. The Thar Desert lies in the south–eastern part of

Pakistan on the stable western margin of the Indian Plate.

Prior to 2007 the area of Block VI was categorised in Zone 2, corresponding to peak horizontal

ground acceleration of 0.08 to 0.16g. In 2007, the seismic risk for the entire country was

reassessed in light of two major earthquakes in the region. Block VI now falls in the Seismic

Zone 2B which corresponds to a peak horizontal ground acceleration of 0.16 to 0.24g. The

location of Thar coalfield in relation to seismic zones is shown in Figure 36.

Figure 36: Seismic zones in study area

Source: Hagler Bailly Pakistan


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13.3.5 Landslides

There is no available data regarding the landslides within the Project site and there are no

records of collapse, debris flow or other adverse geological events around the proposed Project

site. There is a close correlation between landslides, seismic activity and intense rainfall.

Landslides are primarily caused by slope saturation and earthquake prone areas also increase

the likelihood of landslides.

13.3.6 Historical and future contamination sources

13.3.6.1 Potential for historical contamination

The Project site has not been occupied by any industries previously that would lead to

contamination in the area. A recent study investigated the presence of arsenic (As) in

groundwater, which is one of the main sources of drinking water in Tharparkar. The study

showed high levels of As34 in groundwater samples that might be transported by the Indus River

from the Himalayas and mobilised in aquifers by the reductive dissolution of various As-bearing

oxides35. Considering the dry climate of Tharparkar region, evaporation also contributes to the

high levels of As.

The ESIA of Block II also concluded that based on the water quality samples obtained from 40

wells, that the groundwater is generally unfit for human consumption.

As discussed in section 13.3.3, surface soils samples were collected and were assessed as part

of the mine ESIA and the heavy metals were detected at concentrations above the laboratory

LOR. Based on the absence of any significant historical sources it is considered unlikely that

soils have been impacted by any anthropogenic sourced contaminants.

Due to the limited information available on the routes of the associated infrastructure at this

stage, the specific ground conditions associated with these Project components have not been

assessed. Given the remote and rural setting of the Thar Coalfield, it is not considered likely that

parts of the associated facilities will pass through currently or historically industrialised areas

which have the potential to have been subject to contaminating activities. Assessment of the

ground conditions along the route will be undertaken by the Government of Sindh as part of

separate assessments.

13.3.6.2 Potential contamination due to construction and operation works

The main potential contamination impacts from the construction and operation of the power

plant and associated infrastructure will be associated with the transport, storage and use of

hazardous materials. The main potential future sources of contaminants are considered to be:

● Coal dust from the storage and use of lignite coal (particularly associated with crushing

activities)

● Bottom and fly ash storage, and transport of ash to the emergency ash storage area on site

(potential associated heavy metal and polycyclic aromatic hydrocarbons (PAH)

contamination), and subsequent transport of ash to the off-site ash disposal area

● Fuel oil used for boiler start up

● Surface run-off as a pathway for contamination (storm drainage)

● Waste water (operational and sewage) including oily water run-off, chemical waste and coal

and ash yard storm water

34 Based on the World Health Organisation’s (WHO) maximum permissible limits for drinking water 35 Brahman et al., 2016, Smedley and Kinniburgh, 2002 and Singh, 2006


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● Storage and use of chemicals at the construction laydown area and Project site during

construction

● Storage and use of chemicals, such as those for water treatment. Chemicals used are likely

to include hydrochloric acid and caustic soda.

For all aspects of the construction and operation works, there is potential for secondary health-

related impacts to construction and site workers from the handling of hazardous or

contaminative materials. Where relevant, these impacts are also discussed in the sections

below. If appropriate personal protective equipment (PPE) is worn, with suitable health and

safety risk assessments undertaken and standard good construction methods adhered to, the

possibility of construction workers being impacted by contaminated land is likely to be low.

13.3.7 Value of geology and soils

The geology in the Project area is assessed as having a negligible geological value, as there

are considered to be no national or internationally recognised sensitive geological features in

this part of the Project area.

At the time of this study there were no data available on soil fertility in the Project area.

Available data on the classification of land by use indicates that the Project area is partially

agricultural field; therefore the soils are considered to have a low value/sensitivity based on the

criteria for determining sensitivity of features (refer to section 13.2).


13.4.1 Overview

The main Project components which may impact soil quality are considered to be:

● Site preparation including levelling ground preparation within the Project site

● Construction and operation of the new 2x330MW coal-fired power plant and associated

infrastructure, including:

– Coal yard at power plant site

– A substation that will connect to an existing 500kV transmission line

– One 210m stack

– Cooling water system

– Ash yard (temporary storage)

– Ash disposal area (within Block VI)

– Access roads within Block VI

– On-site accommodation, office facilities, fire station, workshop and open materials

storage area.

Potential impacts relating to the above components are discussed separately in the following

sections. Based on an initial assessment, the principal potential impacts to soil and groundwater

during all phases of the Project include:

● Degradation of soil and groundwater quality as a result of leaks and spills of hazardous

materials (including waste) during their transport, storage, handling and disposal

● Disturbance of potentially contaminated soil as a result of ground works (excavation/

levelling) which could encourage leaching of contaminants into groundwater

● Vegetation and soil loss associated with construction

● Storage of ash generated from the combustion process and the generation of soil infiltration

of ash contaminated water with the potential to impact groundwater quality.


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Soil and groundwater are potentially at risk of contamination from the construction,

commissioning and operational activities of the Project facilities, including the management of

wastewater and other fluids generated by the Project and the storage and handling of other

hazardous materials. There is also the potential for secondary impacts to groundwater and

human health as a result of soil contamination.

The potential for impacts to soil and groundwater from contamination resulting from construction

and operation of the Project are discussed below. The following impact assessment is based on

our understanding that no significantly polluting activities have previously been undertaken in

the Project area. Given the relatively similar nature of both the construction phase and future

decommissioning phase, it is anticipated that the impacts described below can be attributed to

both.

For all aspects of the construction, operation and decommissioning works, there is the potential

for secondary impacts, from contaminated soils affected by the works, to construction and site

workers via the handling of hazardous materials or soils. Where relevant, these impacts are also

discussed in the following sections. The Project will enforce the use of appropriate PPE as

adherence to standard construction methods. As such, the possibility of construction workers

being impacted by contaminated soil or other hazardous material is considered to be low.


Construction of the Project and associated infrastructure will be undertaken on previously

undeveloped land. This will lead to the loss of approximately 40 hectares of land for the

development. Whilst the magnitude of this impact is considered to be major adverse, the soils at

the Project area are considered to have a low value due to their limited agricultural value.

13.4.2.1 Site preparation

Prior to construction, the Project site will require preparation including site levelling (due to 20m

to 50m tall rectangular dunes) and for the construction of piled foundations. Site levelling will

require significant movement and reworking of soils which could lead to degradation, erosion

and/or loss of soil cover. Compaction of soils can cause secondary impacts on soil drainage.

The soils in the Project area are considered to have a low value and sensitivity. The area

affected is considered to be of a reasonable size, whilst other similar areas will remain and the

impact will be permanent, therefore the magnitude is considered to be moderate adverse.

Impacts to the soil are assessed as minor adverse and therefore are not significant. The site

levelling will have an impact on the soil drainage properties which will in turn affect the drainage

of potential precipitation run-off and infiltration. The significance of these impacts are discussed

further in chapter 11.

13.4.2.2 Construction activities

Disturbance of soils during construction, particularly due to movement of vehicles, may lead to

erosion of the upper soil layers. A subsequent secondary impact of erosion includes creation of

dust. Based on our knowledge of the site history, it is considered unlikely that the soil quality at

the Project site has previously been impacted by anthropogenic contamination. Creation of dust

may have implications for human health and ecological receptors near to areas where

construction activities are to be carried out. Potential impacts from the creation of dust are

discussed in more detail in the chapter 7.

Construction of the buildings and hard surfacing and re-vegetation (if possible) of undeveloped

areas will act to reduce erosion. Construction activities will ensure the stability of foundations.


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13.4.2.3 Contamination of soil

Existing contamination

There is potential for impacts from existing soil contamination during construction when soils will

be disturbed and exposed. It is understood that the Project site has not previously been

developed. As discussed in section 13.3.6, previous soil testing on the Thar Coalfields showed

the presence of As; therefore the potential presence of soil contamination on the proposed

development site cannot be discounted. Contamination could be spread via excavation and

movement of soils, through windblown pathways via dust creation, sediment in runoff and

through leaching into groundwater. The magnitude of contamination impacts to soils and human

health is conservatively considered moderate adverse for all of the Project elements. With

regard to human health (of construction workers and neighbouring site users) is considered to

have a high sensitivity and without suitable mitigation, the impact is assessed as major adverse

and is significant.

Future contamination

During construction, a range of potentially hazardous substances would be used, such as oils,

lubricants, fuels and cement. These materials will also require transport to the site. Accidental

spills or leakages of hazardous substances may result in local contamination of soils, with

potential implications for groundwater. With current best practice construction site management,

the likelihood of this occurring will be minimised to a negligible risk.

The magnitude of contamination impacts to soils would be minor to moderate adverse. Based

on the low value/sensitivity of soils in the Project area, the impacts to soils are assessed as

negligible to minor adverse and therefore is not significant.

13.4.2.4 Wastewater

A range of potentially contaminated waste liquids will be produced during construction activities

including: concrete wash water; sewage effluent; surface runoff and waters for hydro testing,

washing and cleaning (particularly during facility start up). All wastewater and liquid waste

streams for the Project will ultimately be treated prior to discharge in accordance with the SEQS

effluent discharge limits.

During construction, particularly prior to construction of the site drainage system, it is anticipated

that some run-off may not be captured by the sites drainage system. If uncontrolled or

untreated, discharge of waste waters could have a minor magnitude of impact on soils and

subsequently on groundwater due to the composition of the water and potential presence of

pollutants. Based on the low value of soils in the Project area, the impact to soils are assessed

as negligible and is therefore not significant.

Secondary impacts to groundwater are discussed in more detail in chapter 11.


13.4.3.1 Contamination

Similar to the construction phase, the main potential contamination impacts for the Project are

associated with the use, transport and storage of hazardous materials, and liquid waste

disposal. Pollutants associated with the Project activities include fuel oil used for boiler start up,

coal dust, bottom and fly ash and other chemicals related to the site processes, such as those

for water treatment (including hydrochloric acid). Impacts may result from leaks and spills from


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the storage and use of hazardous materials stored at the plant. Due to the incorporated design

and environmental mitigation measures that will be in place this is very unlikely.

A three-part conveyor system will be utilised for unloading delivered coal, transferring crushed

or pulverised coal from a stockpile to the storage bunkers; and delivery of the pulverised coal to

the CFB boilers. Soil contamination can result from the loss of coal or coal dust into the ground.

Two coal storage yards will be located at the site which could be the source of particulate

pollution if washed out of the stockpile. Leachate from the stockpile may contain contaminants

associated with coal such as heavy metals and can present a risk to surrounding soil and

groundwater if freely draining. The quality of the leachate will depend on the coal composition.

Bottom and fly ash will be stored separately in silos at the site. The Developer will be

responsible for the transportation and disposal of ash, which is expected to be at the Block VI

mine site. Discussions with the Developer and relevant stakeholders will be undertaken to

ascertain whether there is a potential for commercial use for the fly ash (eg blocks and cement

manufacturing) and bottom ash (eg road construction) within Pakistan.

Hydrocarbons such as fuel oil, lubricating oil and degreasing solvents are highly mobile and can

potentially contaminate a wide area. On encountering groundwater, the liquids may migrate

laterally over a wide area, presenting risks to groundwater resources further afield. Some liquids

may also migrate vertically in groundwater presenting a contaminant risk to identified aquifers

(refer to section 13.3). Water treatment chemicals could present a risk to the environment if

present in discharge waters, runoff, or if introduced to the environment via leaks and spills. All

hazardous materials will be stored in bunded containers or on lined surfaces with surface

drainage to a foul water treatment system.

The coal stocking areas will have sealed concrete surfaces and will have incorporated drainage.

The exact design and required thickness will be determined during Project detailed design

phase, with the minimum requirement that there shall be no possibility of infiltration in the

groundwater. Dust will be managed (using a sprinkler system) [and the coal stocking area will

be surrounded by an earthen bunded wall to reduce the potential effects of windblown dust from

the coal storage area.

Many of the chemicals used at the site are highly mobile and can potentially contaminate a large

area. Without suitable mitigation, chemicals entering groundwater may migrate laterally,

presenting risks to groundwater resources further down gradient. Some liquids may also migrate

vertically in groundwater presenting a risk to deeper aquifers. The risks to groundwater from

contamination are discussed in chapter 11.

13.4.3.2 Seismic impacts

As discussed in section 13.3.4, Block VI falls in the seismic Zone 2B which corresponds to

moderate/intermediate seismic risk. Earthquakes not only present a risk to building structures

and human health, but also have the potential to damage drainage structures and containers for

storage of hazardous materials. Impacts may be as a result of leaks and spills of hazardous

materials, site drainage from potentially contaminated areas and process waste. Measures to

mitigate the impacts of potential earthquakes are included in the design of the Project.

13.4.3.3 Surface water runoff

The plant design will include two buried treatment facilities for domestic wastewater. Oily waste

water from the fuel oil storage and unloading area, boiler room and transformer yard area will be

collected in a sump before being treated in an oil separator. Treated oily wastewater will flow to

a central monitoring basin. The coal storage yard will be located on a sealed concrete surface


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with a surface drainage collection system which will discharge to a final settling lagoon will then

be discharged into the mine stormwater drainage system.

There is potential for impacts to soil and groundwater from failure of the treatment process or

ineffective drainage due, for example, to blockages or insufficient capacity. There is potential for

contamination impacts if collection ponds are not appropriately lined or maintained.

For all of the above, the potential impacts to soils are assessed as negligible due to their low

value/sensitivity and a minor adverse magnitude of impact, which is not significant. The risks to

groundwater from contamination are discussed in chapter 11.

13.4.3.4 Impacts on soil quality

Contamination has the potential to affect soil quality locally at the Project site. Depending on the

extent of contamination (small or large spill/leak) the magnitude would be minor to moderate.

Soil is considered to be a low sensitivity receptor. Based on its low value, the resulting impact to

soils would be negligible to minor adverse and therefore not significant.

Storage and handling of hazardous materials onsite will be undertaken in accordance with the

site environmental health and safety plan to minimise the risk of leaks and spills and therefore

the potential for impacts to the environment and human health.

If not suitably controlled, soil contamination has the potential to impact groundwater, human

health and ecology. The most likely receptors include site operatives and visitors who may

come into contact with contaminated dusts, most likely via inhalation and ingestion. Human

health receptors have a high value. Based on the most likely exposure route (inhalation and

ingestion of dust) and the likely contamination related to the processes (organics mainly

comprising hydrocarbons, and heavy metals), health impacts could be short-term or chronic and

therefore the magnitude would be moderate adverse. Taking into account the potential impact

on human health, the significance of this impact is assessed as major adverse and significant

prior to mitigation being applied. Incorporating spill protection measures in plant design and

monitoring during the operational phase will reduce the impact significance.


13.5.1 Overview

The main impacts on soils for all aspects and phases of the Project are considered to be

erosion, landslides during monsoon season and contamination. This is particularly significant

during the early construction phase when ground disturbance, leaks and spills are more likely.

During construction, contamination impacts from leaks and spills will be mitigated through use of

best practice construction methodology in line with local regulations. Impacts from waste can be

suitably mitigated by following a Project specific waste management plan. For all aspects of the

Project a comprehensive HSE plan will be implemented, aimed at preventing accidents, injuries

and work-related diseases through identification of the causes of physical, chemical and

biological hazards and by prioritising hazard elimination, hazard control and hazard

minimisation.

Mitigation measures are incorporated in Table 96 and Table 97 and residual impacts after

mitigation are identified in Table 98.


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13.5.2 Mitigation of risks to human health

Impacts to human health during all stages of the development can be prevented by following

good site practice and use of appropriate PPE. Suitable PPE includes: eye protection; body/leg

protection; foot protection; hand protection; hearing protection; lung protection and head

protection.

Physical exposure to soil and dust can result in a risk to site workers. PPE should be maintained

and replaced when worn out. Occupational monitoring of workers will be undertaken in order to

confirm the effectiveness of use of PPE and if required the PPE requirements will be revisited.

Other measures for protection of human health include: communication of potential hazards to

workers; safe storage of hazardous materials; provision of suitable welfare facilities including

clean water for washing and drinking; provision of suitable ventilation systems in workers

accommodation; environmental monitoring (e.g. gas and vapour monitoring) and emergency

preparedness and response plans.

An emergency preparedness and response plan (EPRP) will be prepared, detailing procedures,

response personnel, medical support, equipment, evacuation procedures and measures for

limiting or stopping potential events. A framework EPRP has been provided in the ESMP

(Volume IV).


A CESMP will be developed for the site prior to construction. This document will outline the

practices and procedures during the construction phase and will be further developed for the

operational phase, to ensure minimal associated environmental impacts.

Mitigation measures required for construction of the Project are summarised in Table 96.

There is potential for impacts to the health of contractors and site workers during construction

activities when handling hazardous waste materials. A comprehensive occupational health and

safety (OHS) plan aimed at preventing accidents, injuries and work-related diseases through

identification of the causes of physical, chemical, biological and radiological hazards and by

prioritising hazard elimination, hazard control and hazard minimisation would be implemented.


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Table 96: Mitigation measures required during the construction phase

Process/activity Impact Mitigation

Site preparation (levelling) and vehicle movement

● Vegetation loss and compaction, resulting in erosion of desert soils leading to: soil and further vegetation loss, change in drainage structure, clogging of drainage features by wind-blown dusts and sediments in rainwater run off

● Where possible vehicles to use defined access roads/tracks.

● Where travelling off road, keep vehicle movements to a minimum.

● Earthworks to be undertaken during suitable weather conditions i.e. low wind strength to minimise the level of wind-blown dust. Damping down of soils may also be used to prevent creation of dust.

Earthworks/ intrusive construction works

● Mobilisation of dust and secondary impacts on human health

● Use best practice construction methodology in line with local regulations.

● Undertake earthworks during suitable weather conditions i.e. low wind strength to minimise the level of windblown dust. Damping down of soils may also be used to prevent creation of dust. Contractors to wear suitable PPE to protect against inhalation of dust. A risk assessment will be carried out to identify the level of PPE required in line with site specific risk factors.

Leaks and spills of hazardous materials

● Soil quality with secondary impacts on groundwater quality and human health.

● Use best practice construction methodology in line with local regulations to minimise the potential for leaks or spills to occur.

● Hazardous materials will be suitably stored to prevent leaks and spills. Drip trays will be used to intercept leaks and spills from equipment and during refuelling. Adequate bunding will be provided for all fuel and chemical storage.

● Develop and implement an EPRP and a separate spill prevention and response plan for clean-up of contaminated material in case of fuel leaks.

Waste water from construction, integrity testing and cleaning


● Use best practice construction methodology in line with local regulations.

● All waste water requiring treatment will be processed in the dedicated wastewater treatment facility.


Mitigation measures required for operation of the Project are summarised in Table 97.

As with the construction phase there is a potential for impacts to the health of site workers when

handling hazardous materials. These will be addressed through the implementation of OHS

management systems.


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Table 97: Mitigation measures required during the operational phase

Process/activity Impact Mitigation

Leaks and spills of hazardous materials


● Drip trays will be used to intercept leaks and spills from equipment and during refuelling.

● Develop and implement an EPRP and a separate spill prevention and response plan in accordance with local regulations. Clean-up contaminated material in case of fuel leaks.

● Hazardous materials will be suitably stored to prevent leaks and spills. Bunding at least 110% of largest container will be provided for all fuel and chemical storage. Double or triple skinned bunding will be used where necessary.

Site drainage (including ash and coal storage yards)

● Soil and groundwater quality

● All drainage and process water (including surface water run-off and water from the coal stockyard) will be collected, treated at the water treatment plan prior to discharge off-site and/ or re-use on site. Treatment will include separation of oil from the water, pH adjustment and biological treatment.

● All storage ponds will be suitably lined and will be monitored for leakages.

● In accordance with the site ESMP, on-going monitoring and maintenance of the drainage system will be undertaken.

● Wastewater emissions will comply with local water quality and discharge regulations and will not exceed maximum allowable concentrations for discharge of wastewater to land and water.

● In the stack area, fly ash will be stored in elevated silos in an area with a concrete base and wall around it.

● Soil and groundwater quality will be protected in the coal stockyard area by placement of a concrete base which will mitigate the migration of pollution.

