RBOD ProjectEnvironmental Vista

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RBOD Project-Environmental Vista

• Naseer Memon

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RBOD Project

• Stage-I Larkana and Shahdad Kot districts
• Stage-II Kashmore, Jacobabad, Dadu districts
  and Balochistan
• Stage-III IV Sindh and Balochistan
• Length of drain 273 kms
• Design discharge increased from 2,271 to 3,525
  cusecs
• Cost increased from Rs. 14 to 31 billion
• Expected completion-2008

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Drainage projects are environmentally sensitive
development projects and need careful design
implementation, stringent mitigation measures and
effective long term monitoring
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Outfall Options

• Manchar Lake
• River Indus
• Evaporation Ponds
• Via LBOD to Sea
• Via RBOD to Sea
• The last option is likely to be the least
  damaging if socio-environmental impacts are
  properly mitigated

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Environmental Impact Assessment

• Conducting EIA is a pre-requisite for
  environmentally sensitive large projects.
• Public sector projects are generally implemented
  without EIA.
• It is appreciable that the IPD conducted an EIA
  for RBOD project.

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Review of the EIA

• EIA is a guiding document for environmental
  management of the project. Therefore it would be
  pertinent to review the stipulations of the EIA.
• Stakeholder consultation on environmental issues
  is missing which is mandatory under PEPA Act
  1997.
• Responsibilities in some areas are not clearly
  defined. e.g. who will ensure pre-discharge
  treatment of Kotri industrial effluent?
  (proponent is responsible)

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Review of the EIA

• The EIA proposes Environmental Biological
  Management through plantation of 2 million trees
  in Khirthar hills.
• It is not clear as to who will implement this
  huge undertaking and who will fund this plan.
• Abstract of cost given in the PC-1 of the project
  (page 35-36) is silent about this item. EIA also
  does not give any rough estimates.
•  

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Review of the EIA

• The following aspects are also missing in the
• EIA
• Change Management
• Indicators for compliance and effect monitoring
• Selection of camp sites, waste disposal and
  restoration plan
• Transport management (speed limits, oil leakages,
  washing etc.)

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Impact on hill torrents ecosystem

• The project area is exposed to occasional
  torrential flows from Khirthar range
• The EIA document does not provide adequate
  information on likely effects of the project on
  hill torrent ecosystem and the drain structure
  itself.
• Lessons learnt from CBRC need to be analyzed and
  incorporated.

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Impact on hill torrents ecosystem

• The following aspects require further
  investigation
• Number of torrents interrupting the drain, their
  maximum past discharges and frequency
• Impact on downstream water users and resulting
  socio-economic losses
• Engineering risk involving training of flash
  floods through narrow escapes

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Impact on local aquifer

• Drainage projects pose serious environmental risk
  for freshwater aquifers
• The EIA does not adequately cover this very
  important environmental aspect.  
• The project area runs closer to River Indus. It
  is most likely that the area has freshwater
  recharge zone with relatively higher water table,
  which will become prone to saline seepage. 
• Revised PC-I provides stone pitching of bunds and
  lining of bed
•  

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Impact on Gharo creek ecosystem

• Chapter 6 (page-6-11) mentions, No monitoring
  was done for the Gharo Creek, therefore no
  scientific statement can be made viz-a-viz
  environmental impact of K.G drain on the Gharo
  Creek.
• However in conclusion it is said that The
  current environmental assessment of Gharo Creek
  does not indicate any serious state of
  pollutionTherefore, it can be predicted that
  with the discharge of RBOD into Gharo will not
  have a negative impact

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Impact on Gharo creek ecosystem

• It is not clear what sort of assessment is
  referred here in absence of monitoring.
• Gharo creek ecosystem merits scientific
  assessment before jumping into conclusions like
  no impact.
• For long-term impact assessment baseline
  information need to be collected.
• EIA is silent about mitigation measure if such
  monitoring establishes negative environmental
  impact on the creek ecosystem.

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Tidal Impact

• Page 6-11 article-vi mentions with the rising
  tide the flow in the Khuhi-Gharo drain is
  reversed up to almost 10 kms from the creek.
• This reminds terrible failure of Tidal Link Canal
  of LBOD.
• LBOD changed whole regime of KPOD after
  construction of the Tidal Link Canal.
• The EIA is silent about the likely impact of the
  backflow in KG drain after commissioning of the
  RBOD. Also it does not give details of outfall
  structure

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Socio-economical Issues

• Socio-economical issues of any large development
  project are long reaching and are integral part
  of environment. This may include employment,
  displacement, impact on means of livelihood,
  historical rights of communities, gender
  perspective etc.
• The EIA has very superficially touched (only 7
  lines (page 6-3) this very vital impact of the
  project.

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Socio-economical Issues

• The only aspect discussed is possibility of local
  employment and termed it positive. It does not
  even stipulate any terms for employment
  distribution and other related issues.  
• There is no mention of impact on ground water,
  loss of livelihood, women issues etc.
• Absence of comprehensive socio-economic impact
  assessment might eventually result in
  complications for the project executants.

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Recommendations-Impacts

• The following aspects should be studied in
  greater details
• Impact on hill torrents ecosystem
• Impact on freshwater lakes
• Impact on Gharo creek ecosystem
• Impact on ground water aquifer
• Impact on livelihood means of communities
• Impact of backflow during high tide

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Recommendations-Monitoring

• Establishing Environmental Cell in IPD for the
  project is appreciable.
• Environmental impact monitoring should not be
  restricted with the Environmental Cell. It should
  be made broad based involving other stakeholders
  like SEPA, SWD, Environmental NGOS e.g. WWF, IUCN
  and universities.  
• Environmental monitoring reports should be made
  public on quarterly basis.

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Recommendations-Upstream Measures

• In order to mitigate environmental impacts,
  upstream measures should also be considered.
• Like treatment of industrial effluent of Kotri,
  similar measures may also be adopted in the
  districts releasing agricultural disposal in
  MNVD.  
• In collaboration with the Agriculture department
  use of chemical fertilizers and pesticides may be
  restricted and gradually replaced with organic
  alternatives to minimize pollutants in RBOD.  

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Recommendations-Upstream Measures

• Municipal effluent received by MNVD may also be
  treated before releasing into the drain.
• The environmental monitoring plan should also
  encompass these aspect.
• Future extension at upstream should only have
  been considered after satisfactory performance of
  the current phase of the project.
• At suitable upstream locations localized
  evaporation and recycling options should also be
  investigated to reduce the discharges.

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Recommendations-Learning from Past

• RBOD is the second largest drainage project in
  Sindh after LBOD.
• Issues, failures and successes registered in the
  LBOD project should be carefully analyzed and
  incorporated in RBOD project.
• Implementing the project in shortest possible
  time with lowest possible cost is appreciable
  objective but not at the cost of increased risk
  and higher cost for people

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• Thank You