Project Title to be centred - Welcome to LESCO Augmentation... · Web view1.7 Structure of Report 5 2. Description of the Project 7 2.1 Type of Project 7 2.2 Categorisation of the

Power Distribution Enhancement Project

(Loan 2178 SF-PAK)INITIAL ENVIRONMENTAL EVALUATION

LESCO Transformer’s Augmentation Sub-projects

CONTENTS

1. INTRODUCTION 11.1 Overview 11.2 Requirements for environmental assessment 11.3 Scope of the IEE Study and Personnel 41.4 Policy and Statutory Requirements in Pakistan 51.5 National Environmental Quality Standards 51.6 Solid waste management 51.7 Structure of Report 5

2. DESCRIPTION OF THE PROJECT 7

2.1 Type of Project 72.2 Categorisation of the Project 72.3 Need for the Project 82.4 Location and Scale of Project 82.5 LESCO Subprojects 9

3. Description of the Environment 14

3.1 Sub-project Project Areas 143.2 Topography, Geography, Geology, and Soils 143.3 Climate and Hydrology 143.4 Groundwater and Water Supply 143.5 Surface water 143.6 Air Quality 153.7 Noise & Vibration 153.8 Ecological Resources 163.9 Economic Development 17

Asian Development Bank

May, 2009Lahore Electricity Supply Company

Government of the Islamic Republic of Pakistan

3.10 Social and Cultural Resources 183.11 Education & Literacy 183.12 Health Facilities 20

4. SCREENING POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 21

4.1 Project Location Impact Assessment and Mitigation 214.2 General Approach to Mitigation 214.3 Prevention of ground contamination 224.4 Cultural Heritage, Temples, Religious Sites, Social Infrastructure224.5 Potential Environmental Impacts in Construction 224.6 Trees, Ecology and Protected Areas 234.7 Hydrology, Sedimentation, Soil Erosion 234.8 Air Pollution from Rock Crushing, Cut, Fill, & Asphalt 234.9 Noise, Vibration and Blasting 244.10 Sanitation, Solid Waste Disposal, Communicable Diseases 244.11 Potential Environmental Impacts in Operation 254.12 Enhancement 26

5. INSTITUTIONAL REQUIREMENTS & ENVIRONMENTAL MANAGEMENT PLAN 27

6. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE31

7. FINDINGS RECOMMENDATIONS AND CONCLUSIONS 32

7.1 Findings and Recommendations 327.2 Conclusion 32

Figures and Maps

Figure 1.1 Pakistan EIA ProcessFigure 1.2 Letter from Pakistan Federal EPA on EIA ProcessFigure 2.1 Jurisdiction of LESCOFigure 2.2 LESCO Substations

Appendices

Attachment 1 A-D Location of sub projects. Attachment 2 Photographs of the DGS locations Attachment 3 Environnemental Management Plan (matrix)Attachment 4 Monitoring Plan (matrix)Attachment 5 Typical bunds for transformers

Power Distribution Enhancement Project – LESCO Transformer’s Augmentation Subprojects

Initial Environmental Examination

ABBREVIATIONS

ADB Asian Development BankCSP Country Strategy ProgramDGS distribution grid substationDISCO independent electricity distribution companyDX distribution transformerDXL distribution network transmission lineDIZ Direct Impact ZoneEA Environmental AssessmentEARF Environmental Assessment Review FrameworkEIA Environmental Impact AssessmentEMP Environmental Management PlanGDP Gross Domestic ProductGoP Government of PakistanGIS Gas Insulated SwitchgearITC Increase transformer capacity - augmentationLESCO Lahore Electricity Supply Company LimitedLeq equivalent sound pressure levelMPL maximum permissible levelNEQS National Environmental Quality StandardsNGO Non Governmental OrganizationPC public consultationPEPA Pakistan Environmental Protection AgencyPEPAct Pakistan Environment Protection Act 1997 (as regulated)PPMS Project Performance Monitoring SystemPWD Public Works DepartmentREA Rapid Environmental AssessmentREI review of environmental implicationsSEA Sectoral Environmental AssessmentSEL instantaneous sound pressure levelSIA Social Impact AssessmentS-P sub-projectSR Sensitive ReceiverTOR Terms of Reference

PKR Rupee: Unit of Pakistan currency. $US approx = Rs 80

i

Power Distribution Enhancement Project – LESCO Transformer’s Augmentation Subprojects Initial Environmental Examination

1. INTRODUCTION

1.1 Overview

This document is the Initial Environmental Examination for the Tranche 2 extension and augmentation sub-projects of Lahore Electricity Supply Company (LESCO). This IEE was prepared under TA Loan 2178 of the Asian Development Bank (ADB) Power Distribution and Enhancement Multi-tranche Finance Facility (PDEMFF).

Government of the Islamic Republic Pakistan (GoP) has requested ADB to provide the PDEMFF to facilitate investments in power distribution and development of networks of eight independent distribution companies (DISCOs) that distribute power to end user consumers. The funding from ADB is expected to be released in stages (tranches). The Power Distribution Enhancement (PDE) Investment Program is part of the GoP long term energy security strategy. The proposed ADB intervention will finance new investments in PDE and assist capacity building of sector related agencies. The investment program will cover necessary PDE development activities in secondary transmission/distribution networks of eight DISCOs and the PDEMFF loan is proposed to be approved by ADB in 2008. The PDEMFF activities include extension (additional transformers) and augmentation (replacement of transformers with higher capacity) distribution line extensions, new and replacement distribution lines, additional sub-stations, transformer protection and other non network activities such as automatic meter reading, construction equipment and computerized accounting. New distribution lines to and from various network facilities and some of the above activities will also be included in the later tranches.