Storage of wastewater in ponds

● Soil and groundwater quality

● Ponds will be fully lined to prevent leaks and spills.

● The ponds will be designed with extra capacity for monsoon deluge.

● All aspects of the plant will be designed to withstand the assessed intensity of earthquake.

Transport, handling, storage, drainage and use of potentially contaminating materials

● Soil, groundwater and surface water quality

● By implementing the mitigation detailed above, for leaks and spills and drainage, potential impacts to soil and groundwater quality can be minimised.

● Routine quarterly monitoring of groundwater quality and level at up-gradient and down-gradient locations in the vicinity of the power plant.

● Assessment of any changes in groundwater conditions, to ensure groundwater quality is not degraded by Project activities and to provide early warning should impacts occur.


Following the implementation of mitigation as set out in sections 13.5.3 and 13.5.4, residual

impacts are set out in Table 98. There are not expected to be any significant residual impacts.


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Table 98: Summary of ground contamination impacts and mitigation

Activity Potential impacts Sensitivity Magnitude Impact descriptor

Mitigation or enhancement Residual impacts and significance

Construction

Site preparation (levelling) and vehicle movement

● Erosion

● Landslide

● Damage to soils

Low Moderate adverse

Minor adverse ● Best practice construction techniques

● Where possible vehicles to use defined access roads/tracks.

● Where travelling off road, keep vehicle movements to a minimum.

● Earthworks to be undertaken during suitable weather conditions i.e. low wind strength to minimise levels of wind-blown dust. Damping down of soils may also be used to prevent creation of dust.

Negligible - not significant

Earthworks – disturbance of soil with potentially existing contamination

● Potential impacts to human health

High Moderate adverse

Moderate adverse ● A CESMP will be developed for the site.

● Best practice construction techniques

● Compliance with local and international guidance

● Develop and implement an EPRP and a separate spill prevention and response plan.

Minor adverse - not significant

Leaks and spills of materials from construction activities

● Potential impacts to human health

Low Minor to moderate

Negligible – minor adverse

● A CESMP will be developed for the site.





Collection and treatment of wastewaters

● Soil contamination Low Minor Negligible ● A CESMP will be developed for the site.




Negligible - not significant

Operation

Leaks and spills of materials (and site drainage/ waste waters if damage occurs)

● Potential secondary impacts to human health

Low Minor to moderate adverse



● Implement site inspection protocol and undertake monitoring as necessary.



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Activity Potential impacts Sensitivity Magnitude Impact descriptor

Mitigation or enhancement Residual impacts and significance

Site drainage from ash and coal storage yards


Low Moderate adverse

Moderate to major adverse

● All drainage and process water will be collected, treated at the WWTP prior to discharge off-site and/ or re-use on site.

● All storage ponds will be suitably lined.

● Ash will be stored in impermeable sealed bags.

● All buildings, infrastructure and electrical equipment will be designed to withstand an earthquake intensity of 8.



Operational activities leading to spills and leaks


● Soil contamination

Low Minor to moderate adverse


● A OESMP will be developed for the site.



● Implement site inspection protocol and undertake monitoring as necessary.



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14 Ecology & biodiversity

14.1 Introduction

This chapter presents the baseline conditions and the assessment of Project impacts on

biodiversity associated with the construction and operation of the Project. It identifies the

relevant framework of the legislation and other requirements, and identifies and assesses

potential significant impacts, before defining appropriate mitigation measures that will be

implemented as part of the Project. The baseline includes protected areas, habitats and

species, with information being used from primary and secondary sources.



The national legislation relevant to biodiversity is summarised in Table 99 below.

Table 99: Biodiversity-specific legislation

Legislation / Guideline (Year of issuance)

Brief description

Forest Act (1927) and Forest (Amendment) Act (2010)

The Act deals with the matters related to the protection and conservation of natural vegetation and habitats. It empowers the competent agency to declare protected and reserved forest areas and to maintain these. Although it recognises the rights of people to access natural resources for their domestic use, it prohibits unlawful cutting of trees and other vegetation. Therefore, consent is required from the forest department of the concerned province prior to cutting any trees for construction purposes or otherwise.

Sindh Environmental Protection Act, 2014

To provide for the protection, conservation, rehabilitation and improvement of the environment, for the prevention and control of pollution, and promotion of sustainable development.

The Sindh Wildlife & Protected Areas Act, 2010

An Act to provide for protection, preservation, conservation, sustainable use and

management of biodiversity, especially wildlife, and establishment and management of

protected areas in the Province of Sindh.

Sindh Wildlife Ordinance 1972 and Amendments 2001

Details the rules, regulations and permits for hunting, trapping and capturing of game animals; conservation of National Parks, Game Reserves; and the laws and guidelines of working in protected area and sanctuaries.

14.2.1.1 National Biodiversity Action Plan

Pakistan completed a national biodiversity action plan (BAP) in 2000, which acts as Pakistan’s

biodiversity policy for meeting the planning requirements of the United Nations (UN) Convention

on Biological Diversity (CBD). The process leading up to the preparation of the national BAP

involved broad participation from governments, academia and civil society through national and

regional-level consultative workshops to develop and review the draft document (CBD

Secretariat, 2016).

The national BAP sets out a strategy for action under 13 main components which correspond to

the Articles of the CBD: planning and policies, legislation, identification and monitoring, in-situ

conservation, ex-situ conservation, sustainable use, incentive measures, research and training,

public education and awareness, EIA, access issues, exchange of information and financial

resources. For each component, the issues relevant to Pakistan are identified and a list of

objectives and corresponding actions are recommended to deal with the identified issues.


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Slowing the rate of biodiversity loss in Pakistan is a key objective in the national BAP. This will

require policy and institutional reform to better understand biodiversity and the most effective

means for ensuring its conservation and sustainable use. The active participation and support of

local communities will be essential for in-situ conservation. The national BAP also calls for

greater collaboration between government agencies, local communities and NGOs to work

together as partners in biodiversity conservation.


14.2.2.1 International conventions

Pakistan is a party to a number of conventions in relation to biodiversity, including the

Convention on the Conservation of Migratory Species of Wild Animals (CMS), the Convention

on International Trade of Endangered Species of Wild Fauna and Flora (CITES), the

Convention on Wetlands of International Importance (Ramsar Convention) and the UNCBD.

The CBD defines biodiversity as “the variability among living organisms from all sources

including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological

complexes of which they are part; this includes diversity within species, between species, and of

ecosystems”. As a signatory country, Pakistan has a responsibility to:

● Safeguard its biodiversity

● Introduce procedures requiring EIA for Projects likely to have significant impacts on

biological diversity; refer to Section 4.5 on EIA related legislation in Pakistan

● Introduce legislative provisions that ensure environmental policies and procedures are duly

taken into account

14.2.2.2 IFC PS6 (2012)

This chapter has been prepared in line with Pakistani national standards and requirements.

However, where possible, the assessment followed IFC PS6 (IFC, 2012a) and IFC Guidance

Note 6 (IFC, 2012b).

The IFC PS6 objectives are:

● To protect and conserve biodiversity

● To maintain the benefits from ecosystem services

● To promote the sustainable management of living natural resources through the adoption of

practices that integrates conservation needs and development priorities

IFC PS6 requires that a conservation value is allocated to the ecological features (protected

areas, habitats and species) which are likely to be directly or indirectly impacted in the Project

AoI. Under the IFC guidance, the requirements of PS6 apply to Projects in all habitats, whether

or not those habitats have been previously disturbed and whether or not they are legally

protected. Specifically, a Project is required to:

● Assess the significance of Project impacts on all levels of biodiversity as an integral part of

the social and environmental assessment process

● Take into account differing values attached to biodiversity by specific stakeholders

● Assess major threats to biodiversity, especially habitat destruction and invasive alien species

In accordance with IFC PS6, habitats are divided into modified, natural and critical habitats.

Critical habitats can be either modified or natural habitats supporting high biodiversity value,

including:


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● Habitat of significant importance to critically endangered and/or endangered species

(International Union for Conservation of Nature and Natural Resources (IUCN) Red List)

● Habitat of significant importance to endemic and/or restricted-range species

● Habitat supporting globally significant concentrations of migratory species and/or

congregatory species

● Highly threatened and/or unique ecosystems

● Areas associated with key evolutionary processes

Since habitat destruction is recognised as a major threat to the maintenance of biodiversity and

to assess likely significance of impacts, IFC PS6 requires the following depending on habitat

status:

● Modified Habitat: exercise care to minimise any conversion or degradation of such habitat,

depending on scale of Project, identify opportunities to enhance habitat and protect and

conserve biodiversity as part of operations.

● Natural Habitat: developer will not significantly convert or degrade such habitat unless no

financial/technical feasible alternatives exist, or overall benefits outweigh cost (including

those to biodiversity), and conversion or degradation is suitably mitigated. Mitigation must

achieve no net loss of biodiversity where feasible; offset losses through creation of

ecologically comparable area that is managed for biodiversity, compensation of direct users

of biodiversity.

● Critical Habitat: in areas of critical habitat the developer will not implement Project activities

unless there are no measurable adverse impacts on the ability of the critical habitat to

support established populations of species described or on the functions of the critical

habitat; no reduction in population of a recognised critically endangered or endangered

species and lesser impacts mitigated as per natural habitats.


14.3.1 Ecological area of influence

For the ecological impact assessment, the Area of Influence (AoI) varies with the ecological

receptor and consists of the following areas:

● Project affected area (PAA), i.e. footprints of all Project components and related facilities

power plant site:

– Coal yard

– 2 x 330MWe generation units

– A substation that will connect to an existing 500kV transmission line

– One 210m exhaust stack

– Cooling water system

– Ash yard (temporary storage)

– Ash disposal area (within Block VI)

– Access roads within Block VI

– On-site accommodation, office facilities, fire station, workshop and open materials

storage area

● Buffer zone of 500m from PAA in relation to habitats, flora, birds (excluding vultures),

mammals and reptiles


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● Buffer zone of 15km from PAA in relation to protected areas (national and international

levels), vultures, and for cumulative impact assessment

This AoI was selected to include the areas directly affected by the land take for the Project,

areas which will be temporarily affected during construction, areas likely to be impacted by

disruption and areas where there is a risk of pollution and noise disturbance during construction

and/or operation.

The ecological baseline within the AoI was formulated from information obtained from various

primary and secondary sources. Details on the methodologies used are provided in the

following sections.

14.3.2 Desktop review

A desk-based review of available information from national and international sources was

undertaken. This included:

● UN CBD website (http://www.cbd.int/)

● UNESCO database on World Heritage Sites (http://whc.unesco.org/en/interactive-map/)

● Ramsar Secretariat (www.ramsar.org)

● IUCN Red List of Threatened Species version 2015-4 (http://www.iucnredlist.org) (IUCN,

2015)

● Status and Red list of Pakistan Mammals (Sheikh and Molur, 2004)

● BirdLife International Data Zone (http://www.birdlife.org/datazone/home)

● Protected Planet (http://www.protectedplanet.net/country/PK)

● The Reptile Database (http://reptile-database.reptarium.cz/)

● Flora of Pakistan (http://www.tropicos.org/Project/Pakistan)

● Catalogue of Life (http://www.catalogueoflife.org/)

Previous reports undertaken as part of the Thar Coalfield Project and other projects in the

region have been reviewed and included:

● Thar Coal Block II Power Project ESIA (Hagler Bailly, 2014)

● Block VI Lignite Mining Project ESIA (Hagler Bailly, 2013)

● Environmental and Social Study for Thar Coalfield (Mott MacDonald, 2015)

Information on the following nature conservation areas and other protected areas (existing or

proposed) within the AoI and up to 15km has also been collected and reviewed:

● Ramsar sites

● Key Biodiversity Areas (KBA)

● Important Bird Areas (IBA)

● World Heritage Sites (WHS)

● Biosphere Reserves

● National conservation areas in Pakistan:

– National Parks

– Wildlife sanctuaries

– Game reserves

– Protected and reserved forests


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14.3.3 Biodiversity surveys

14.3.3.1 Overview

Biodiversity surveys were undertaken in July and October 2011 by Hagler Bailly Pakistan to

inform the ESIA for Block VI Thar coalfield (Hagler Bailly, 2013). Block VI was awarded 66.1km2

by Sindh Coal Authority (SCA) and the study area extended a further 10km from the boundary.

Biodiversity surveys were also undertaken in December 2009, March/ April 2010 and July/

August 2010 by Hagler Bailly Pakistan to inform the ESIA for Block II Thar coalfield (Hagler

Bailly, 2014). Block II was awarded 95.5km2 by SCA and the study area extended a further 5km

from the boundary. During the surveys, 28 sampling locations were surveyed in Block VI and 53

sampling locations were surveyed in Block II.

The following habitats and species were studied as part of these surveys:

● Habitats and flora

● Mammals

● Birds

● Herpetofauna (Reptiles and Amphibians)

● Invertebrates (Block VI only)

Ecological surveys were undertaken in 2012 to inform the environmental and social study for

Thar Coalfields (Mott MacDonald, 2015). The study area included the Thar Coalfields blocks

and the whole of the Tharparkar district. The methods are summarised in the sections below

and full descriptions are included in the Mott MacDonald (2015) report (refer to Volume III).

Additional ecological surveys in Block VI were undertaken in June 2016 to update the previous

surveys. These surveys were undertaken by a team of local specialists under the coordination

of Mott MacDonald. The report from June 2016 is included in Volume III. The June 2016

surveys covered habitats/flora, mammals, birds and reptiles. A combination of methods were

used, including direct visual observations during the day, spotlighting at night, recording field

signs of animals (faecal pellets, dens, tunnels, tracks, footprints and calls), interviews with local

people and consultation with the Wildlife Department and conservation NGOs.

14.3.3.2 Habitat and flora survey

The field studies for habitats and the abundance and diversity of the flora in Block II and Block

VI were conducted in 2009, 2010 and 2011 and covered all seasons (Hagler Bailly, 2013,

2014). Habitats were classified based primarily on geomorphology and soil texture, with

consideration of variations within habitat types. Wildlife habitats were described using three

basic components: cover, food, and water (based on Morrison et al 2006) with vegetation as the

core descriptive component. During each survey, between 3 and 10 quadrats of 10x10m were

taken at random points along a transect within the survey area. For all surveys, plants within

and directly adjacent to each quadrat were noted. Percentages for cover, density, frequency

and Importance Value Index (IVI) for each species from the study were recorded or calculated.

A botanical survey of the Tharparkar district was undertaken in April 2012 (Mott MacDonald,

2015). During the survey 50 quadrats of 50x50m were taken using stratified random

methodology in each of the following microhabitats: dune crest, slopes/swales/flanks, sandy

plains, saline lands, lake/wetland and hilly tract.


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14.3.3.3 Fauna surveys

Mammal surveys

For all surveys in 2009, 2010 and 2011, line transect (500m by 20m) were completed at each of

the sampling sites for mammals. All animals sighted, or their signs (footprints, droppings, dens

etc.), GPS coordinates and habitat type were recorded. As well as these diurnal surveys,

surveys were conducted for nocturnal mammals using spotlights whilst travelling in a vehicle

along roads/ vehicle tracks. Incidental sighting were also recorded during other surveys.

Live trapping and releasing of mammals was carried out within Block VI and Block II. Sherman

traps were used and set at specific areas. Fresh bait was used to attract mammals on every

trapping day; the traps were then checked the following morning. The trapped mammals were

identified and their weight and sex was recorded. Other relevant data such as the date, habitat,

location, elevation, and weather conditions, were also recorded.

In April 2012, sampling for small mammals was conducted in 27 quadrats of 500x500m in

representative areas of Tharparkar district. In some areas (Mithi and Nagarparkar), rodents

were also recorded at night through spotlighting. Medium-sized and large mammals were

recorded through direct observations, field signs such as foot prints, scats and dens, and from

information from locals, hunters and game watchers of the Department of Wildlife, Sindh (Mott

MacDonald, 2015).

Bird surveys

Birds were recorded along transect lines (500m by 50m) at each sampling location for all

surveys in 2009, 2010 and 2011. Transects started early morning and late afternoon and

covered all habitat hypes on site. The start time and coordinates of the starting point were

recorded. The bird surveys in April 2012 covered the whole of the Tharparkar district and

involved walkovers and using a car.

In 2012, officials of Sindh Wildlife Department and local residents were interviewed in order to

assess the existing threats to the birds as well as any possible negative impacts of the Thar

Coal Project to the resident and migratory avian fauna of the area (Mott MacDonald, 2015).

Reptile and amphibian surveys

Line transects (500m by 20m) were completed at each sampling site for reptiles and amphibians

in Block VI and Block II. Sightings of individuals and signs (impression of body, tail or footprints,

faecal pellets, tracks, dens or egg laying excavations etc) were recorded along with their GPS

coordinates, elevation, habitat type and photographs where possible.

Active searches were conducted for animals and their signs for diurnal and nocturnal species

along the transect lines, at the relevant time of day. One set of pitfall trap (5-10) were also

placed at a sampling site for a single day and night with drift fences alongside them. Samples

were collected and preserved where the species could not be identified in the field.

The 2012 surveys involved stone turning, checking under vegetation, searching for basking

skinks on sand dunes and walking along microhabitats. Amphibians were observed along water

bodies as well as in ruderal habitats. The specimens that could not be identified in the field were

preserved for detailed study in the laboratory (Mott MacDonald, 2015).

Invertebrate surveys

The invertebrate surveys were carried out in a number of sampling location for diurnal species

and also for nocturnal species to record the abundance and diversity of invertebrates in Block VI

and Block II.


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Sweep net transects and butterfly transects were used during diurnal surveys. A sweep net of

30cm diameter rim, 2.25ft long bag and one metre long handle was used to collect invertebrates

along a transect line. The observer walked at constant speed for thirty minutes repeatedly

sweeping the net from side to side. Samples were collected from the sweep nets every 50m to

be preserved and were identified later. Butterflies were counted along the same transect line

within 2.5m of the observer in all directions whilst walking the transect at a constant speed. The

temperature, wind and cloud cover were recorded for each sampling point.

Nocturnal surveys were undertaken using a portable car battery operated ultra violet light trap.

The trap was operated for thirty minutes at each sampling location.


The magnitude of the potential impacts upon each ecological feature (Table 100) is assessed

for the construction and operation of the Project. The conservation value (sensitivity) or

weighting attributed to each ecological feature which occurs within the Project AoI is defined in

Table 101.

In order to categorise the sensitivity on the basis of biodiversity-specific criteria typically adopted

for the assessment of ecological impacts, the sensitivity ranking presented in Table 101 differs

slightly from the evaluation matrix presented in chapter 5 by including the conservation value

category “Very High.” However, a “High” or “Very High” sensitivity (conservation value) is

equivalent to the general category “High” for receptor sensitivity in the impact evaluation matrix.

Significance has been determined by the interaction between the magnitude of impacts and the

sensitivity of receptors affected, as depicted in the impact evaluation matrix shown in chapter 5.

Table 100: Criteria for determining impact magnitude

Category Definition

Major Fundamental change to the specific environmental conditions assessed resulting in long term or permanent change, typically widespread in nature (regional, national and international), would require significant intervention to return to baseline; exceeds national standards and limits.

Moderate Detectable change to the specific environmental conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Detectable but minor change to the specific environmental conditions assessed.

Negligible No perceptible change to the specific environmental conditions assessed.



The ecological surveys only focused on the typical habitats and areas of ecological interest. Due

to the large scale of the Project, it was neither possible nor practical to survey the entire AoI as

part of this ESIA. This impact assessment has made use of the survey data collected in the

previous years as part of Thar Coalfields environmental and social studies (see Section 14.3.2).

This assessment has considered the potential unexpected ecological features and

precautionary mitigation measures along with additional monitoring are included in Section 14.6

and 14.7.


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Table 101: Criteria for determining receptor sensitivity (conservation value)

Conservation value (Sensitivity)

Detail Species criteria Habitat or site criteria

Very high Very high importance and rarity. International scale with limited potential for substitution.

IUCN critically endangered and endangered species.

Internationally designated sites (or equal status). Critical habitats of significant international ecological importance.

High High importance and rarity, national scale, or regional scale with limited potential for substitution, species of international status but not within designated areas.

IUCN vulnerable species. Nationally protected species of significant population size and importance.

Nationally designated sites (or equal status). Areas of critical habitats of national ecological importance, and natural habitats of significant ecological importance and/or high biodiversity with limited potential for substitution.

Medium High or medium importance and rarity, local or regional scale, and limited potential for substitution, species of national status but not within designated areas.

IUCN near threatened species. Nationally protected species or rare species, but not a significant population size and not of national importance.

Regionally important natural habitats. Modified habitats with high biodiversity or under significant threat of loss within the region.

Low Very low or low importance and rarity, and local scale.

IUCN least concern. Species of local importance.

Undesignated sites and natural habitats of local biodiversity and cultural heritage interest. Modified habitats with limited ecological value.

Other sites with little or no local biodiversity and cultural interest. Modified habitats with limited biodiversity value.

Negligible Very limited ecological importance.

IUCN least concern species. Species of no national or local importance.

Highly modified habitats of no biodiversity value.


14.4 Baseline context

14.4.1 National and regional context

Pakistan is located within the Palearctic and Indomalayan ecozones. The ecosystems of

Pakistan range from coastline in the south to the mountain ranges of the Himalayas and Hindu

Kush in the north along with deserts and plains (CBD, 2014). The vegetation is dry and sub-

humid land comprised of xerophytic shrubs and small trees, grasslands and steppe. The

variation in relief and climate means Pakistan has a rich biodiversity and many ecosystems,

habitats and species of global significance. In Pakistan, 195 mammal species (six endemic)

have been recorded, as well as 668 bird species (25 endangered), 177 reptile species (13

endemic), 22 amphibians (nine endemic), 198 freshwater fish (29 endemic) and 5,000 species

of invertebrates, as well as 5,700 species of flowering plants (over 400 endemic) (CBD

Secretariat, 2016).

Main threats to the terrestrial biodiversity in Pakistan are overgrazing, deforestation, illegal

hunting, and habitat disintegration due to population growth and infrastructure development.

The main threats to biodiversity of inland waters are pollution from industrial and municipal

waste. The coastal and marine ecosystems are also threatened from pollution (CBD, 2014).

The Project site is located within the Thar desert and Tharparkar district, in the south-east

province of Sindh. The Thar desert, also known as the Great Indian Desert, occupies 77,000

square miles of rolling sand dunes in eastern Pakistan and the north-western Indian state of

Rajasthan. The annual rainfall in the region is particularly low ranging from 4 to 0 inches and


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most of that falls during the monsoons in summer. Block VI (where the Project is located) is

situated in the north of Thar coalfield and it occupies a land area of about 66.1km2.

Protected areas

Pakistan has 14 national parks, 72 wildlife sanctuaries, 66 game reserves, nine marine and

littoral protected areas, 19 protected wetlands, and a number of other protected areas of

grassland, shrubland, woodland and natural monuments.

There are no protected areas within 15km of the PAA. The closest protected area is Rann of

Kutch, an internationally designated Ramsar site, Important Bird Area (IBA) and nationally

designated Wildlife Sanctuary. The IBA and the Wildlife Sanctuary share the same northern

boundary which is 22.5km from the PAA. The northern boundary of the Ramsar site is 43km

south of the PAA.

14.4.2 Habitats

The Project AoI lies in the Thar Desert, which has a semi-arid tropical climate with four distinct

seasons.

Surveys undertaken in Block VI and Block II identified four main habitat types that include

agricultural fields, sand dunes, plains and human settlements (Hagler Bailly, 2013; Hagler Bailly

2014) (Table 102). Sand dunes were the dominant habitat observed within the Block VI in 2011

(constituting 58% of the habitat), whereas agricultural fields were the dominant habitat observed

in Block II in 2009/2010 (constituting 56% of the habitat).

Table 102: Habitat types within Block VI and Block II AoI

Habitat type Habitats (%) within Project AoI

Block VI, 2011 Block II, 2009/2010

Agricultural fields 36% 56%

Sand dunes 58% 35%

Plains 3% 7%

Human settlement areas 2% 2%

Source: Hagler Bailly (2013; 2014)

The vegetation in the Thar Desert consists of xerophilious grasslands composed of Eragrostis

sp. Aristida adscensionis, Cenchrus biflorus, Cympogon sp., Cyperus sp., Eleusine sp.,

Panicum turjidum, Lasiurus scindicus, Aeluropus lagopoides, and Sporobolus sp. Scrub

vegetation consists of low trees such as Acacia nilotica, Prosopis cineraria, Prosopis juliflora,

Tamarix aphylla, Zizyphus mauritiana, Capparis decidua, and shrubs such as Calligonum

polygonoides, Calotropis sp., Aerva sp., Crotalaria sp.. Haloxylon salicornicum and Haloxylon

recurvum are also present (Hagler Bailly, 2013; Hagler Bailly, 2014).

In July 2011, the dominant species recorded in Block VI included Crotalaria burhia (rattlepod),

Prosopis cineraria (kandi), and Aerva tomentosa (desert cotton) within the agricultural fields.

The dominant species recorded in Block VI in October 2011 in agricultural fields included

Prosopis cineraria (kandi), Aristida sp (threeawn), and Ziziphus nummularia (ber). In Block II in

2009/2010, the plant communities dominating mostly the edge of agricultural lands were

Salvadora oleoides (tooth brush tree), Aerva tomentosa (desert cotton), Leptadenia

pyrotechnica (broom bush), Calotropis procera, Ziziphus nummularia (ber) and Crotalaria burhia

(rattlepod).

In July 2011, the dominant species recorded in Block VI within the sand dunes were Acacia

senegal (gum acacia), Aerva tomentosa (desert cotton) and Leptadenia pyrotechnica (broom


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bush). Dominant species in sand dunes in October 2011 include Indigofera cordifolia (heart-leaf

indigo), Acacia senegal (gum acacia) and Aerva tomentosa (desert cotton). The common and

dominant plants of sand dunes in Block II include Aerva javanica, Acacia senegal, Crotalaria

burhia (rattlepod), Calligonum pollygonoides, Leptadenia pyrotechnica (broom bush), and

Salvadora oleoides (tooth brush tree).

The plains in Block VI included Salvadora oleoides (tooth brush tree), Leptadenia pyrotechnica

(broom bush) and Aerva tomentosa (desert cotton) as the main species in July 2011, and

Indigofera cordifolia (heart-leaf indigo), Salvadora oleoides (tooth brush tree) and Leptadenia

pyrotechnica (broom bush) as the dominant species in October 2011. Due to grazing pressure,

the vegetation of grasses, scrubs and bushes in Block II in 2009/2010 was considered uniformly

degraded (Hagler Bailly, 2013; 2014).

The 2012 surveys described the vegetation within six microhabitats in the Tharparkar district but

only dune crest, dune slope and sandy plains are relevant to the Project AoI. The species

composition of these microhabitats is presented in the Mott MacDonald (2015) report.

14.4.3 Flora

Floristically, the Project is located at the southern limit of the Sindh Province of the Sudano-

Zambezian Region (Tropicos, 2016).

The botanical surveys recorded the following species:

● 123 species recorded during the 2011 field surveys in Block II (Hagler Bailly, 2013)

● 137 plant species recorded in 2009/2010 in Block VI (Hagler Bailly, 2014)

● 162 species recorded in the Tharparkar district in April 2012 (Mott MacDonald, 2015)

● 53 species recorded in the PAA in 2016 (refer to Volume III)

● Of the 162 species recorded in 2012, grasses (Poaceae) were dominant (33 species-

20.37%), followed by Fabaceae (12 species - 7.41%) and Amaranthaceae, Boraginaceae,

Euphorbiaceae (7 species - 4.32% each). Most of the species are annual (51%) followed by

perennial (36%) and biennial (13%) (Mott MacDonald, 2015).

The June 2016 surveys recorded 75 mature trees of four species in the designated PAA:

Prosopis cineraria (kandi), Salvadora persica (jhar), Senegalia modesta (syn. Acacia modesta

syn. Prosopis modesta) (kumbat), and Faidherbia albida (syn. Acacia albida) (roheero).

None of the plant species found during the surveys is threatened globally or nationally. The

2012 survey recorded five endemic species to Pakistan in the Tharparkar district, but they were

not present in the Project AoI (Mott MacDonald, 2015).

Euphorbia caducifolia (leafless milk hedge, thohar) is spread widely throughout the Project AoI

in Block VI, especially in the sand dunes. This species is protected under Appendix II of CITES.

It is widespread in India and Pakistan, in coastal plains and hills; at elevations of up to 800m

above sea level. (Ali and Qaiser, 2001).

Two invasive species were found as part of the ecological surveys for Block VI in 2011 (Hagler

Bailly, 2013): Prosopis juliflora (vilayati babul) and Prosopis glandulosa (honey mesquite). They

were found 18km south of the PAA. Prosopis juliflora is an invasive shrub species native to

South and Central America. It is fast-growing, salt-tolerant and drought-tolerant (Weber, 2013).

This species is a noxious weed in Pakistan and was found in agricultural fields, sand dune and

plains during the surveys for Block VI and Block II (Hagler Bailly, 2013; 2014). This species was

recorded in 40% of the quadrats surveyed in April 2012 in the Tharparkar district, including

Block VI where the Project is located (Mott MacDonald, 2015).


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Prosopis glandulosa (honey mesquite) was recorded in the PAA during the June 2016 surveys

in Block VI. This species is native to the southern United States and northern Mexico, and is

naturalized in Punjab and Sindh.

14.4.4 Mammals

Surveys undertaken in Block VI in 2011 observed or reported signs of 15 mammal species

(Hagler Bailly, 2013) and surveys undertaken in Block II in 2009/2010 observed or reported 20

mammal species (Hagler Bailly, 2014). Twenty seven mammalian species belonging to fifteen

families are reported to occur in the Block II AoI (Hagler Bailly, 2014). No mammal species

recorded in Block VI or Block II are globally/nationally threatened species, endemic species or

protected species in Pakistan.

The 2012 surveys recorded 34 mammal species in the Tharparkar district (Mott MacDonald,

2015). The following species are threatened globally and/or nationally but none of these were

recorded within the Project AoI or Thar Coalfields:

● Indian pangolin (Manis crassicaudata) – IUCN Endangered, Pakistan Vulnerable

● Honey badger (Melivora capensis) – IUCN Least Concern, Pakistan Critically Endangered

● Striped hyaena (Hyaena hyaena) – IUCN Near Threatened, Pakistan Critically Endangered

● Caracal (Caracal caracal) – IUCN Least Concern, Pakistan Critically Endangered

● Asiatic wild ass (Equus hemionus) – IUCN Near Threatened, Pakistan Critically Endangered

● Indian gazelle (Gazella bennettii) – IUCN Least Concern, Pakistan Vulnerable

The June 2016 surveys in the PAA recorded eight mammal species through field signs or direct

observations, including golden jackal (Canis aureus), Indian hare (Lepus nigricollis), Javan

mongoose (Herpestes javanicus) and Indian hedgehog (Paraechinus micropus) (see Volume

III). None of these species are threatened globally or in Pakistan.

The Indian grey wolf (Canis lupus pallipes) is known from the Thar desert but it is very rare; it

was not observed in the Block VI or Block II AoI during the field surveys (Hagler Bailly, 2013;

2014). This species is listed as Endangered on the Pakistani National Red List 2004 and as

Least Concern on the IUCN Red List. The major threats to the species are decline in habitat and

prey species. They are found in subtropical scrubland, tropical dry scrubland, hot desert, open

areas and tropical thorn forest (Sheikh and Molur, 2004).

The common red fox (Vulpes vulpes) and the Bengal fox (Vulpes bengalensis) were identified

during the surveys in 2009/2010 and 2011 (Hagler Bailly, 2013; 2014). Common red fox was

also recorded in the Thar Coalfields in April 2012 (Mott MacDonald, 2015). In addition, an

unidentified fox species Vulpes sp, was observed in Block VI in 2011, in Block II in 2009/2010

and in the PAA in June 2016. There is a possibility that it could be Rueppell’s fox or sand fox

(Vulpes rueppelli) which is listed as Vulnerable on the Pakistani National Red List 2004.

However, the distribution of this species does not cover the Project AoI (IUCN, 2016). This

species is listed as Least Concern in the IUCN Red List.

14.4.5 Birds

A total of 74 bird species were observed in Block VI AoI in 2011 and 88 species were observed

in Block II AoI in 2009/2010 within all habitat types. The species observed include both resident

and migratory birds of which none are water birds because there are no permanent wetlands in

the wider area. Six globally threatened bird species are known in the AoI of Block VI and Block

II: three are listed as Critically Endangered on the IUCN Red List, one is listed as Endangered

and two are listed as Vulnerable (Table 103).


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During the April 2012 survey in the Tharparkar district, 74 bird species were recorded (Mott

MacDonald, 2015) of which 58 are resident, 4 winter visitors, 8 irregular year-round visitors and

4 species are summer breeders according to Grimmett et al. (2008). The following threatened

species were recorded during these surveys: oriental white-backed vulture (or white-rumped

vulture) (Gyps bengalensis), Egyptian vulture (Neophron percnopterus), Indian vulture (Gyps

indicus) and great knot (Calidris tenuirostris) (Table 14.5).

The June 2016 surveys identified 23 bird species in the PAA (refer to Volume III). Of these, two

species are globally and nationally threatened:

● Oriental white-backed vulture (or white-rumped vulture) (Gyps bengalensis) is Critically

Endangered globally (IUCN, 2016) and is considered to be rare in the PAA

● Egyptian vulture (Neophron percnopterus) is globally Endangered and rare in the PAA

Table 103: Nationally/ globally threatened bird species observed in Block VI, Block II, PAA and Tharparkar district

Latin name Common name Distribution in Pakistan (IUCN Red List)

IUCN status CITES appendix

Source

Gyps bengalensis

Oriental White-backed Vulture or White-rumped Vulture

Resident Critically endangered

II Block VI ESIA (2011)

Block II ESIA (2009/2010)

Tharparkar district (2012)

PAA (2016)

Gyps indicus Long-billed Vulture or Indian Vulture

Resident, non-breeding

Critically endangered

II Block VI ESIA (2011)



Neophron percnopterus

Egyptian or Scavenger Vulture

Resident, breeding

Endangered II Block VI ESIA (2011)



PAA (2016)

Aquila clanga Greater Spotted Eagle

Non-breeding Vulnerable II Block VI ESIA (2011)


Aquila heliaca Imperial Eagle Resident Vulnerable I Block VI ESIA (2011)

Calidris tenuirostris

Great Knot Winter visitor Endangered - Tharparkar district (2012)

Source: Data compiled by Mott MacDonald

The oriental white-backed vulture or white-rumped vulture (Gyps bengalensis) was recorded

during all field surveys in 2009/2010 and 2011 (Hagley Bailly, 2013; 2014). Eleven individuals

were sighted over the surveys in 2011 in Block VI and they were observed in all three habitats,

<2km from the PAA. Three empty nests were located on Prosopis cineraria trees in Block II in

2009/2010; these were thought to be nests of either the white-backed vulture or Egyptian

vulture (Neophron percnopterus). In April 2012, oriental white-backed vulture was recorded in

the Nangarparkar tehsil but not in the Thar Coalfields (Mott MacDonald, 2015). Oriental white-

backed vulture was recorded during the June 2016 surveys in the PAA but is considered to be

rare. Gyps bengalensis is close to extinction in Pakistan and is listed as Critically Endangered


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on the IUCN Red List and listed on Appendix II of CITES. They occur mostly on plains and feed

on carrion.

Indian or long-billed vulture (Gyps indicus) was sighted in the 2009/2010 and 2011 field surveys

(Hagley Bailly, 2013; 2014) and is listed as Critically Endangered on the IUCN Red List and

listed on Appendix II of CITES. It is also a qualifying feature of Rann of Kutch IBA, located

22.5km south from the PAA. A total of four individuals were observed in Block VI in locations

approximately 15km from the PAA. This vulture has a small resident population breeding on

cliffs in the extreme south-west Tharparkar district (Hagler Bailley, 2013). In April 2012, Indian

vulture was recorded in Block VI and in the Nangarparkar tehsil (Mott MacDonald, 2015). The

Indian vulture is known to breed in south-east Pakistan and can be found in cities, towns and

villages near cultivated areas, and in open and wooded areas (BirdLife, 2015b). No Indian

vultures were observed to be nesting in Block VI or Block II during the surveys.

Egyptian or scavenger vulture (Neophron percnopterus) is listed as Endangered on the IUCN

Red List and listed on Appendix II of CITES. They typically nest on ledges or in caves on cliffs,

crags and rocky outcrops. They forage in lowland and montane regions over open, often arid,

country and also scavenge at human settlements feeding on carrion, tortoises, organic waste,

insects, young vertebrates, eggs and even faeces. The Egyptian vulture was observed within

Block VI in the survey conducted in 2011 and the location of the record was approximately 1km

from the PAA. A total of two occupied Egyptian vulture nests were identified in the Block VI AoI

in 2011 and two occupied Egyptian vulture nest were identified in the Block II study area in

2009/2010. Additional vulture nests were identified during all surveys but these were empty

(Hagler Bailly, 2013; 2014). The nests were located outside the actual boundary of Block VI,

approximately >8km from the PAA. As part of the surveys in April 2012, Egyptian vulture was

recorded in Blocks II and IV, but it was concluded that they roost, nest and breed in the

Nagarparkar tehsil, which is at least 100km from the Project AoI (Mott MacDonald, 2015). As

part of the surveys in June 2016, this species was also reported by local people in the PAA (see

Volume III).

Threats to vultures are mainly due to anti-inflammatory drugs used to treat domestic livestock

which are poisonous to the birds. Other threats include changes in human consumption and

processing of dead livestock (BirdLife, 2015a).

Greater spotted eagle (Aquila clanga) is listed as Vulnerable on the IUCN Red List and listed on

Appendix II of CITES. The species occupies a fragmented range including small numbers in

Pakistan and north-west India. It occurs in lowland forests near wetlands, nesting in tall trees. It

feeds on retrieved quarry, small mammals, waterbirds, frogs and snakes and hunts over

swamps and wet meadows (BirdLife, 2013a). These habitats are found mainly in the Rann of

Kutch Ramsar site, IBA and Wildlife Sanctuary south of the Project AoI. One individual was

observed in agricultural fields in Block VI in 2011, approximately 8km west of the PAA.

Imperial eagle (Aquila heliaca) was recorded over 2km from the PAA within Block VI during the

October 2011 surveys. It is listed as Vulnerable on the IUCN Red List and listed on Appendix I

of CITES. It is a scarce winter visitor to Sindh, it prefers open plains and deserts and avoids

high mountainous regions (BirdLife, 2013b).

Red-headed vulture or king vulture (Sarcogyps calvus) has not been confirmed in the Project

Aol. It is listed as Critically Endangered on the IUCN Red List and listed on Appendix II of

CITES. It was not recorded during the 2009/2010 surveys in Block II (Hagley Bailly, 2014), the

2011 surveys in Block VI (Hagler Bailly, 2013), 2012 surveys in the Tharparkar district (Mott

MacDonald, 2015) or 2016 surveys in the PAA. However, the Project AoI falls within the

distribution of this species (BirdLife, 2015c). They are a rare occurrence in the Tharparkar area,


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they are usually found in open country away from human habitation, well-wooded hills and dry

deciduous forest with rivers (BirdLife, 2015c). Nests have been recorded in tall trees (BirdLife,

2015c), however no tall trees were recorded within Block VI or Block II during the field surveys

(Hagler Bailly, 2013).

Great knot (Calidris tenuirostris), globally Endangered, was recorded in 2012 in the

Nangarparkar tehsil outside the Thar Coalfields and Project AoI (Mott MacDonald, 2015). This is

species is very unlikely to occur in the Project AoI because there are no suitable wetlands for

them to winter.

Pakistan lies within the Asian Migratory Flyway, which is used by large numbers of migrating

birds from Europe, Central Asian States and India every year. No significant presence of

migratory birds has been reported from the Block VI or Block II AoI.

14.4.6 Herpetofauna (reptiles and amphibians)

During the 2009/2010, 29 reptile species and two amphibian species were identified as being

present or likely to be present within Block II AoI (Hagler Bailly, 2014). During the 2011 surveys,

19 reptile species and one amphibian species were identified within Block VI AoI (Hagler Bailly,

2013). Surveys in the Tharparkar district in 2012 recorded 20 reptile species and two amphibian

species (Mott MacDonald, 2015). The June 2016 surveys recorded 10 reptile species in the

PAA, including Indian spiny-tailed lizard (Saara hardwickii), saw-scaled viper (Echis carinatus

sochureki), Indian desert monitor (Varanus griseus koniecznyi) and black cobra (Naja naja) (see

Volume III).

No globally/nationally threatened species were recorded in the AoI of Block VI and Block II, in

Tharparkar district in 2012, or in the 2016 surveys in the PAA. Two Pakistani endemic reptile

species (striped sand gecko Crossobamon maynardi and Kachh spotted ground gecko

Cyrtopodion kachhense) were identified during the 2012 surveys but they were in the

Nankarparkar tehsil, away from the Thar Coalfields and Project AoI (Mott MacDonald, 2015).

The Indian desert monitor (Varanus griseus koniecznyi) was observed in all surveys, is listed

under CITES (Appendix I). The Indian spiny-tailed lizard (Saara hardwickii), common sand boa

(Eryx johnii), chain sand boa (Eryx conicus) and black cobra (Naja naja) were all observed

within Block VI and Block II AoI and are listed under CITES (Appendix II). None of these species

have been assessed on the IUCN Red List.

One endemic reptile species to Pakistan, the Cholistan desert lacerta (Eremias cholistanica)

was found in both Block II AoI in 2009/2010 and Block VI AoI in 2011. Eleven individuals where

observed in Block II, mainly in agricultural fields, approximately 7km south-west of the PAA.

Two individuals were found in Block VI surveys in plains and agricultural fields, with the closest

observation also approximately 7km south-west of the PAA.

14.4.7 Invertebrates

The diurnal surveys undertaken in July 2011 in Block VI observed invertebrate specimens

(excluding butterflies) belonging to 19 taxa and butterfly specimens belonging to 4 taxa. During

the diurnal surveys undertaken in Block VI in October 2011 (post-monsoon), invertebrate

specimens belonging to 65 taxa, and butterfly specimens belonging to 14 taxa were found.

The highest abundance of invertebrates observed in July 2011 (diurnal and nocturnal surveys)

was within agricultural fields whereas the highest abundance of invertebrates observed in

October 2011 was in sand dune habitat. Sand dunes also contained the highest abundance of

butterflies in both diurnal surveys.


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No globally/nationally threatened species were recorded in the Project AoI in any of the previous

surveys; however, there is little research on invertebrates in Pakistan.

14.4.8 Consideration of critical habitat

As part of the ESIA for Block VI Thar coalfield, a critical habitat assessment was undertaken

(Hagler Bailly, 2013) using the IFC PS6 (IFC, 2012a) and associated Guidance Note 6 (IFC,

2012b). It was concluded that critical habitat was not present in the AoI of that Project for Block

VI. The conclusion is also valid for the Project subject to this EIA.



14.5.1.1 Overview

This section presents the identification and assessment of the following potential biodiversity

impacts of the Project during the construction phase.

Construction impacts:

● Terrestrial habitat and flora loss and degradation (permanent and temporary)

● Disturbance to terrestrial animal species (eg dust, noise, artificial light)

● Injury or death of terrestrial animals

● Habitat fragmentation

● Accidental introduction and dispersal of invasive species from construction activities, which

could have a long-term and irreversible impact on the local biodiversity

● Increase in road kills and injuries of wildlife.

14.5.1.2 Protected areas

Rann of Kutch Rasmar site, IBA and Wildlife Sanctuary is located over 22.5km south of the

PAA. Due to the distance from the Project site, the identified protected areas are unlikely to be

affected by the construction works. The conservation value of the protected area is considered

to be very high (international importance), but impact magnitude is negligible. The resulting

ecological effects are therefore negligible and not significant.

14.5.1.3 Habitats and flora

The Project AoI comprises mainly agricultural fields, sand dunes and sandy plains. The

development will result in the permanent loss of small areas of these habitats. The habitat loss

will include 15.75ha within the footprint of the Project and 2.25ha on a separate site for the

accommodation camp. These habitats are considered to be widespread and of low conservation

value, and the impacts of the works will be moderate in magnitude. Therefore, the construction

impacts on habitats will be permanent and of minor significance in the absence of mitigation.

The botanical surveys in 2009/2010, 2011, 2012 and 2016 in the Project AoI and wider area

indicate mainly common species of flora are present, with no globally or nationally threatened

species recorded. These species are generally considered to be of low conservation value. The

plant species on site will be directly affected by the development. Indirect impacts on species

within the AoI may include increased dust and disturbance through increased traffic. Impacts on

flora species are considered to be moderate in magnitude and the impacts will be permanent

and of minor adverse significance and not significant.


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Accidental introduction and dispersal of invasive species such as vilayati babul (Prosopis

juliflora) and honey mesquite (Prosopis glandulosa) from construction activities could increase

the magnitude of the impacts in the absence of mitigation measures as they will compete with

native flora. However, the impact would still be of minor adverse and not significant.

14.5.1.4 Fauna

Mammals

Land disturbance caused by Project activities will lead to a localised reduction in food, shelter

and range for mammals. Surface stripping will result in the removal of vegetation cover and may

cause accidental death of small mammals. Artificial lighting and noise during construction will

cause disturbance to mammals in the Project AoI. Mammals may also be subject to hunting and

poaching by construction staff in the absence of mitigation. However, mammals are mobile and

are likely to move away from the area when the works commence.

No mammals of international or national conservation value were confirmed in the Project AoI

during the surveys conducted in 2011 (Hagler Bailly, 2013), 2009/2010 (Hagler Bailly, 2014),

2012 (Mott MacDonald, 2015) or 2016 (Volume III). There are records for nationally and globally

threatened mammals in the wider area of Thar District (e.g. Indian grey wolf, honey badger) but

these species are unlikely to be affected by the Project.

The mammal species recorded in the AoI of the Project are of low conservation value and the

construction impacts are considered to be of moderate magnitude. The resulting impact of

construction on mammals is temporary and minor adverse and therefore not significant.

Birds

Birds are likely to be affected during the construction of the Project because of loss and

degradation of habitat, noise, artificial lighting, habitat loss, presence of people, and hunting.

The habitats in the Thar Desert are important for the survival of several globally threatened

raptor species. The following species are confirmed in the Project AoI: oriental white-backed

vulture or white-rumped vulture (Gyps bengalensis), Egyptian vulture (Neophron percnopterus),

long-billed vulture or Indian vulture (Gyps indicus). Both oriental white-backed vulture and

Egyptian vulture nest in the Tharparkar district but the known nests are not in the Project AoI.

These species are of very high conservation value. Impacts on globally or nationally threatened

bird species are considered to be moderate and therefore the resulting impact of construction

will be temporary, resulting in a major adverse impact and therefore will be significant in the

absence of mitigation.

There are many common species of birds recorded in the Project AoI (Section 14.4.5) and these

are of low conservation value. Impact magnitude is likely to be moderate and the resulting

impact will be temporary and minor adverse and not significant.

Herpetofauna

Impacts on globally/nationally threatened or endemic reptiles and amphibians are considered to

be negligible, given that none were recorded in the Project Aol. The resulting impact is

considered to be negligible and therefore not significant.

The common species of reptiles and amphibians in the Project AoI are likely to be affected

during the construction of the Project because of habitat loss and degradation, animal deaths

and injuries, noise and vibration, artificial lighting and dust. These species are of low

conservation value and the construction impact magnitude is likely to be moderate. The

resulting impact is temporary and minor adverse and not significant.


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Invertebrates

Habitat loss/degradation, artificial light and dust are likely to have a negative impact on

terrestrial invertebrates during construction. The magnitude of these impacts is considered to be

moderate. Given the low conservation value of the invertebrates in the Project AoI, the resulting

impact of construction is minor adverse and temporary and therefore not significant.


14.5.2.1 Overview

This section presents the identification and assessment of the following potential biodiversity

impacts of the Project during operation:

● Increased noise and disturbance to fauna due to increased road traffic for the delivery of coal

and exportation of ash and loading of materials

● Disturbance affecting birds and mammals from light and human presence from operation

activities

● Increase in road kills and injuries of wildlife

● There is a low pollution risk from the storage of the coal

● Degradation of air quality because of the power plant emissions and ash disposal

The following sections assess these impacts in relation to the biodiversity receptors and these

sections are therefore organised according to receptor types.

14.5.2.2 Protected areas

The Rann of Kutch Ramsar site, IBA and Wildlife Sanctuary is located over 22.5km south of the

PAA. Due to the distance from the Project site, the identified protected areas are unlikely to be

affected by the operational activities. The conservation value of the protected area is considered

to be very high (international importance), but impact magnitude is negligible. The resulting

ecological impacts are negligible and therefore not significant.

14.5.2.3 Habitats and flora

There are no sensitive habitats on the Project site and Aol that will be affected during operation.

The habitats close to the Project may be affected by indirect degradation due to dust deposition

or pollution (in the absence of mitigation). The habitats in the Project AoI are of low conservation

value and impact magnitude during operation is considered to be minor; the operational impact

on habitats and flora is therefore negligible and not significant.

14.5.2.4 Fauna

Mammals

Mammals in the Project AoI may be affected by noise, artificial lighting, degradation of air

quality, and increase in road kills during the operation of the Project. Mammals may also be

subject to hunting and poaching by operational staff in the absence of mitigation. These impacts

are considered to be of minor magnitude. The mammal species recorded in the Project AoI are

common and of low conservation value. The resulting impact of operation on mammals is

therefore negligible and not significant.

The impact magnitude on threatened mammal species of high conservation value is considered

to be negligible during operation as these species have not been recorded in the Project AoI.


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The overall operational impact on threatened mammals is therefore negligible and not

significant.

Birds

Birds in the Project AoI may be affected by noise, artificial lighting, presence of people, hunting

by operational staff, and degradation of air quality during operation of the Project.

The following globally threatened species are known from the Project AoI but there are no

confirmed nests there: oriental white-backed vulture or white-rumped vulture (Gyps

bengalensis), Egyptian vulture Neophron percnopterus, long-billed vulture or Indian vulture

(Gyps indicus). These species are of very high conservation value but impact magnitude during

construction is considered to be minor. The resulting impact is therefore permanent and

moderate adverse and therefore significant.

The other bird species recorded in the Project AoI are common and of low conservation value.

Impact magnitude on these species is likely to be minor and therefore the operational impacts

are negligible and not significant.

Herpetofauna

No globally or nationally threatened reptiles and amphibians were recorded in the Project Aol

and operational impacts on these species are negligible. The resulting impact is considered

negligible and not significant.

The common herpetofauna occurring within the AoI are of low conservation value. During the

operation of the Project, these species may be affected by noise, artificial lighting, degradation

of air quality, and increase in road kills. Impact magnitude on these species is likely to be minor

and therefore the impacts are negligible and not significant.

Invertebrates

The common species of terrestrial invertebrates present within Project AoI are of low

conservation value. They may be affected by degradation of air quality and artificial light

pollution during the operation of the Project. The magnitude of the impacts is considered to be

minor and the overall impact is negligible and not significant.


14.6.1 Overview

Mitigation measures have been developed for key biodiversity features to ensure the systematic

implementation of the mitigation hierarchy i.e. avoid, reduce (minimise), remedy (restore) and

offset. This will allow for the careful management of risk, and the best possible outcomes for the

Project without compromising the health, function and integrity of the ecological systems.

14.6.2 Avoidance measures incorporated in Project design

The design of the Project has taken into consideration the environmental and ecological

sensitivities, with the aim to avoid significant impacts on the areas of high nature conservation

value, in particular:

● The Project location has been chosen in an area where existing infrastructure can be

maximised for the delivery of coal and the transport of waste ash.


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● The Project will comply with safety standards to avoid spillages and leakages from

chemicals, liquids and other substances stored onsite. Set procedures will be followed where

spillages and leakages do occur.

14.6.3 Generic mitigation measures

The following generic mitigation measures will be applied on the Project:

● All construction and operational working areas will be kept to the minimum to reduce habitat

loss and degradation.

● Access routes for construction and operational activities outside the existing cleared area (if

required) will be kept to a minimum. Plans will be implemented to minimise all construction

traffic activities outside the Project area. These actions will significantly reduce potential

impacts on habitats and disturbance to species.

● Artificial lighting used on construction sites and camps will be minimised, shaded and

directed downwards to avoid light spillage and disturbance to birds, mammals and other

wildlife.

● Noise disturbance and vibration will be kept to a minimum through measures such as

ensuring proper maintenance of construction machinery and equipment and complying with

national standards;

● Measures such as wind breaks and water sprays will be implemented to reduce dust during

the working period.

● Spill prevention and response measures will be implemented with regard to refuelling and

use of toxic substances to minimise accidental contamination of habitats.

● Enforcement of speed limits along access and haul roads to minimise the risk of road kills.

● Implementation of waste management practices to prevent food waste being left accessible

to scavengers.

● Construction and operation staff will be made aware of the importance of biodiversity in the

Project area (through staff inductions, posters in site offices, leaflets and signs banning

certain activities e.g. no hunting).

14.6.4 Habitats and flora

There are no internationally or nationally protected habitats likely to be affected by the Project.

The Project will result in 15.75ha of permanent habitat loss within the main Project site and

2.25ha of temporary loss for the accommodation camp. There will be additional temporary

habitat clearance required for the new access road within Block VI.

Light water sprays will be implemented for reduction of dust during construction.

Any habitat clearance required will be restored on-site (if the impact is temporary) or recreated

off-site through new planting using native species that do not require special irrigation measures

in the long term. Seventy-five trees (mainly kandi Prosopis cineraria and jhar Salvadora persica)

will need to be removed within the PAA. Given that tree survival rate in arid environments is

relatively low, the 75 trees to be removed should be replaced on-site or off-site at a ratio of 6:1.

14.6.5 Non-native invasive species

Non-native (alien) invasive species are the second threat to the global biodiversity after habitat

destruction. The likelihood of invasions by non-native species is higher in habitats that are


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altered and disturbed, for example during construction. Invasive species have the following

traits:

● Fast growth

● Rapid reproduction

● High dispersal ability

● Ability to alter growth form to suit current conditions

● Tolerance of a wide range of environmental conditions

● Ability to live off a wide range of food types

● Association with humans

Any development project poses a risk of spreading invasive species. Two invasive species have

been recorded in the Project AoI: vilayati babul (Prosopis juliflora) and honey mesquite

(Prosopis glandulosa). Measures to prevent the spread of these species will be implemented in

line with the recommendations below.

IFC PS6 (IFC, 2012a) includes the following best practice measures with regard to alien

invasive species (AIS):

● Must not intentionally introduce alien species unless this is in accordance with existing

national regulatory framework

● Must not deliberately introduce AIS irrespective of national regulatory framework\

● Introduction of alien species (e.g. in planting) must be subject to a risk assessment

● Implement measures to avoid accidental introduction or spreading of alien species (detailed

as follows)

● Consider the implementation of measures to eradicate AIS from natural habitats.

Detailed guidelines on the prevention and management of AIS have been published by IPIECA

(2010) for the oil and gas industry, but these guidelines are relevant to many other project types,

including this Project. Preventative, control and monitoring measures will be implemented with

regard to the following aspects of the Project:

Packaging and movement of materials

● Minimise traffic and the distance it has travelled

● Source goods/materials locally where possible

● Contain any AIS and report their presence

Vehicles and plant

● ‘As-new’ wash-down is essential before entering non-infested areas and after working in

infested areas

● Train and raise awareness regarding AIS

● Pressure wash vehicle tyres in a contained area

● Contain and destroy residue

● Record and report the presence of any AIS

Soil and vegetation

● Minimise disturbance to, or movement of, soil and vegetation

● Prevent soil damage and erosion


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● Ensure imported soil/other materials are safe and free of AIS (source from a reputable

supplier, request information on the soil’s origin and certification of AIS-free status if

possible)

● Prevent AIS establishment on exposed stored soil (do not store bare soil near known

sources of AIS, consider using matting to cover exposed soil)

● Ensure infested material is disposed of safely

● Retain as much natural vegetation as possible

Habitat reclamation

● Use native plants for reinstatement and landscaping

● Assess any non-native species (to be used in landscaping) for AIS potential

● Consider that some AIS may be soil-based

● Avoid altering soil and waterbody properties

14.6.6 Fauna

Habitat loss will be minimised, and where possible a phased vegetation clearance should be

undertaken, to ensure animals are able to escape the works area during construction. Noise

and disturbance will be minimised through best practice measures during construction and

operation.

To minimise the potential impact to all breeding bird species, vegetation clearance will be

undertaken outside of the main bird nesting period (breeding season is between April and July).

Where clearance is not possible outside the breeding season, a check for breeding birds and

active nests by a qualified ecologist will be undertaken within 48 hours of vegetation clearance.

If breeding birds are discovered then works will be postponed in that area until the breeding

cycle is complete (this may take up to three weeks). A species specific buffer zone (minimum

25 m) will be set up around the nest site.

Deep excavations will be protected (covered up) overnight or when not working to prevent

animals being trapped inside. Additionally, ramps will be installed in deep excavations to allow

animals to escape. If any animals are trapped in excavations, they will be released into a safe

area or an ecologist will be consulted to agree the best course of action.

The following best practice noise reduction measures will be implemented to reduce impacts on

birds during construction:

● Avoidance of unnecessary revving of engines and switch off equipment when not required

● Vehicles and equipment will be properly maintained to meet the manufacturers’ noise rating

levels. Any silencers or bearings which become defective would be replaced as soon as

possible

● Using reverse warning systems incorporating broadband noise where practicable

● Using enclosures for noisy plant such as pumps or generators

● Minimising drop height of materials

● Limiting the use of particularly noisy plant or vehicles where practicable

● Plant and vehicles will be operated with noise control hoods closed.

Hunting of wild animals by construction and operation staff will not be permitted. All staff will be

required to follow company rules and code of conduct. Any staff member breaching the hunting

ban will be subject to disciplinary action.


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It is understood that Sindh Carbon Energy Ltd. (SCEL) intends to prepare a BAP for the

management, protection and restoration of vulture species and to prevent the decline in their

population due to coal mining and power generation activities in the Thar area. The proposed

BAP should incorporate actions relevant to the Project in addition to the coalfields.

The Project will require an electricity transmission line connection of 160km. This is an

associated facility, which will be the responsibility of the Government of Sindh. The following

recommendations should be implemented:

● The powerlines, masts and towers should be designed in such a way that they do not lead to

bird mortality.

● Bird deflector devices should be installed on pylons and conductors to minimise bird

electrocution and collision.

● The transmission line pole and insulator design should follow the CMS Guidelines for ‘avian-

safe’ lines (Prinsen et al., 2012), African-Eurasian Waterbird Agreement (AEWA) Guidelines

(www.unep-aewa.org/), Birdlife International Position Statement on birds and power lines

recommendations and suggested practices (Birdlife International, 2013c) and Avian Power

Line Interaction Committee suggested practice (APLIC, 2006).


Monitoring of ecological mitigation will be conducted for the duration of the construction phase.

These requirements, along with associated responsibilities and reporting requirements will be

detailed in the CESMP. The Environmental Manager will ensure the measures included in this

report and the CESMP are implemented during the construction of the Project. Specialist advice

from a qualified ecologist will be obtained when required. The environmental (including

ecological) reporting responsibilities during construction will be described in the CEMP.

The compensatory tree planting on-site or off-site will be maintained and monitored for a

minimum of five years. Maintenance will involve provision of water, removal of weeds, control of

pests and replacement of any dead trees.

Monthly monitoring should be carried out in the first year after construction along the

transmission line routes to check for evidence of bird deaths due to electrocution and collisions.

If evidence is found of bird deaths resulting from electrocution or collision then appropriate

remediation measures should be put in place; this may mean replacing the type or location of

bird deflector devices.


Without mitigation, most of the Project’s impacts are considered to be not significant (minor and

negligible). The only significant impacts before mitigation are on threatened birds (major during

construction and moderate during operation). All impacts will be significantly reduced through

the responsible implementation of the mitigation measures, which are described in Section 14.6.

After the successful implementation of the mitigation measures, there will be no significant

residual impacts.

Table 104 summarises the residual impacts of the Project on the key ecological features which

occur within the AoI.


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Table 104: Summary of Project impacts before and after mitigation

Receptor Potential Impacts

Conservation importance (sensitivity)

Impact magnitude

Impact significance

Mitigation Residual impacts

Construction

Protected areas

Rann of Kutch (Ramsar site, IBA and Wildlife Sanctuary)

Impacts unlikely as these sites are more than 22km from the Project site

Very high

High

Negligible

Negligible None required Negligible, not significant

Habitats and flora

Widespread habitats: sand dunes, sandy plains, agricultural fields

Loss and degradation of habitat

Low

Moderate

Minor Pollution prevention, reduction of dust, and best practice measures to minimise habitat loss and degradation

Minor, not significant

Common flora species

Direct loss and degradation of common flora within the Project area.

Introduction of invasive species competing with native flora

Low

Moderate Minor

Pollution prevention, reduction of dust, and best practice measures to minimise habitat loss and degradation.

Measures to prevent/minimise the spread of invasive species.


Notable fauna

Common mammal species

Loss, fragmentation and degradation of habitats

Disturbance from noise, light pollution and human presence

Increased dust and pollutants from construction

Hunting by construction staff

Low Moderate Minor Avoidance or minimisation of habitat loss and degradation.

Phased habitat clearance.

Best practice measures to reduce noise.

Pollution prevention.

Hunting ban by construction staff.


Threatened bird species

Habitat loss and degradation

Disturbance because of noise, lighting and presence of people

Very High and High

Moderate Major Avoidance or minimisation of habitat loss and degradation.





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Impact magnitude

Impact significance





Pre-construction checks for nesting birds.

Common bird species









Pre-construction checks for nesting birds.


Common herpetofauna species








Common terrestrial invertebrate species

Habitat loss/degradation, artificial light and dust

Low Moderate Minor Pollution prevention and best practice measures to minimise habitat loss and degradation.


Operation

Protected Areas

Rann of Kutch (Ramsar site, IBA and Wildlife Sanctuary)

Impacts unlikely as these sites are more than 22km from the Project site

Very high

High

Negligible

Negligible None required. Negligible, not significant

Habitats and Flora

Widespread habitats: sand dunes, sandy plains, agricultural fields

Dust deposition and air pollution

Low

Minor

Negligible Pollution prevention measures.


Common species

Loss and degradation of common flora

Low

Minor Negligible




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Impact magnitude

Impact significance


due to pollution.

Introduction of invasive species competing with native flora

Notable Fauna

Common mammal species


Increased dust and pollutants

Increase in road kills

Hunting by operational staff

Low Minor Negligible Best practice measures for noise and lighting.


Hunting ban.

Speed limits.


Threatened birds Disturbance from noise, light pollution and human presence



Very High Minor Moderate Best practice measures for noise and lighting.


Hunting ban.


Common bird species






Hunting ban.


Common herpetofauna species



Increase in road kills



Hunting ban.

Speed limits.


Common terrestrial invertebrate species

Degradation of air quality and artificial lighting





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15 Social impact assessment

15.1 Introduction

15.1.1 Overview of the assessment

This chapter looks at how people and communities may be affected as a result of the Project in

terms of the way they live, work and interact with one another on a day-to-day basis. The broad

objectives of this assessment are to ensure that key potential socio-economic and community

impacts have been identified, assessed, mitigated and managed in a consultative and

constructive manner.

Social and community impacts have been assessed and identified as significant in relation to

employment generation and the potential influx of workers. Consideration has also been given

to avoiding and mitigating any potential impacts related to occupational and community health

as well as safety and security risks from construction activities resettlement and land

acquisition.

Environmental impacts from construction activities could also have a cumulative impact on local

community receptors such as schools and hospitals, however to avoid double counting of

impacts these have been addressed within their respective chapters and are not covered again

here. Specifically: air quality and dust impacts are assessed in chapter 7 and noise and

vibration are covered in chapter 9.

15.1.2 General approach

The process followed has been one of analysing, monitoring and managing the intended and

unintended socio-economic and community consequences - both positive and negative - of the

Project, and any social change processes invoked by the interventions.

The socio-economics and community assessment undertaken for this ESIA has been carried

out to meet Pakistani requirements. The approach and methodology draws on guidance for

social impact assessment by the International Association for Impact Assessment (IAIA)36. The

IAIA conceptualises social impacts as changes to one or more of the following:

● People’s way of life – how they live, work, play and interact with one another on a day-to-day

basis

● Their community – its cohesion, stability, character, services and facilities

● Their culture – their shared beliefs, customs, values and language use

● Their environment – the quality of the air, water, food, amenity, safety and pollution risks

● Their health and wellbeing – physical, mental, social and spiritual wellbeing and perceptions

of safety

● Their personal and community property rights – access issues and economically affects

Adverse impacts will be avoided and wherever possible, management and mitigation measures

have been identified to reduce their effects on the community. Where impacts are beneficial,

measures are designed to enhance the effects and share their benefits more widely, in

particular amongst local people who may also be affected negatively by the Project.

36 International Association for Impact Assessment, Social Impact Assessment: International Principles, May 2003.


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15.2 Applicable legislation and standards


15.2.1.1 EIA consultation requirements

The Pakistan Review of IEE and EIA Regulations (2000) and the SEPA (Review of IEE and

EIA) Regulations (2014) state that in the case of an EIA being conducted for a project, the

following consultation requirements are to be met by the Federal Agency in charge:

● A public notice is to be issued in English and Urdu in a local newspaper within the project

area. The notice should contain: a) the name of the project, b) its exact location, c) the name

and address of the proponent and d) the places where the EIA can be accessed.

● The public notice issued should contain the date, time and place of the public consultation to

be held with stakeholders, where they are able to provide comments on the project and its

EIA.

● Public consultation should not be earlier than 30 days after the date of publication of the

public notice.

● The EIA must be circulated to all relevant government agencies.

● All comments received by the Federal Agency from the public and/or any government

agency shall be collated, tabulated and duly considered before finalising the EIA.

The Guidelines for the Preparation and Review of Environmental Reports (1997) state that in

order for the environmental and social assessment to be credible, fair and transparent, full

public involvement should be a part of the process. This should include:


● Publishing lists of decisions – including the requirement for an EIA and the final outcome of

environmental approval

● Public availability of any recommendations for mitigation and impact management plans

According to the Guidelines for the Preparation and Review of Environmental Reports (1997),

good ways to disseminate the information contained within the EIA include local language

video, radio and television, presentations, newsletters and information sheets, displays

(supported by members of the study team), gatherings such as local community groups, small

meetings and workshops.

The Guidelines for Public Consultation (1997) deal with approaches to public consultation and

techniques for designing an effective program of consultation that reaches out to all major

stakeholders and ensures the incorporation of their concerns in the impact assessment. These

guidelines will be applied when undertaking the consultation for this Project.

15.2.1.2 Labour, occupational health and safety and resettlement legislation

Labour rights are established in the constitution of Pakistan. Labour laws are elaborated on

national level through acts and ordinances that cover specific issues including limits to working

hours, minimum working age and conditions of employment.

Of the 24 labour-related laws that existed in 2014 in Pakistan (Pasha, 2014), the following relate

directly to the International Labour Organisation (ILO)’s Core Labour Standards which Pakistan

has ratified:

● Bonded Labour System (Abolition) Act, 1992


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● Employment of Children Act (ECA), 1991 (prohibits child labour in Pakistan under the age of

14)

● Minimum Wages Ordinance, 1961

● Industrial Relations Act, 2010

● West Pakistan Minimum Wages for Unskilled Workers’ Ordinance, 1969

There are no laws covering equal remuneration for male and female workers undertaking work

of equal value and removal of discrimination in respect of employment and occupation.

Key labour market regulatory requirements that are relevant to maintain labour rights for this

Project include (World Bank, 2014; Paycheck, 2015; The Nation, 2013):

● Maximum length of a single fixed-term contract: 9 months

● Maximum working days per week: 6

● Premium for work on weekly rest day (% of hourly pay): 100%

● Maximum length of probationary period: 3 months

● Notice period for redundancy dismissal (average for workers with 1, 5 and 10 years of

tenure): 4.3 salary weeks

● Severance pay for redundancy dismissal for a worker with 1 year of tenure: 4.3 salary weeks

Health, safety and welfare of workers at factories, construction sites and labour camps are

addressed in the Factories Act of 1934 (as amended). These regulations will be applicable to

the Project and particularly during construction. They place responsibility on the EPC contractor

to provide a healthy and safe environment to workers, including workers of subcontractors. The

relevant provincial labour department is responsible for taking the necessary measures to

ensure compliance with the Factories Act. There is no requirement to obtain any permit or

license from the Labour Department to start construction of the Project.

15.2.1.3 Land acquisition

The only national legislation currently relating to land acquisition and compensation is the Land

Acquisition Act (LAA) of 1894. Under the LAA, the provincial revenue departments are

empowered to carry out the acquisition of private land or built-up property for public purposes,

including on behalf of a federal agency or a private developer. The LAA is limited to a cash

compensation policy for the acquisition of land and built-up property, and damage to other

assets, such as crops, trees, and infrastructure based on market rates.



The Project has been assessed by comparing the existing social baseline conditions with the

change expected over time as a result of the Project. The temporal scope of assessment

includes the following phases of the Project:

● Resettlement and site preparation: Lignite Mining Project will implement resettlement from

Q4 2016 - 2019

● Main construction phase: Expected to commence in 2020, lasting up to 2023

● Operations: Expected to commence in 2021

● Decommissioning: The plant is expected to have a lifetime of at least 30 years and an

assessment of any works necessary to keep the plant operating will be undertaken at that

time.


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The spatial scope of the social and community assessment has been defined by geographical

and administrative boundaries. Pakistan is divided into four territories and four provinces

including the Sindh province where the coal fields have been discovered. The Sindh province is

divided into 29 districts including the Tharparkar district where the Power Plant Project is

located.

The Thar Coalfield is spread across an area over 9,000 km² within the district of Tharparkar and

is located approximately 380km east of the province capital, Karachi. Tharparkar is further

divided into six37 talukas38. The Project’s impacts have been assessed at three scales and

baseline data is presented for each:

Table 105: Project area of Influence

Area of influence Location

Wider Area of Influence (WAI) Islamic Republic of Pakistan

Local Area of Influence (LAI) The Sindh Provide

District of Tharparkar

Talukas (Mithi, Diplo, Islamkot, Nagarparkar, Chachro and Dahli)

Immediate Area of Influence (IAI) Five villages in Block VI: Ranjho Noon, Yaqoob ji Dhani, Yousuf ji Dhani, Gangoo ji Dhani and Salar ji.

15.3.2 Data sources

Information for this assessment has been obtained from a number of secondary data sources

including the ESIA of the Block VI Lignite Mining Project (2013), the SESA (2014) and the

interim RAP (2013) as well as the national census (1998) and information provided by

international financial institutions. In addition, in June 2016, primary data on the affected

communities within the Project’s IAI was obtained through focus group undertaken by local

consultants. The chapter uses this information to reflect on the socio-economic situation of the

local population.

15.3.3 Significance criteria

The significance of an impact has been determined by the interaction between its magnitude,

and the sensitivity of receptors affected. Professional judgement has been used by

appropriately qualified social scientists when assigning significance. The use of these two

concepts for this assessment is outlined below.

The sensitivity of receptors has been estimated through consideration of their socio-economic

vulnerability. This is measured by their capacity to cope with social impacts that affect their

access to, or control over, additional or alternative social resources of a similar nature,

ultimately affecting their wellbeing. Sensitive or vulnerable receptors are generally considered to

have less means to absorb adverse changes, or to replicate beneficial changes to their resource

base than non-sensitive or non-vulnerable receptors.

When considering sensitivity, the type of resources in question varies between receptors. For

example, a community’s vulnerability has generally been measured in terms of its resilience to

loss of community facilities, whereas an individual’s vulnerability has generally been considered

in relation to their resilience to deprivation and loss of livelihood assets or opportunities (such as

jobs, productive land or natural resources). Impacts that increase impoverishment risks

37 Mithi (district headquarters), Diplo, Islamkot, Nagarparkar, Chachro and Dahli, even though during the last census (1998) only four

have been reflected 38 A taluka is an administrative area which has a town or city as its administrative centre and is usually surrounded by a number of other

settlements.


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contribute to vulnerability. Impoverishment risks include landlessness, joblessness,

homelessness, marginalisation, increased morbidity and mortality, food insecurity, loss of

access to common property resources and social disarticulation. Table 106 presents the

guideline criteria that have been used to categorise the sensitivity of receptors.

Table 106: Sensitivity criteria

Sensitivity of receptors

Definition

High An already vulnerable social receptor with very little capacity and means to absorb proposed changes or with very little access to alternative similar sites or services.

Medium An already vulnerable social receptor with limited capacity and means to absorb proposed changes or with little access to alternative similar sites or services.

Low A non-vulnerable social receptor with some capacity and means to absorb proposed changes and with some access to alternative similar sites or services.

Negligible A non- vulnerable social receptor with plentiful capacity and means to absorb proposed changes and with good access to alternative similar sites or services.


The magnitude of an impact has been determined by consideration of the extent to which it

results in social receptors gaining or losing access to, or control over, socio-economic resources

resulting in a beneficial or adverse impact on their individual and collective wellbeing. Wellbeing

is considered as the financial, physical and emotional conditions and quality of life of people and

communities.

For beneficial impacts, the extent to which local wellbeing is likely to be enhanced has been

considered. This is in accordance with the international movement in social impact assessment

practice with increased focus on enhancing long-term development benefits for local

communities’ sustainability, as opposed to only considering mitigation of adverse effects. As

such, the magnitude criteria include consideration of the extent to which benefits are shared

with and or realised by local people and communities.

The assessment of magnitude has been undertaken in two steps. Firstly, key social impacts

associated with the Project and their related beneficial and adverse, direct and indirect, and

cumulative effects have been identified. Secondly, the magnitude of impacts and their impacts

have been categorised as either major, moderate, minor or negligible based on consideration of

the parameters listed below along with professional judgement:

● Likelihood

● Duration

● Scale – number of people or groups affected

● Spatial extent

Table 107 summarises the typical varying degrees of impact magnitude.


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Table 107: Magnitude criteria

Magnitude (beneficial or adverse)

Definition (considers likelihood, duration, number of people affected, spatial extent and local benefit sharing)

Major A highly likely impact that would have implications beyond the Project life affecting the wellbeing of many people across a broad cross-section of the population and affecting various elements of the local communities’, or workers’, resilience.

Moderate A likely impact that continues over a number of years throughout the Project life and affects the wellbeing of specific groups of people and affecting specific elements of the local communities’, or workers’, resilience.

Minor A potential impact that occurs periodically or over the short term throughout the life of the Project affecting the wellbeing of a small number of people and with little effect on the local communities’, or workers’, resilience.

Negligible A potential impact that is very short lived so that the socio-economic baseline remains largely consistent and there is no detectable effect on the wellbeing of people or the local communities’ or workers’, resilience.


The relationship between sensitivity and magnitude and how this is used to determine

significance of impacts is depicted in the overall significance matrix presented in Chapter 5.


Key limitations are related to the absence of readily available secondary data for a range of

factors and the obstacles in place to accessing official data. The latest national census was

completed in 1998, which means that a large part of the data available is outdated. Where

possible more recent data has been used. Surveys conducted in 2012 as well as the results

from the focus groups and interviews with affected stakeholders within the LAI and IAI in 2016

have been used to verify official statistics or address information gaps. Where discrepancies in

data have arisen, either the latest data has been used or the source has been named in order to

verify its origin.


15.4.1 Overview

The sections below present an analysis of the baseline socioeconomic and community profile

according to the following topics:

● Demographic profile

● Local residential and community land-use

● Economy, employment, education and skills

● Education and skills

● Ecosystem services

● Access to electricity, water and sanitation, and transport

● Health

● Ethnicity, religion and caste

● Language

● Governance

● Gender relations

● Poverty, deprivation and vulnerable groups

● Cultural heritage


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15.4.2 Demographic profile

In 2015, the estimate for Pakistan’s population was 199,085,847. The median ages for male

and female were similar and the population was relatively young. The population pyramid for

Pakistan is presented in Figure 37. The 2015 estimated growth rate was 1.46% and life

expectancy was higher for females (69.4 years) than males (65.47 years). Figure 37 reflects the

age distribution in Pakistan and shows a young population with approximately 30% of the

national population aged 14 or younger. The working aged population (age 15-64) comprises

63% of the total population and the elderly (65 years and older) make up only 4%.

Figure 37: Pakistan’s population pyramid

Source: https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html, accessed 15 August 2016

Nearly two thirds of the Pakistani population lives in rural areas, with only 39% of the total

population living in urban areas39. The overall rate of urbanisation is 2.8% (estimated annual

rate of change from 2010-2015)40.

At the last census, the population of the Tharparkar district was approximately 914,291 people,

with a population density of 47 persons per km2 (1998)41, which increased to 65 persons per km2

by 201142. The population has been predicted to increase significantly to 1,407,585 in 2012 and

39 CIA World Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. Reviewed 15 August 2016 40 Ibid. 41 Source: District Census Report of Tharparkar, 1998, Population Census Organization, Statistics Division, Government of Pakistan 42 Pakistan Economic Survey (2011)


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3,659,404 by 204343. Approximately 95% of the population was classified as rural. The urban

population is located in three main towns - Mithi, Islamkot and Diplo. Figure 38 illustrates the

location of the towns within the district. The rural population is located within approximately

2,321 villages, ranging in size from less than 50 to over 5,000 persons.

Figure 38: Distribution of population within the Tharparkar District

Source: Thar Coal Land Use Plan

Table 108 shows the population in the Tharparker District (last updated 1998). During the last

census there were only four talukas. Currently there are six talukas. Table 108 also includes the

projected population figures for 2012.

Table 108: Population in four talukas in the Tharparkar District (last updated 1998)

Taluka Population 1998 Projected Population 2012

Male Female Urban Rural Total

Chachro 202,276 155,481 - 357,757 357,757 550,780

Diplo 87,013 74,867 9,703 152,177 161,880 249,220

Mithi 129,143 112,405 30,124 211,424 241,548 371,872

Nagarparkar 81,427 71,679 - 153,106 153,106 235,712

Total 499,859 414,432 39,827 874,464 914,291 1,407,585

Source: National Census Pakistan 1998 and SESA 2013

43 Thar Coal Field Land Use plan


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The IAI consists of five villages with a total population of 2,250 people44. Initially there were six

villages in Block VI; however the village of Kharo Jani is in the process of being resettled as part

of the Block VI Lignite Mining Project. As of September 2016, the land ownership survey is

underway and potential resettlement sites within the Block are being identified. Table 109

outlines the population living in the IAI (excluding Kharo Jani).

Table 109: Population within IAI

No. Village name No. of households No. of people

1. Ranjho Noon 480 1,400

2. Yaqoob ji Dhani 5 21

3. Yousuf ji Dhani 120 600

4. Gangoo ji Dhani 17 65

5. Salar-ji-Dhani 14 95

Total 636 2,250

Source: Mott MacDonald Pakistan

15.4.3 Local residential and community land-use

The Ministry of Environment in Pakistan uses ten categories of land classifications, including

forest, agricultural land, open Ground/ fallow, exposed rocks, desert built‐ up area/land,

waterlogged and saline land, water bodies and snow/glaciers. Forest cover including scrub,

riverain, mangroves and plantation is about 5% in the country. Agricultural land including

irrigated, rainfed and rodkohi agriculture extracted from spectral reflectance of crop cover is

about 20%. It does not include the fallow land which has been covered under open

space/ground class (covering about 10% area of country). Rangelands covered over 27%, while

rock outcrops occupied another quarter of the country. The snow/glacier coverage was recorded

at about 2%. Deserts have about 10% and other uses (built up area, waterlogged and saline

land and water bodies together accounted for a little more than one percent)45.

In the Sindh province mangroves are the main forest types covering 3.5 % of the province.

These are concentrated on the Indus delta in the southern part of the province. Along the Indus

River there are Riverain Forests covering an area of 1.4%. Tree plantation and orchards are

mainly in the farm lands. The predominant agriculture is irrigated cultivation that covers 25.8%

area of the province. Some Rod‐kohi agriculture is also practiced in the province. Deserts areas

cover about 22% of the western part of the province. Due to low gradient, water logging and

salinity problem has occurred and covers about 2% of the area in the province46.

The Project is located in the western part of the Sindh province, in the desert area, which is why

the LAI and the IAI are considered hostile environments to live in. The key natural feature that

dictates the location of settlements is the availability of grazing land and land that can be used

for cultivation of crops. Land covered with sand dunes has limited utility for grazing and

cultivation and as such one of the major challenges for the people of the Tharparkar district is to

find land for cultivation and grazing purposes. The LAI is 61% covered with sand dunes

whereas only about 39% is categorized as plain land. Availability of water is also an important

factor as it is required both for drinking and household needs as well as for the livestock.

44 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016

45 Ministry of Environment in Pakistan, 2009 46 Ibid.


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Monsoon and inconsistent rains result in a short agricultural growing season with agricultural

activities occurring at a subsistence level only47. Although the majority of households use

communal lands called gaucher land for livestock grazing, the socio-economic survey

conducted as part of the Interim Resettlement Plan48 found that 23% of the people affected by

the Project had their own land. Settlements are typically located at the edge of land that can be

cultivated. Settlements generally start when persons belonging to a single caste or tribe find an

area which can support subsistence farming as well as livestock population.

15.4.4 Economy, employment and income

Pakistan is a low-income country with economic growth of only 3.5% per annum (from 2008 -

2013). The gross domestic product (GDP) has been increasing since 2012, and was estimated

to have grown by 4.2% in 2015. Services were the greatest contributor to GDP (estimated at

55.5% in 2015), with agriculture making up 25% and industry 19%. Important agricultural

products include cotton, wheat, rice fruits and vegetables. Main industries include textiles and

apparel, food processing, pharmaceuticals and construction materials. Pakistan’s exports are

heavily reliant on its textiles and apparel industry49.

Agriculture is the biggest employer (43.7%) with services and industry also making important

contributions (33.9% and 22.4 % of the labour force respectively). Pakistan is one of the main

sources of labour for the Middle East and as a result remittances are an important source of

revenue for many households. Unemployment is estimated at 6.5% (2015) although this is

believed to significantly underestimate the true picture50.

The Sindh province plays a pivotal role in the national economic and development agenda. It

has the highest concentration of urban population at 49%, as compared to an overall country

average of 37%, making it the most urbanized and economically developed province of

Pakistan. However, the Tharparkar district is largely rural (96% according to the 1998 census)

and represents the most underdeveloped area in the Sindh province. The contribution of Sindh

province to the national Gross Domestic Product (GDP) is around 33%, the second highest after

the Punjab province. In addition, Sindh contributes 70% of the country‘s income tax revenues

and 62% of its sales tax revenues. The high level of industrialisation in the Sindh province

comes from the fact that the province is home to half of the country‘s textile and sugar units,

20% of the pulp and paper mills, and 35% of edible oil industry; accounting for 34% of

Pakistan‘s total industrial capacity in large-scale manufacturing and 25% of small-scale

manufacturing51.

Within the Tharparkar district, agricultural and livestock activities are the main source of income

for the people. The district has more than 22% of all the livestock of the Sindh province

according to a survey conducted in 200852. Agriculture depends on rainfall, which is often erratic

and falls between July and September only. After the rains, the desert subsoil aquifers are

recharged and the pasturelands are regenerated. However, by February, the aquifers are often

depleted and the pasturelands dry up.

Generally, livestock in the Tharparkar district depends on grazing in pastures and crop residues.

The duration of livestock tenure (or share agreement) between livestock owners and shepherds

47 Draft SESA Report May 2013 Updated (2015) 48 Hagar Bailly, Interim Resettlement Action Plan, 2013

49 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html 15 August 2016 50 Ibid. 51 Ibid. 52 Herani G., Wasim P., Rajar A., Riaz S., Livestock: A Reliable Source of Income Generation and Rehabilitation of Environment at

Tharparkar, 2008


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is typically 4, 6 and 7 years for goats and sheep, cows, and camels, respectively. The

shepherds are responsible for looking after the animals, whereas the owner shares the cost

incurred on purchase of fodder and medicine equally. Animals are sold with consent of both the

owner and the shepherd. In addition to sharing, livestock herding is also done by hiring

shepherds to look after the herd on daily or monthly wage basis. Women are especially involved

in livestock herding and play an important role in this occupation.

In Tharparkar district, 21.4% of the people migrate due to a lack of employment and 10.3% due

to marriage53. Men of those households who have enough resources to leave their dependents

behind usually undertake migration, whereas poorer families are forced to migrate entirely.

Majority of the households from Tharparkar district migrate seasonally for four to six months.

Migration period usually starts from February onwards to provide labour for harvesting wheat

and cutting sugarcane in the irrigated areas of Sindh province such as Sanghar, Mirpurkhas,

Shadipali, Kunri and Nawabshah. These seasonal migrants move back in time to sow and

harvest their own crops during the monsoon season.

Except for livestock farming, there are very limited opportunities for income generation. Salt is

exported from Diplo and other areas. However due to the lack of transportation the granite and

china clay found in the Nagarparkar region are currently extracted in limited quantities. There is

little industry in the district although it is rich in mineral resources. There are no major industrial

units. The Tharparkar district industry includes two ice factories, over 700 carpet making centres

and 59 local flour mills (Atta Chakies)54. Commerce centres around handicrafts, wood works,

sheep wools and carpets. Handicrafts are skills common amongst Thari’s. Shawls made of silk,

wool or cotton, handmade bed sheets, Khes of goat55 and camel hair skin and wool blankets are

some of the major products. Although these types of income generating activities typically

provide low revenues for the producers, interest has grown in the carpet industry with some

villagers moving away from agriculture to carpet weaving with the number of carpet looms

increasing56.

The focus group discussions conducted in the IAI confirm that unemployment is high in the five

IAI villages and that agriculture is the main form of employment. The majority of men migrate

seasonally, as described above, in order secure an income for their families.

15.4.5 Education and skills

The estimated national literacy rate in 2015 was low at only 57.9%, with higher rates amongst

men (69.5%) compared to women (45.8%). The average number of years of education a child

can expect to receive is eight (nine years for males and seven for females)57. According to the

1998 Census, the literacy ratio in the Tharparkar district was 18.3% (28% of men and 7% of

women). A higher proportion of the urban population were literate (57%) compared to rural

(16%).

Literacy rates in the Tharparkar district are below those of the Sindh province and Pakistan as a

whole. Net education enrolment rates have increased for both sexes from 59% in 2002 to 73%

in 201458. However, a number of factors continue to make it challenging such as the proximity of

53 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016

54 Draft SESA Report May 2013 55 Black goat’s hair shawl 56 Inception Report 2011 57 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html 15 August 2016 58 UNESCO Institute for Statistics, 2016


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schools for rural students, low numbers of female teachers, shortages of secondary and tertiary

educational institutions and absence of basic facilities such as electricity in most schools.

Education for girls is particularly challenging with only 15 schools for girls in the whole district59.

Social constraints do not allow girls to travel long distances alone and the shortage of female

teachers further limits the educational opportunities.

The majority of the population within the IAI is illiterate (numbers range between 70%-90%60

illiteracy between the villages), with only a small amount of the population being educated, and

only to primary school level. Limited availability of schools and teachers along with the fact that

school aged children are often engaged in income generating activities, like labour or

maintaining of livestock herds, means there is little chance for education. The existing schools in

the IAI are in poor condition and teachers are unavailable to fill the required positions. Table

110 shows the number of primary schools within the affected villages located in Block VI.

Table 110: Number of Schools inside Block VI

Village Name No. of Schools

Ranjho Noon 2

Yousuf Ji Dhani 1

Salar Ji Dhani 1

Gangoo Ji Dhani 0

Yaqoob Ji Dhani 0

Total 4

Source: Mott MacDonald Pakistan

15.4.6 Ecosystem services

Ecosystem services refer to the benefits that people obtain from ecosystems and are often

grouped into four categories: supporting services, provisioning services, regulating services and

cultural services. In the LAI people utilise provisioning ecosystem services - natural resources

used to support their income and livelihoods. These include food, medicinal plants, raw

materials making things, water and energy. Cultural ecosystem services – natural resources

which provide spiritual, cognitive, reflective, recreational or aesthetic benefits - are also

accessed. Examples of natural resources that support incomes and livelihoods, and cultural

traditional identified within the LAI are briefly outlined below61.

● Calotropis procera (Ak) – it is a useful tree that grows on the sides of small dunes. The

wood of ak is used in the construction of houses. Cotton like material extracted from this

plant is used in making pillows62. It is also used for making ropes which are used for drawing

water from wells.

● Tecomella undulata (Rohiro) – this tree grows in the fields and on the sides of sand dunes.

The wood of rohiro is very strong and valuable. Its wood is used for making furniture and

toys and baskets are made from the sticks.

● Acacia senegal (Konbat) – the wood of konbat tree is used to make plows.

● Prosopis cineraria (Kando or Kandi) –the wood is used to make pulleys used in drawing

water from wells.

59 Socio-Economic & Environmental Aspects of Coal Mining in Tharparkar District, 2009, Thardeep Rural

Development Programme, Karachi, quoted in IA Block VI Lignite Mining Project, 2013

60 Focus Group Discussion conducted by Mott MacDonald Pakistan, 2016 61 EIA Block VI Lignite Mining Project, 2013 62 Nadiem. I. H., 2001, Thar, The great Pakistan desert: Land, History and People, Lahore, Sang-e-Meel Publications.


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● Salvadora oleoides (Khabar Jar) – The wood of khaber jar is used in the construction of

houses.

● Ziziphus nummularia (Ber) – the wood of this tree is useful for certain crafts. People make

handles of spade and axe from its wood as well as wooden frames that can be placed on the

camel’s back and used for sitting.

● (Bairi) – the roots of this plant are used for making churning pots as well as water containers.

● Plants such as Amaranthus viridis (Pipon) and Momordica charantia (Karela) are also used

by the locals as vegetables

● Herbs such as (thali), (laks), (marhas), Citrullus colocynthis(tooh), Amaranthus viridis

(pipon), (marero) and Momordica charantia(karela) have various medicinal uses and are

used by the locals for curing human ailments such as gastric problems and diabetes.

● Shrubs are used to provide fodder for the grazing animals

● Leptadenia pyrotechnica or (Khip) – this shrub is used to make mats, ropes and building

material for houses

● (Sen) – this shrub is used for making ropes, fodder for livestock and thatching of homes.

● Dondhan) –the fluffy material from this shrub is collected by local people and sold or used to

make pillows.

● Mud and clay is used in the construction of houses

● Capparis decidua (Karer) – the wood of this tree is used for making musical instruments

such as Alghoza (double flute) and flutes.

● (Kado) – The wood of this plant is used for making flutes.

People collect a variety of herbs from sand dunes, thali (land lying between two sand dunes),

pastures (which are located in dahars), laks and marhas to cure various human ailments. Herbs

are also used to cure livestock diseases. Women are more knowledgeable about the use of

herbs. The most preferred herbs are tooh, pipon, marero and karela (bitter gourd). Tablets,

made from the paste of tooh, are used for gastric problems whereas pipon is used for diabetics.

Many Tharis also use pipon as vegetable. Likewise, karela, used for diabetics, is also used as

vegetable by people in the local area63.

15.4.7 Access to electricity, water, sanitation and transportation

Pakistan’s total installed capacity is 24,38 MW (2014 estimate). Its electricity consumption is

78,890GWh (2013 estimate) and it currently imports 392GWh (2013 estimate). Approximately

two thirds of the country’s total installed capacity is generated from fossil fuels, with nearly a

third from hydroelectric plants and only 3% from nuclear fuels64. Only 6.75% of households in

the Tharparkar district have electricity. Most households (92.5%) use kerosene oil. Kerosene

use is higher in rural areas (95%) compared to urban areas (31%)65. Villages surveyed for the

Lignite Coal EIA did not have access to electricity. Outside Block VI, only 35% of surveyed

villages had electricity and no one used natural gas. Households surveyed used fuel wood and

charcoal as cooking fuel66.

In 2015, most of the national population were estimated to have access to improved drinking

water; with urban rates being slightly higher than rural (93.9% compared to 89.9%). In

63 ESIA Block VI Lignite Mining Project, 2013 64 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016 65 Draft SESA Report May 2013 Updated, sourced from the 1998 census data for Tharparkar 66 ESIA Block VI Lignite Mining Project, 2013.


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comparison, the Tharparkar district has poor water and sanitation provision. It was ranked the

lowest district in terms of water supply and sanitation coverage within Sindh province and

nationally within the 10 bottom districts. Availability of piped water is negligible with only 2% of

households having access - 34% of urban households compared to 1% of rural households.

In the Tharparkar district many households use well water for their basic needs. Some wells are

government owned although many dug wells are owned and operated by the communities

themselves. However only 48% of the water from wells can be considered fit for human

consumption due, in part, to the salinity of the groundwater. The availability of hand pumps

across the district is low and they are therefore only used by 1.2% of households. Rainwater for

drinking is also collected by most households using traditional channels called tarais,

underground and overhead tanks, and earthen jars although these are not considered to be

efficient collection systems67

Across Pakistan, 83% of urban populations have access to improved sanitation facilities

compared to 51% of the rural population (estimated in 2015)68. At the district level, most of the

rural population defecates in or near cultivated fields. Less than half of urban sewage is drained

off through sewers and only a small fraction of that is treated before being disposed of into

water bodies. The lack of sanitation facilities and poor hygiene is identified as one of the main

causes of communicable infections within the country69.

Within the Study Area the distances of the blacktop and unsealed roads are 20km and 127km,

respectively. In addition, there are 27km of unsealed tracks that are available for travel for most

part of the year except between July and September when fields are cultivated.

The main mode of transport in the district is by road. Transport facilities are in the form of

passenger vans, which traverse different parts of the district. In some parts of the district,

traditional means of transport, mainly transport by camels, are still used. Kekra, a form of local

transport made from the army trucks belonging to the World War II period and locally adapted

for desert use, has been a reliable mode of transport in the Thar Desert and is still used for

travel through the desert along the sealed and unsealed roads (see Figure 39 and Figure 40).

Figure 39: Modes of Transport in the Study Area - Kekra

Figure 40: Modes of Transport in the Study Area – Travel by Camel

67 Draft SESA Report May 2013 Updated 68 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016 69 Draft SESA Report May 2013 Updated


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Tharparkar has limited access and communications which adversely affects its economy. There

are only 195km of paved roads across the district. A mobile phone service is available through

the wireless local loop system, although main line telephones are not available70.

The focus group discussions held in the IAI provide confirm that there are no clean drinking

water and sanitation facilities available in the affected communities. Furthermore, electricity is

not available in any of the settlements within Block VI.

15.4.8 Health

Life expectancy in Pakistan remains relatively low at 67.39 years. There is a disparity between

life expectancy for males which is 65.47 years and for females at 69.471. The main causes of

mortality in Pakistan are non-communicable diseases (heart disease, stroke, chronic obstructive

pulmonary disease and diabetes), communicable diseases (lower respiratory infections,

diarrhoeal diseases and tuberculosis); and ante and post-natal complications (preterm birth

complications, birth asphyxia and birth trauma, neonatal sepsis and infections)72. Infectious

diseases that are prevalent in Pakistan include bacteria diarrhoea, hepatitis A and E, and

typhoid fever (food / or waterborne diseases); and dengue fever and malaria (vectorborne

diseases)73.

Infant mortality is high, with Pakistan ranking 26th in the world (55.67 deaths / 1,000 live births).

Maternal mortality is also relatively high with 178 deaths / 100,000 live births, ranking 44th in the

World (both estimated in 2015)74. Malnutrition amongst children is high with a third of children

under five years underweight (ranked 11th in the World). Prematurity, acute respiratory

infections, birth asphyxia, diarrhoea and neonatal sepsis are the most common causes of

deaths in children under five years (2013)75.

The Tharparkar district has the lowest Human Development Index76 of all districts in the Sindh

province. It is one of the most impoverished and marginalized areas of the Sindh province with

almost 90% of households living below the poverty line. High levels of total dissolved salts

(TDS) and fluoride in underground water coupled with lack of easy access to clean drinking

water and sanitation facilities contribute to the health issues faced by the local population.

Waterborne diseases are very common throughout the desert area of Tharparkar. Unsanitary

conditions and lack of awareness of personal hygiene are attributed to a rise in hepatitis B and

C with almost 25% of population suffering from it. Skin conditions such as scabies, psoriasis

and fungal infections affect 25-40% of the population of various villages and are also linked to

sanitation and hygiene. Maternal mortality is high in Tharparkar. Unskilled birth attendants, lack

of gynaecologists at hospitals, traditionally women not visiting town hospitals and inability to pay

for delivery expenses are contributory factors. Malaria is also common in the monsoon season.

70 Draft SESA Report May 2013 Updated 71 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016

72 Pakistan WHO statistical profile. http://www.who.int/gho/countries/pak.pdf?ua=1. 15 August 2016

73 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016 74 CIA Factbook https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html. 15 August 2016 75 Pakistan WHO statistical profile. http://www.who.int/gho/countries/pak.pdf?ua=1. 15 August 2016 76 UNDP Pakistan http://hdr.undp.org/en/countries/profiles/PAK


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According to 1998 Census, Tharparkar District has one civil hospital, three taluka hospitals

operated by the District Health Office (DHO), two rural health centres, 30 basic health units, two

maternity and child welfare units and 40 district council dispensaries. There was one hospital

bed for every 7,000 persons in Tharparkar district and only one doctor for every 11,000 persons.

The focus group discussions conducted in the IAI revealed that the most common health

impacts were malaria and snake bites. In addition, the local population has to travel long

distances to reach the towns of Islamkot or Mithi and pay prohibitive prices in order to receive

medical treatment. Furthermore, according to the Infrastructure Baseline and Spatial

Referencing Report, there is only one basic health facility located in Block VI77, which means the

area is underserved in terms of health services.

15.4.9 Ethnicity, religion and caste

An ethnic group is defined as members of any culture who share certain beliefs, values, habits,

customs and norms78. There are a number of ethnic groups represented within Pakistan:

Punjabis make up the largest group 94.7%), followed by Pashtun (15.4%) and Sindhi (14%).

Distinctions may arise due to language, religion, historical origin, geographic isolation and

kinship. In the Tharparkar District Hindus and Muslims form the two ethnic groups and are

further sub-divided into multiple castes. Table 111 gives the percentage distribution of

population by main religious groups, in the Tharparkar District. Muslims are in majority, forming

59.4% of the district‘s population. However, in and around the IAI and LAI Hindu community is in

majority, where the population of Hindus and Muslims is 62% and 38%, respectively.

Table 111: Tharparkar District population in percentage by religion, 1998

Religion All areas Urban Rural

Muslim 59.4% 29.5% 60.8%

Hindu 40.5% 69.6% 39.1%

Others 0.1% 0.9% 0.1%

Source: District Census Report of Tharparkar, 1998, Population Census Organization, Statistics Division, Government of Pakistan

Hindu and Muslim societies have caste systems which is a social class separated from others

by distinctions of hereditary rank, profession, or wealth. It carries a different meaning for the

Hindus and Muslims. Muslim castes are divided into sub castes and further into lineages. For

example, the Langa caste is divided into sub-castes Dodani and Chanesarani, which are further

divided into Mithani and Gulani lineages. The Hindu caste structure follows the traditional Varna

model. According to this model, there are four castes or jatis, namely Brahman (priest), the

Kshatriya (noble), the Vaishya (commoner), and the Shudra (servant)79. The main caste among

Hindus included Brahman and Rajpoot (Thakur). Bajeer is a common caste for both Muslims

and Hindus. The Scheduled castes (commonly Hindu) included Menghwar, Bheel and Kohli80.

Caste also defines peoples’ occupations. Menghwars originally were mostly involved in

leatherwork. They were known for skinning dead animals (for leather related work) and hence

were referred to as dhed. They have now set themselves apart by devoting themselves to

occupations such as weaving and opportunities involving higher education skills. The Bheels

initially led a nomadic life and migrated seasonally to the irrigated areas for labour, occupying

77 Infrastructure Baseline and Spatial Referencing Report, Mott MacDonald Pakistan, 2013 78 This section does not cover indigenous peoples as per the World Bank or IFC definitions, Indigenous peoples will be addressed further

in the mitigation section 79 Focus Group Discussion with five affected villages in Block VI, Mott MacDonald Pakistan 80


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their home villages for only a few months in a year. They are now involved in other occupations,

such as, farming and services. Kolis, the only original inhabitants of the Tharparkar District,

were the poorest and least established members of society. Originally, hunters and soldiers, the

Kolis now live by herding and farming.

A tribe is a social division in a traditional society consisting of families or communities linked by

social, economic, religious, or blood ties, with a common culture and dialect, typically having a

recognized leader. There are three main tribes represented within the Tharparkar district –

Rajputs, Baloch and aboriginal Dravadians. Within the LAI and IAI the main tribes amongst

Muslims are Syed, Baluch, and Rajputs.

15.4.10 Language

In Pakistan, although Urdu is the official language it is spoken by only 8% of the population.

Punjabi is the most common language spoken (48%), followed by Sindhi (12%) and Saraiki (a

variant of Punjabi) (10%). The main language of Tharparkar district is Sindhi (97%-99% have it

as their mother tongue); other languages spoken include Urdu, Dhatki, Balochi, Saraiki, Gujrati

and Parkari81.In the IAI the most common language used by Muslims is Sindhi and the language

most commonly used by Hindus is Dhatki. However most Muslims and Hindus understand and

converse in both languages82.

15.4.11 Governance

The Islamic Republic of Pakistan has a federal parliamentary system with a president as head

of state and a popularly elected prime minister as head of government. The president, in

keeping with the constitutional provision that the state religion is Islam, must be a Muslim. He or

she is elected for a five year term and is eligible for one re-election83.

Seats in the government are allocated to each of the four provinces, the Federally Administered

Tribal Areas, and Islamabad Capital Territory on the basis of population. National Assembly

members serve for the parliamentary term, which is five years, unless they die or resign sooner,

or unless the National Assembly is dissolved. Although the vast majority of the members are

Muslim, about 5 % of the seats are reserved for minorities, including Christians, Hindus, and

Sikhs. Elections for minority seats are held on the basis of separate electorates at the same

time as the polls for Muslim seats during the general elections84.

Pakistan's four provinces enjoy considerable autonomy. Each province has a governor, a

Council of Ministers headed by a chief minister appointed by the governor, and a provincial

assembly. Members of the provincial assemblies are elected by universal adult suffrage.

Provincial assemblies also have reserved seats for minorities. Although there is a well-defined

division of responsibilities between federal and provincial governments, there are some

functions on which both can make laws and establish departments for their execution. Most of

the services in areas such as health, education, agriculture, and roads, for example, are

provided by the provincial governments. Although the federal government can also legislate in

these areas, it only makes national policy and handles international aspects of those services85.

The law and order situation in the district is generally peaceful. Fewer than 0.5% of registered

81 Draft SESA Report May 2013 Updated (2015) 82 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016 83 US Federal Research Division of the Library of Congress, 2016 84 US Federal Research Division of the Library of Congress, 2003 85 Ibid.


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criminal cases in Sindh, were from Tharparkar (35 out of 11,900 registered criminal cases)86.

There are 14 police stations in the district; none of which are located in the study area.

The traditional governance system of villages with multiple castes residing in them is different

from that in the villages with a single-caste. In villages with a single caste the wadero, if the

caste is Muslim, or the patel, if the caste is Hindu, are the village heads. Minor disputes such as

family feuds are resolved by the village wadero or patel. In villages with multiple castes, each

Shudra caste has its own patel and they are subordinates to the patel of Thakur caste or

wadero of the Muslim caste, if the Muslims are also residing in the same village87.

Apart from the wadero and patel, there also exists a village council or the panchayat for Hindus.

Amongst the Muslim, wadero holds the ultimate political influence in a village. However, the

council of the elders also works with the wadero in tandem. Each elder in the council represents

his respective lineage. Panchayat and patel are losing their influence rapidly, while the wadero

is gaining authority amongst the local IAI communities. This could be because in comparison to

the patel, the wadero has more influence outside of the IAI, in the local government88.

15.4.12 Gender relations

The 2014 World Economic Forum ranked Pakistan 141 of 142 countries worldwide for gender

equality, with only Yemen performing worse. In 2012, a World Bank report detailed the

difficulties Pakistani women face in gaining access to capital due to social constraints —

needing permission from a male to even qualify for a loan, for example. According to the study,

50% to 70% of microloans given to women in Pakistan may actually be used by their male

relatives89. Men are the main breadwinners in Pakistani society, while women are mainly

involved in domestic activities. Recent efforts have been made to enhance the status of women,

for instance by including women on elected bodies. Legal reforms and an allocation of seats

within parliament have resulted in an increase in the number of seats held, 21% of seats in

Parliament are women90.

There are some organisations working to improve gender equality and provide more

opportunities for women in Pakistan. The Citizens Foundation, a non-profit organization, runs

schools across the country, encouraging female enrolment with the goal of having its campuses

gender balanced. The Kashf Foundation, founded in 1996, became the first microfinance

institution in Pakistan to target women from low-income communities. The First Women Bank

was founded in 1989 to support businesswomen. Pakistan’s Small and Medium Enterprises

Development Authority (SMEDA) also provides support for female entrepreneurs91.

In the IAI, for all castes, the male household head was found to be primarily responsible for

external and internal household affairs. He is not only responsible for representing the

household in the village and wider community, but he is also the person who takes all of the

decisions within the household. Women do however play a major role in supporting the

household and in addressing food security and nutritive wellbeing. In the IAI women are

responsible for cooking, dishwashing, milking livestock, looking after children and the sick,

fetching water, washing clothes, and collecting fuel wood. In addition, women belonging to the

poorer households help in agricultural work in the fields along with male family members and

86 Development statistics of Sindh, 2006, published by Sindh Bureau of Statistics, Government of Sindh. 87 Hagar Bailly, Interim Resettlement Action Plan, 2013

88 Ibid. 89 Women, girls and Malala: Research on gender and education in Pakistan, and beyond, Harvard Kennedy School, 2014

90 Draft SESA Report May 2013 Updated 91 Women, girls and Malala: Research on gender and education in Pakistan, and beyond, Harvard Kennedy School, 2014


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migrate with them to provide farm labour in the irrigated areas of Sindh for four to six months of

the year. Most women, regardless or religion or caste, are also involved in making handicrafts

like embroidered sheets and clothes, although income from selling these handicrafts usually

goes to the male household head.

15.4.13 Poverty, deprivation and vulnerable groups

One third of Pakistan’s population continues to live in poverty, corresponding to some 50 million

poor individuals. Women and children (out-of-school/working), disabled, and potentially the

elderly, are the most vulnerable groups of poor. The poor live mainly in rural areas, are

unskilled, and work in the informal sector. Employment opportunities are scarce and real

earnings have declined in the last decade. The poor also lack in all of the basic physical and

productive assets and have limited or no access to essential social services.

After the Balochistan province, the Sindh province is considered to have the highest rural

poverty incidence at 31%. According to the Social Policy Development Center (SPDC) in 2005

indicated Tharparkar as the second-most deprived district in Sindh, ranking it 15th out of 16

districts. According to the Thardeep Rural Development Program (local Non-Governmental

Organisation) the population living below the poverty line is 28.92%92.

In the IAI around 52% of the households fall below the poverty line and are amongst the most

vulnerable93. In addition, there are seasonal migrants (21.4%), ethnic minorities and female

headed households, who are all considered vulnerable groups94.

15.4.14 Cultural heritage

There are a number of sites of religious, cultural and archaeological significance in the Thar

Desert area which include the hills of Karunjhar, sacred Hindu temples in Nagarparkar,

Gaomakhi Waterfall, Bhemgoda Pond, Chandan Garh Fort (built in 1859) and Naukot Fort95.

Muslim places of worship include mosques and shrines, and Hindu places of worship include

temples and shrines (Figure 41 and Figure 42). All villages in the IAI have mosques and most

have temples. Shrines are located in only some of the villages. The same shrines can have

religious significance for both Muslims and Hindus although would be known by different names.

Shrines with mutual significance and dual identities can be seen in many parts of lower Sindh

and South India96. Hindu and Muslim religious buildings are usually constructed differently.

Muslim shrines are generally called dargah and are roofed buildings decorated with stucco.

Hindu shrines known as than (open-platform) are usually simple or open-platforms. Shrines are

generally found outside the house or at the entrance of the cluster whereas temples are mostly

located inside the house.

92 http://www.thardeep.org/thardeep/tharparker.html 93 Focus Group Discussions conducted by Mott MacDonald Pakistan in the IAI in June 2016 94 Ibid. 95 ESIA Block VI Lignite Mining Project, 2013 96 Ibid.


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Figure 41: Places of Worship in Study Area

- Mosque in Ranjho Noon

Figure 42: Places of Worship in Study Area - Temple of Rama Pir in Mansingh Bheel

Previous archaeological surveys in the Thar desert have suggested some form of pastoral

nomadic culture in the region dating back at least 7,000 years. There is potential in the area for

nomadic burials of considerable antiquity97. The area also has potential for the presence of

Palaeolithic (130,000 years bp) and Mesolithic (15/10, 000 year bp) activity often in the form of

stone tool and lithic/flint scatters on sand dunes and around saltwater basins98. The

archaeological and historical evidence does not suggest the presence of any major civilization

associated with large towns or cities within Block VI. However, such a possibility cannot be

entirely discounted. Although there are no major water courses close to the Project area there

are small ephemeral channels that capture run off during and after heavy rainfall and these

temporary water bodies may have attracted seasonal/temporary settlement in prehistoric and

historic periods.

Historic religious architecture includes a mosque and some Jain temples scattered over

southern Thar, around the small town of Nagarparkar (132km from Mithi). The potential for the

presence of archaeological remains associated with major/urban settlements within the Thar

area is low99.

There are no known pre-historic archaeological sites located in the IAI. This was confirmed by

focus group discussions conducted with the affected villagers. The nearest federally

protected100 archaeological site to Block VI is located about 30km to the east. In the Thar

desert. There are documented archaeological sites including the hills of Karunjhar and sacred

places of worship for Hindus and Jains in Nagarparkar. Site of possible archaeological

significance include the Gad of Mirs (Talpurs) located about 5 km south of Block VI in the south

of Seengaro Village, and Thario Halepotto, a ruin dating to the Buddhist period and located in

Islamkot about 6 km away101.

97 Ibid. 98 Ibid. 99 ESIA Block VI Lignite Mining Project, 2013 100 Sites protected by the Federal Government of Pakistan under the Antiquities Act 1975. 101 Ibid.


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15.5 Likely impacts and assessment of significance

15.5.1 Overview

This section identifies and assesses the construction and operational phase significant impacts

for the construction and operational phases of the Project. Social impacts that are predicted to

be ‘Major’ or ‘Moderate’ are classified as significant. The significant impacts identified in relation

to this Project are employment generation and influx management. Additional potential Project

risks are also discussed in relation to occupational and community health, safety and security

and labour rights and resettlement and land acquisition. As detailed earlier in section 15.1.1, the

various environmental impacts (air quality, noise, dust, traffic) from construction impacts are

assessed in their respective chapters and are not covered here to avoid double counting of

impacts.


15.5.2.1 Construction phase short term employment generation

Temporary employment generation will result from the construction of the Project components

and associated facilities. Construction phase employment is expected to peak at approximately

1,000 workers. The skills base in the community is low and therefore affected stakeholders

would only be able to access unskilled labour jobs such as manual labour as well as provision of

services for workers such as food and refreshments, cleaning of accommodation, sanitation and

hygiene. Women will have even more limited opportunities for employment due to cultural and

societal perceptions and customs.

A key social impact will be the provision of an income source for workers and their families

contributing to their wellbeing and enhancing their quality of life, particularly in the case of

migrant workers who will not need to travel to benefit from this employment. Considering also

the high incidents of poverty in the IAI (52%) and the prevalence of vulnerable populations, local

employment can provide particularly important benefits for them. Although the construction jobs

will be temporary, the skills and experience gained will benefit future job prospects as workers

are likely to develop new and or enhance existing skills. Construction activities will provide

temporary but greater livelihood security. Indirect socio-economic benefits will result from

workers earnings being spent on local goods and services.

Local jobseekers are considered to have high sensitivity due to the poverty levels and high

demand for employment. The magnitude is considered to be minor due to the relatively low

number of jobs that will be available to local workers and the temporary nature of the impact. As

such, construction phase employment is considered to be moderate beneficial, and therefore

significant.

15.5.2.2 Population influx

The simultaneous construction of the coal power plant in Block II (adjacent to Block VI), the

open pit mine in Block VI and this coal power plant in Block VI means that there is likely to be a

large number of non-local workers coming into the area. While some of the construction jobs will

be accessible to local workers, there will be need for outside skills. Considering that the local

population is only 2,250 people, even an influx of 500 workers would constitute 20% of the local

population. The extent of migration is usually determined by project characteristics and a

number of factors which have been given consideration are provided in Table 112, below.


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Table 112: Key factors leading to high rates of influx and adverse social impacts

Influx factor Analysis

Scale of project:

larger projects attract more migrants

This Project has a three year construction period and has a construction workforce of around 1,000 people and could therefore be attractive to additional migrants also.

There will be two additional projects (one mine in Block VI and one coal power plant in Block II) with similar sized work forces being construction at the same time.

Area’s capacity to meet project needs/population density of project area

The Project is located in the Thar Desert, which is a poor and deserted part of the country. The local capacity to cope with population influx is very low, as there is high incidents of poverty and low availability of infrastructure and social services.

Opportunities for compensation and benefits speculation

The adjacent mine project resettled a village of a total of 1,200 people and provided compensation and land. Given that it is a remote area, it is possible that the resettlement is not widely known, as even some of the people living within the Project area appear unaware. However, given that there are three construction sites there might be cumulative benefits that are considered attractive.

Conclusion: Overall, the Project is expected to attract external workers and some opportunistic economic migrants or ‘camp followers’ during the construction phase. In addition, given the remote location and the inability of locals to deal with influx at present it is considered a significant impact

Source: Mott MacDonald based on IFC 2009 guidance on IFC Handbook Project-Induced In-Migration.

Local people are considered to have high sensitivity due to their poverty levels, limited access to

social services and their remote location. Influx has the ability to bring about cultural changes

and cause people to feel out of place in their own home. In addition, there is an increased risk of

disease, insecurity and overburdening of already inexistent social services. The magnitude is

considered to be moderate as there will be multiple construction sites at the same time. As

such, construction phase influx is considered to be major adverse, and therefore significant.

15.5.2.3 Construction phase loss of ecosystem services

As noted in section 14.5.1.3, the Project will result in the permanent loss of a small area of

agricultural fields, sand dunes and sandy plains including 15.75ha within the footprint of the

Project and 2.25ha on a separate site for the accommodation camp. These habitats are

considered to be widespread. and no individuals or communities have been identified as

depending on these resources for their livelihoods or subsistence or for nonmaterial cultural

benefits. The Project is expected to have a negligible impact on ecosystem services and

therefore is not significant.

15.5.2.4 Construction phase impacts on cultural heritage

The Project will not have any direct adverse impacts on religious facilities, or known

prehistorical or archaeological sites in the IAI. However, there is potential within Block VI for

archaeological finds ranging from Palaeolithic, early Prehistoric through to later Prehistoric

archaeological and artefactual. The magnitude is considered to be moderate given the potential

for permanent loss of archaeological finds within the Project footprint. The construction of the

Project is expected to have a low adverse on cultural heritage and therefore is not significant.


15.5.3.1 Employment generation

The operational phase is expected to generate fewer direct employment opportunities than the

construction phase with the number of skilled jobs to perform maintenance and operation of the

plant estimated at approximately 200-300. Some roles such as office staff may be performed by

the same personnel as in the construction phase, so the actual number of new jobs created may

be slightly lower. Many of the positions will be skilled roles and it is not known at this stage how

many will be available to local community members with limited skills sets.


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The majority of the job seekers that will benefit are likely to have some existing skills and

therefore more livelihood opportunities than the construction workforce. The potential

employment opportunities for operational workers are considered to have moderate sensitivity.

The impact magnitude is considered to be negligible to minor due to the relatively low number of

jobs and the necessary skills needed. According to these categorisations, the impact of

operational is considered to be a negligible to minor beneficial impact, and therefore not

significant.

15.6 Potential risks

15.6.1 Overview

Whereas the previous sections discussed social impacts that are considered highly likely to

occur, this section discusses potential social risks that could occur but are less likely. The

Project will take a precautionary approach to avoid and mitigate risks through appropriate social

management measures.

15.6.2 Land acquisition and resettlement

The Government of Sindh in conjunction with Mott MacDonald developed a resettlement

policy/strategy in 2013 for the entire Thar Coalfield, which encompasses all developments in

Block VI. The Developer and its consultants then developed an Interim Resettlement Action

Plan (RAP) in 2013 which is compliant with Pakistani and international IFC requirements and

outlines all of the land acquisition and resettlement activities to be conducted in Block VI.

Following the enactment of the Government of Sindh’s Resettlement Policy Framework – Thar

Coalfields (RFP) in May 2015 the Interim RAP was updated to conform with the Government’s

RPF.

The village of Kharo Jani with a population of 1,200 (160 households) and much of its cultivated

lands, is the only village to be displaced. The resettlement process is currently undergoing as

part of the Block VI Lignite Mining Project (2013). The 2011 Resettlement Framework and the

above mentioned interim RAP, which have been the guidance documents for undertaking the

resettlement. The remaining villages will not experience resettlement or land acquisition for the

next 40 years, as this is when phase II of the Block VI lignite mining project is likely to take

place, which could have further resettlement impacts.

In the unlikely event that there is potential resettlement, the interim RAP will need to be updated

to a compliant RAP for the affected people and the procedures that will need to be followed.

15.6.3 Occupational health and safety and labour rights

Site preparation, construction and operational activities pose the following main OHS risks to

workers:

● Exposure to physical hazards from use of heavy equipment

● Trip and fall hazards

● Exposure to dust, noise and vibrations

● Falling objects

● Exposure to hazardous materials; and exposure to electrical hazards from the use of tools

and machinery

● Working at height, with live power equipment and lines

● Exposure to electro-magnetic fields (EMFs)


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There will likely be 400 workers accommodated on site which poses potential risks to the health,

safety, security and therefore wellbeing of construction workers if not managed appropriately.

Health and safety issues associated with the use of temporary accommodation sites include

those relating to sanitation, disease, fire, cultural alienation, sleeping space, quality and quantity

of food, personal safety and security, temperature control and recreation, amongst others.

There are risks to workers’ wellbeing through delayed payment of wages, potential for forced or

child labour and people working without contracts and other safeguards. Similarly, there is the

risk of adverse occupational health and safety impacts related to personal accident or injury on

any construction site. Some of the OHS risks which could arise during the construction phase of

the Project, and are typical to projects of this type of facility include: exposure to physical

hazards from use of heavy equipment and cranes; falling from height; foundation pits/trenches;

working in confined spaces; trip hazards; exposure to dust and noise; falling objects;

electrocution risks. Risks specific to the Project location include exposure to extremes of

climate.

Whilst workers on the Project, particularly sub-contracted construction workers, are vulnerable

to risks to their health safety and wellbeing on a daily basis, the Pakistani regulatory standards

provide some protection. Appropriate planning and execution of health and safety management

planning, workforce management measures and accommodation management must be

undertaken by the EPC contractor and the Developer to reduce the risks as far as possible.

15.6.4 Community health, safety and security

There are a number of activities in the construction phase which if not mitigated could cause

risks to local communities. Increased traffic volumes may result in road safety risks and can

affect the already vulnerable population in adverse ways. The Project will need to conduct a

traffic awareness raising program and ensure that people understand the risks and dangers

faced.

There could be a health and safety risk to the local community posed by the existence of

construction sites and possible presence of armed security guards. Access to construction sites

by community members presents health and safety risks similar to those described in section

15.6.3 above and the presence of the construction workforce presents a risk of spread of

sexually transmitted infections and increased pregnancies amongst local women. Air quality and

noise impacts are discussed in chapters 7 and 9.


15.7.1 Stakeholder engagement and grievance management

A stakeholder engagement plan (SEP) will be produced as part of the Project’s environmental

and social management system (ESMS). The SEP should be developed and implemented

during both the construction phase of for the lifetime of the Project. The SEP will reflect the

ESIA consultation requirements outlined in section 15.2.1.1 in order to enable the Project to

comply with the necessary stakeholder engagement legislation. Moreover, due to the high levels

of vulnerability in the IAI, the SEP must include sufficient channels for stakeholder engagement

and grievance redress in order to mitigate any adverse impacts that might occur and could

affect the local community.

The SEP must be used as a management tool using a culturally appropriate approach to

information disclosure and consultation. The SEP will coordinate, guide and maximise the full

value of the engagement processes for the Project. Participation of stakeholders, in particular

those who are directly affected, is considered essential to realising the full benefits of the


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Project. The SEP will include identification and analysis of stakeholders including vulnerable

groups. Planned stakeholder engagement activities, responsibilities and timelines will be

included in the strategy, including disclosure and consultation activities

The SEP will include a community grievance mechanism with grievance reporting and resolution

procedures and roles and responsibilities of CLOs in terms of grievance management. The

contact details of the CLOs will be disclosed to stakeholders, especially Project affected

communities prior to construction commencing.

15.7.2 Local content strategy

A local content strategy needs to be developed in order to enable local people to benefit from

the creation of employment opportunities and thus facilitate that the high demand for local

employment is met. To this end, the Developer has developed a recruitment and skills

development policy which outlines the establishment of an employment liaison forum. The forum

is designed to engage local representation to assist the recruitment process and to thus

facilitate that local cultural and religious traditions are taken into consideration when developing

working practices and working patterns. This forum will meet on a regular basis to ensure local

concerns are addressed as they arise.

This policy does not directly refer to the hiring of local people but the Developer has made a

commitment to hire as many local people as possible in order to enable the maximum benefit for

the local population. The ESMP will contain a framework for a local content strategy and the

Developer’s existing recruitment and skills development policy will be developed further to

specifically include local recruitment.

The local content strategy will include requirements for job opportunities to be disclosed locally

to Project affected peoples, with priority in recruitment given to vulnerable populations. The

strategy will include the means by which local people hired on a short-term basis during

construction can obtain permanent contracts on the Project during the operational phase.

In addition, to maximise job opportunities for local people, the local content strategy will need to

facilitate skills development of the local workforce. The local content strategy will reflect the

Developer’s commitments (as per their recruitment and skills development policy) to adhere to

non-discriminatory practices and opportunities should be made available to all local people

regardless of their ethnicity, caste, religion, gender or age. The overarching aim should be to

provide longer-term benefits to local people beyond the lifetime of the Project, therefore

enhancing everyone’s future employability.

15.7.3 Occupational health and safety plan

In order to mitigate the large amount of risks associated with working on construction sites and

safeguard worker’s well-being, an OHS plan is required to identify preventative and protective

measures to protect the health and safety of workers on-site. The Developer has developed

HSE policies and an EPRP.

Mitigation measures that must be covered in the Developer’s OHS policy will include the

following:

● Exposure to physical hazards from use of heavy equipment

● Trip and fall hazards

● Exposure to dust, noise and vibrations

● Falling objects


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● Exposure to hazardous materials; and exposure to electrical hazards from the use of tools

and machinery

● Working at height, with live power equipment and lines

● Exposure to EMFs

● Working in confined spaces

● Proper use of PPE by all workers

● Contractor to have an appropriately equipped first aid room and staff to address workers’

and communities’ health needs

● Site safety awareness training

● Monitoring and reporting of accidents, injuries, lost-time incidents, near misses and

community interactions on health issues

● Worker accommodation monitoring

● Tool box talks on hygiene and sanitation at least every six months

● Good housekeeping on site

● Control and quality assurance of drinking water

● Pest and vector control activities

● The plan will cross reference the workers code of conduct that has been developed by the

Developer, which outlines rules by which workers have to abide by in order to safeguard

against any harmful practices that might affected the local communities and/or other workers

on site.

15.7.4 Community health and safety plan

There are a number of activities during the construction phase which need to be mitigated in

order not to cause any risks for local communities. Therefore, a community health and safety

plan will be developed to safeguard local community members and the public. It will include but

not be limited to measures to address:

● Appropriate signage and fencing

● A site registry system to prevent unauthorised access to the public

● Safety exclusion zones

● Traffic management measures

● Health screening for nearby residents

● A safety awareness campaign

The traffic management measures will need to include: an awareness raising campaign for local

populations, adequate signage, speed restrictions and circulation restriction of vehicles,

particularly at night.

The plan will cross reference with other relevant management plans such as the OHS Plan and

the SEP. Local health care and emergency services will be consulted in the development of the

plan.

15.7.5 Site security plan

There are a number of potential safety risks for local communities associated with large scale

construction sites. In order to ensure these are adequately mitigated a Site Security Plan has

been developed to manage security arrangements and safeguard the human rights and

wellbeing of members of the public and local communities when encountering security


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providers. The plan will make a commitment to comply with national law and Project’s approach

is underpinned by the principles of proportionality and good international industry practice. The

plan must include provisions for:

● Responsible hiring (including vetting for past criminal offences)

● Training

● Means of security and equipment

● Use of force and weapons

● Access and incidence logging

● Community grievance mechanism (summary of that presented in the SEP)

● Use of government security

● The plan also provides contract details of the Project management and specifies monitoring

measures.

15.7.6 Influx management plan

An influx management plan should be produced to avoid and mitigate the effects of Project-

induced migration, particularly the non-local workforce that will be present on the three local

construction sites (Block II – coal power plant, Block VI – open pit mine and Block VI – coal

power plant). This would include consideration of the following measures to be undertaken in

consultation and in partnership with regional government (key stakeholders will be spatial

planners) and civil society:

● Organising Project recruitment and employment to minimise potential workers going to the

Project site

● Ring-fencing community investment funds for spatial planning and to support local initiatives

to address greater demand for social and community services and infrastructure. The

company should develop a dedicated community investment plan, outlined in section 15.7.7

below.

● Holding influx forums every year during construction to bring together stakeholders and

service providers to create awareness of influx status, share monitoring data, identify

lessons learned, and disseminate good international industry practice

● Supporting financial management through providing financial management seminars to

workers, and consulting with the Government to promote presence of banking and micro

finance services for local entrepreneurs and small and medium businesses in the IAI. NGOs

working specifically with women must be able to participate in order to enable women to

benefit from these allocated funds.

In addition, the Project should ensure that workers are provided with their own health services

such as an onsite clinic and relevant medical staff. Furthermore, the company should provide

transportation for workers to access hospitals outside of the IAI in the case of emergencies. The

other two developments in Block VI and II will also need to ensure that their workers are

provided with adequate health facilities and safety measures are put into place in order for there

to be no cross over of influx.

15.7.7 Community investment plan

A needs-based community investment plan (CIP) should be developed and implemented to help

mitigate the potential adverse impacts of Project-induced in-migration and to share Project

benefits more fully with local communities. The CIP should be implemented in partnership with

local and regional Government authorities, local leaders, NGOs and civil society bodies which


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have local ties with communities. Local peoples will be trained and hired as cadres to implement

programmes. Funds will need to be ring-fenced with annual disbursement budgets

disaggregated between programmes.

The assessment identified that the following interventions could contribute to local development:

● Agriculture – to support agricultural production, for instance through rural extension support

and training in farming techniques as well as value chain benefits such as storage, access to

markets, and inputs; livestock activities could be supported with veterinary services, animal

feed, animal housing, and services for animal health and production.

● Livelihood diversification – technical training could be provided in alternative livelihoods such

as sewing, equipment repair, and hospitality; this could be accompanied with capacity

building in financial management and accountancy and access to micro-credit or savings

and loans facilities or cooperatives.

● Education and health – Education services could include support to schools in terms of

infrastructural improvements and materials such as books, uniforms, and computers;

education infrastructure could be improved, for instance the provision of toilet facilities at

existing schools, and the building of schools for girls; capacity building could be provided for

local teachers; health infrastructure could be improved, for instance provision of clinics and

services. The education and health measures should be undertaken in partnership with the

Government and local civil society organisations to ensure sustainability and maintenance.

● Community infrastructure – including community solar lighting, clean water wells, road

maintenance.

The SEP and the influx management plan should align with the CIP. The CIP will need to

include monitoring against clear key performance indicators. Annual revisions made to the CIP

should use monitoring results to feed into the budget allocation process each year.

15.7.8 Chance find procedure

The Project will not need to conduct an in-depth archaeology study, as there is not enough

substantiated information that leads to the belief that there is considerable cultural heritage

present in the area. However, the Project will need to develop a chance find procedure to

mitigate for the possibility of uncovering historical remains, antiquity or any other object of

cultural or archaeological importance that are unexpectedly discovered during construction

phase.

15.7.9 Worker accommodation plan

A Worker accommodation plan (WAP) will be required for both the construction phase and the

operations phase in order to mitigate any impacts to workers and community members caused

by the provision of temporary accommodation being provided for 400 workers on site.

The WAP should follow the EBRD/IFC guidance note on Worker’s Accommodation: Processes

and Standards (2009) as good industrial industry practice. In particular, the WAP will need to

address: sleeping areas; sanitary and toilet facilities; canteen, cooking and laundry facilities;

standards for nutrition and food safety; medical facilities; and leisure, social and

telecommunication facilities, considering different requirements for local and expatriate workers.

The WAP should ensure there is a management team responsible for the hygiene, safety and

security of accommodation. The plans need to consider ways of safeguarding workers’

valuables, perhaps through the provision of individual safe boxes that can be stored safely and

accessed as required. Workers will not be charged for accommodation and related services. If


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there are charges, these will be identified in the WAP and when workers sign their contracts.

House rules and regulations that are reasonable and non-discriminatory will need to be included

in the WAPs once workers’ representatives are consulted about them.

Employees’ living and working conditions will need monitoring. Government labour inspections

are not systematic, often leaving work camps and construction conditions that are not compliant

with basic occupational safety to continue unchecked. Monitoring of accommodation conditions

will need to be addressed in the WAP and undertaken using the checklist in the IFC guidance

note. Monitoring will be undertaken on a quarterly basis until at least two reporting periods have

identified no corrective actions, after which monitoring can be six monthly.

15.7.10 Gender strategy

A gender strategy should be developed as part of the ESMP to cover both the construction and

the operations phase to ensure that women are able to access the benefits of the Project. The

gender strategy will aim to:

● Raise gender awareness of the different roles and responsibilities within the community, the

economy and agricultural production

● Implement a gender mainstreaming component in all Project related plans and programmes

● Suggest practical and measurable gender actions and targets to be achieved as a result of

the Project and related programmes

The gender strategy actions will be strongly connected to other plans and programmes related

to the Project and harmonised with other management plans.

15.7.11 Indigenous peoples

Although local people do not auto-identify as indigenous102, there are a number of different

ethnic and religious groups in the IAI as outlined in Section 15.4.9 that could be considered

indigenous. The Project should conduct an assessment to determine if any of these groups are

considered indigenous as this would mean they could require additional mitigation measures.

The Project should use the IFC PS7, which provides the most up-to-date guidance (2012). The

IFC defines the characteristics for indigenous peoples as follows:

● Self-identification as members of a distinct indigenous cultural group and recognition of this

identify by others

● Collective attachment to geographically distinct habitats or ancestral territories in the Project

area and to the natural resources in these habitats and territories

● Customary cultural, economic, social, or political institutions that are separate from those of

the dominant society and culture

● A distinct language, often different from the official language of the country or region

If it is determined that indigenous peoples are present in the IAI, then the Project should

develop an Indigenous Peoples Plan as outlined in the IFC PS7 guidelines.


The social impacts and mitigation and management measures discussed in the sections above

are summarised in Table 113 below. The table also presents the conclusions on residual

significance after the application of mitigation and benefit enhancement measures.

102 Focus Group Discussions conducted by Mott MacDonald Pakistan in June 2016


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Table 113: Summary of social impacts and mitigation / enhancement measures

Activity Potential Impacts Sensitivity Magnitude Residual impact significance

Mitigation or enhancement

Statement of significance

Construction

Recruitment of construction workforce

Employment generation for local communities

High Minor Moderate beneficial Local content strategy to be developed as part of the ESMP documentation

SEP and local content strategy to specify means for disclosure of employment opportunities and employment and training opportunities for local people.

Significant

Efforts will be made to employ local people (especially those considered vulnerable) providing upskilling so their roles can continue through to the operational phase.

Influx management Influx of workers has adverse impacts on the local community

High Moderate Major adverse Influx management plan will be developed and implemented

Significant

The project company will provide health facilities for their workers and transportation will be provided to ensure workers do not use the local facilities.


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16 Cumulative impact assessment

16.1 Introduction

This section provides an assessment of cumulative impacts arising from the combination of the

development of the power plant and the lignite mine in Block VI.

Cumulative impacts associated with the interaction of impacts that occur outside of Block VI and

the combination of Block VI and other Blocks in the Thar Coalfields are outside the scope of this

assessment. The cumulative impacts associated with development of all the Blocks in the Thar

Coalfields are described in the SESA, commissioned by the Government of Sindh.

Cumulative impacts are evaluated and described as adverse or beneficial impacts, alongside

their temporal and spatial scope, focusing upon combined, additive or synergistic impacts.

Sensitive receptors are identified where relevant. Due to the nature of the impacts, the

assessment methodology differs from the methodologies used in the respective ESIAs and is

focused on a qualitative review of likely significant impacts identified in the respective ESIA

reports.

The assessment also identifies any relevant mitigation and enhancement measures. These may

be measures that are identified in the impact assessments and can be adapted in terms of their

geographic scope, their scale or their timing.

Based on current information, construction phases of the Block VI lignite mining project and

power plant will be undertaken in a similar time period as outlined below:

● Mine construction of access road, offices, accommodation, dewatering installation: Q4 2017-

2019, with overburden removal continuing until 2022.

● Power plant construction is planned to commence in 2018.

The Block VI lignite mining project operational phase is expected to begin in Q3 2017, and the

Block VI power plant from 2021. Both Projects are therefore expected to be in operation in

unison for approximately 30 years.

16.2 Employment generation cumulative impacts

As a result of the combined construction of the Block VI power plant and Block VI lignite mining

Project, there are likely to be cumulative beneficial impacts upon local communities associated

with temporary employment generation during the construction period. Although the skill base of

local communities is low, and therefore jobs would likely be limited to unskilled labour, local

communities have a high demand for employment.

Despite the temporary nature of the majority of jobs, workers may develop new or enhance

existing skills, which may increase the transferrable skill base and future income generation

prospects of those workers. These skills learnt on one Project could be directly transferred to

work on the neighbouring Project, thus extending the employment length of some workers.

A social impact as a result of this employment generation is likely to be an enhancement in

quality of life as a result of the provision of income for workers and their families, particularly

given the high poverty levels in the immediate area of influence of Ranjho Noon, Yaqoob ji

Dhani, Yosuf ji Dhani, Gangoo ji Dhani and Salar ji Dhani. Wider socio-economic benefits may

be experienced by the local economy as a result of the spending of worker earnings on local

goods and services.


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A variety of actions have been identified to be undertaken by both the Block VI lignite mining

Project and Block VI power plant to enhance the benefits which may be experienced by local

communities. These include:

● A local content strategy will be included in the ESMP for the Block VI power plant, and a

SEP which will specify means for disclosure and employment opportunities.

● The Block VI lignite mining Project will engage a local employment priority policy, and will

establish a vocational training centre in the early phases of construction to increase the

ability of local people to compete for job opportunities.

A coordinated approach between Projects regarding the employment of local populations and

the upskilling of unskilled workers should be undertaken. Furthermore, recruitment and human

resources processes should be aligned for both Projects from the outset, to ensure the fair and

consistent treatment of workers.

16.3 Influx of workers’ cumulative impacts

Both Projects have identified the need for skilled constructional and operational labour

requirements which cannot be met in full by the local population. This will therefore lead to the

influx of migrant workers, and potentially some opportunistic economic migrants, which can

have negative impacts upon local communities in both stages of the Project, but particularly

during construction due to the transient nature of the construction workers. As the population of

the five villages within the Block is only 2,250 people, even an influx of a small number of

workers is identified as having potential negative impacts upon these local populations such as

cultural changes, strains upon already inexistent social services and increase incidents of risk-

taking behaviour.

A variety of actions have already been identified by both Projects to mitigate the negative

impacts possible as a result of worker influx. For example:

● This ESIA identifies an influx management plan to be developed as part of the environmental

and social management plan, and also a community investment plan will be implemented.

● As part of the Block VI lignite mining Project, a social mitigation plan will be implemented,

including measures such as a “cultural emersion and sensitisation course” as part of the

induction plan for new employees.

A coordinated approach should therefore be taken to ensure that adequate services are

provided for workers to ensure workers do not use local facilities, and that actions to

mitigate/enhance impacts are undertaken as outlined in both Projects’ management plans.

Furthermore, management plans identified in both EIAs for mitigating issues of worker influx

could be combined, to enable the minimising of negative impacts upon local communities and

services.

16.4 Landscape and visual amenity cumulative impacts

This ESIA identified that during both construction and operation, negative cumulative impacts

are predicted to occur upon nearby receptors, particularly those within 2km of the site. Changes

in landscape character as a result of land use change from desert to power plant and mine, a

loss of vegetation, and an increase in light pollution levels will contribute to long-term adverse

impacts upon both visual amenity and landscape character. During operation the physical

presence of the new Block VI power plant and Block VI lignite mining Project will permanently

alter the landscape character and visual amenity.


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During construction, it is expected that best practice operating procedures will be followed to

avoid or mitigate where possible visual or landscape impacts upon nearby receptors. These

mitigations are identified to include down-lighting of any temporary lighting, the limiting of land

occupation to the minimum necessary for the works, and the identification of opportunities for

landscaping on site. Similarly, during operation external lighting will be minimised. As part of the

Block VI power plant mitigation, the lower parts of Project buildings should be painted in neutral

colours to be representative of the surrounding landscape and thus minimise cumulative visual

impact.

Therefore, there is an opportunity to take a Block-wide approach to landscaping (vegetation and

of buildings) and lighting during the operation phase. A site-wide strategy could be put in place,

taking account of any sight-lines from local communities.

16.5 Noise cumulative impacts

Although noise impacts associated with the power plant are not predicted to result in significant

impacts in this ESIA, the cumulative impact of Projects could result in some local communities

in close proximity to the Projects experiencing negative impacts which are of longer duration or

greater collective magnitude than identified in individual assessments for these Projects.

Both Projects have identified measures to control and avoid noise emissions. For example, this

ESIA identified Yusef di Jhani residential area as the closest and most sensitive receptor to

noise from the power plant. However, this was assessed as not significant if mitigation

measures such as limiting noisy works to daytime hours only where necessary are put in place.

Similarly, for the Block VI lignite mining Project, best practice mitigation measures such as noise

mufflers on machinery are proposed.

In addition to mitigation measures outlined in both ESIAs, stakeholder activities should include

consultation with people in Yusef di Jhani and other nearby residential areas, to identify any

cumulative noise-related nuisance.

16.6 Air quality cumulative impacts

During construction, there are not expected to be significant cumulative impacts with regards to

air quality as a result of construction of the Project site and the mine, as most emissions from

sources such as construction vehicles and the two Block VI lignite mining project generators are

likely to be minor and localised in nature, and the main emission source of the Block VI power

plant will not be in operation.

During operation, this ESIA considered the main emission source of the proposed Block VI

power plant stack and found that impacts on sensitive receptors were not significant. Although

there will be other sources of emissions such as on-site vehicle movements as a result of

mining operations, these impacts will also be localised and unlikely to result in a cumulative

impact on receptors.

Best practice techniques will be employed at both sites and through all phases of the Projects to

minimise air emissions as described in the relevant management plans, including measures

such as using a fuel efficient model choice of generators, and the use of modern, best available

technologies in each Project.

In addition, a coordinated approach to any grievances related to air quality should be

undertaken to account for any cumulative impacts.


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16.7 Dust cumulative impacts

High levels of fugitive dust are a common phenomenon due to the nature of the ground and the

climate in the Thar region, and although dust emissions are assessed as not significant at all

stages of the power plant Project, it is possible they may have some cumulative impacts upon

nearby receptors when combined with the dust impacts of the mine facilities (for example dust

from lignite stockpiling activities, the movement of construction vehicles around Block VI and

between the mine and power plant during operation), particularly any sensitive receptors within

350m of the sites.

Extensive mitigation measures are proposed in this ESIA for both construction and operational

phases, and will form part of the ESMP, which include measures such as:

● The minimisation of dust during construction and operation through international best

practice measures, control measures, and dust suppression techniques.

● Ensuring that a grievance mechanism is in place for effective reporting and action for any

dust issues.

Similarly, the mining development will use dust control measures such as water spray and the

covering of stockpiles, which will greatly reduce the ability of fugitive dust to travel beyond the

boundary.

Therefore, there is an opportunity to capture the best practice techniques that are relevant to

the activities undertaken at both the Projects and adopt one common list of measures that

control dust.

16.8 Hydrology and hydrogeology cumulative impacts

The hydrology, hydrogeology and flood risk chapter of this ESIA includes an assessment of the

cumulative impacts upon hydrology and hydrogeology. It is understood that the GoS is

preparing a water management plan for the entire Thar Coalfield, which would establish a

baseline for all water resources in the area and allow a cumulative assessment of the impacts

upon water quality and quantity as a result of new developments.

Therefore, it is recognised that this is an important issue where cumulative impacts could arise

and therefore the issues relevant to both Projects in Block VI need to be effectively

communicated and represented in the water management plan.

16.9 Summary

This chapter identifies the cumulative impacts that may result from the construction and

operation of Block VI lignite mining Project and the Block VI power plant Project. Cumulative

impacts associated with the interaction of impacts that occur outside of Block VI and the

combination of Block VI and other Blocks in the Thar Coalfields are outside the scope of this

assessment. The main opportunities identified in this chapter are:

● Opportunities to align approach to local content/recruitment, human resources processes

and opportunities for workers to extend employment by working on both Projects, where

appropriate.

● A coordinated approach to managing the influx of workers required for the Projects, to

minimise disruption to existing local communities and services.

● Adoption of a site-wide approach to landscaping, during operation and decommissioning.

● Adoption of common site-wide measures to control air quality emissions, dust generating

activities and noise emissions during construction and operation, complemented by

stakeholder engagement to detect community grievances.


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● Make representations to the GoS as they develop the water management plan for the Thar

Coalfields, to ensure the needs of Block VI development are taken into consideration.


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