This IEE presents the results and conclusions of environmental assessment for the twelve(12) augmentation sub-projects proposed by LESCO and is submitted by Pakistan Electric Power Company (PEPCO) on behalf of LESCO. PEPCO has been nominated by Ministry of Water and Power (MOWP) to act as the Executing Agency (EA) with each DISCO being the Implementing Agency (IA) for work in its own area. PEPCO’s role in the processing and implementation of the investment program is that of a co-ordinator of such activities as preparation of PC-1s and PFRs, monitoring implementation activities; that includes submission of environmental assessments for all sub-projects in all tranches of the PDEMFF under ADB operating procedures. An IEE has been carried out to fulfill the requirements of ADB Guidelines (May 200312). This IEE study report is used to complete the Summary Initial Environmental Examination (SIEE) for disclosure by ADB if necessary3.

1.2 Requirements for environmental assessment

Under the MFF loan procedures of ADB, implementation of safeguards is to be achieved by environmental assessment of every sub-project to be undertaken following ADB Environment Policy (2002) and ADB Environmental Assessment Guidelines (2003). Power distribution enhancement and development type projects, that are limited to expansion of already developed facilities, have typically been classified as Category B. Each sub-project

1 Initial project classification was carried out in 2009 and the Category is B. Most of the construction impacts will take place with only local impacts and there are no potential significant environmental impacts associated with the T2 (tranche two) sub-project construction. Initial environmental reconnaissance and REA carried out by consultants under ADB guidelines in 2009 indicated that all the T2 sub-projects will be Category B.2 Environmental Assessment Guidelines (ADB May 2003)3 Category A projects that are deemed by ADB's chief compliance officer to be environmentally sensitive for the purposes of (i) the 120 day rule, and (ii) the environmental management plan requirement could involve projects that are near or in environmentally sensitive areas. At this stage no component of the T2 sub-projects under consideration is actually within a critical area and therefore the MFF tranche as a whole is Category B.

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as been subject to environmental assessment after categorisation and the focus was on the most significant issues.

Under GoP regulations, the Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations (2000) categorizes development projects into two schedules according to their potential environmental impact. The proponents of projects that have reasonably foreseeable impacts are required to submit an IEE for their respective projects (Schedule I).

Projects that have more adverse environmental impact (Schedule II) are required to submit an environmental impact assessment (EIA) to the respective provincial Environmental Protection Agency (EPA). Distribution lines and sub-stations are included under energy projects and IEE is required for distribution lines of 11kv and less and large distribution projects (Schedule I). EIA is required by GoP for all projects involving transmission/distribution lines of 11kv and above and for grid sub-stations (Schedule II).

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Expansion of facilities within existing sub-stations including extensions and augmentations of facilities within existing sub-stations are not listed as requiring environmental assessment. However because all the projects involve distribution equipment of 11kv and above at grid sub-stations there could be a technical requirement for EIA under GoP laws.

In that context a Framework of Environmental Assessment (FEA) on power extensions and augmentation sub-projects has been prepared by consultants and submitted to the Pakistan EPA, after hearings with provincial EPAs, which sought to “exempt” preparation of EIA/IEE for such small-scaled sub-projects such as those covered by this IEE.

In response to the FEA submitted by NTDC to the Pakistan EPA4 it has been clarified that all proponents must follow section 12 of the Pakistan Environmental Protection Act for all projects and furthermore that, only for augmentation projects by following the FEA, the

4 Letter dated 29th June 2007 – Ref 2(1)2004-W/KCP-DD from Pak EPA Sajjad Hussein Talpur, Dy Director (EIA/Mont) to NTDC, Muhammad Tahir Khan, Project Director PPTA, NTDC, WAPDA House, Lahore

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required procedures under section 12 would be completed. Pakistan EPA has also assumed that all proponents will consult with the relevant provincial EPAs (PEPA) and follow their advice. In 2006 Punjab EPA requested disclosure of the scope and extent of each subproject in order that the Director General of PEPA can determine if additional land is required and the need for IEE or EIA.

1.3 Scope of the IEE Study and Personnel

This IEE study has included field reconnaissance for all 12 of the sub-projects with surveys taking place from August 2008. The Study Area for each subproject was the sub-station and immediate environs. The areas inside the sub-stations for improvement works were identified and the sensitive receivers immediately adjacent to the sub-stations were recorded, including any irrigation facilities, water supply, habitable structures, schools, health facilities, hospitals, religious places and sites of heritage or archaeological importance and critical areas5 within about 50m of the edge of the sub-station boundary walls.

The field studies were undertaken by a core study team with experience of environmental assessment for power projects in Pakistan including Mrs Syeda Bushra Waheed, Mr. Waheed conducted preliminary scoping, surveys and assessment activities and co-ordinated the field surveys and analysis. Mrs Syeda Bushra Waheed, was responsible to supervise collation of information and co-ordinate the various public consultation activities. The environmental team also benefited from technical support and other important information on the impacts of the proposed power works provided in feasibility reports prepared for LESCO, by expert consultants dealing with engineering, power transmission, socio-economic, re-settlement and institutional aspects.The study process began with scoping and field reconnaissance during which Rapid Environmental Assessments2 were carried out to establish the potential impacts and categorization of network enhancement activities. The environmental impacts and concerns requiring further study in the environmental assessment were then identified. The methodology of the IEE study was then elaborated in order to address all interests. Subsequently both primary and secondary baseline environmental data were collected and the intensity and likely location of impacts were identified with relation the sensitive receivers; based on the work expected to be carried out at each site. The significance of impacts from the power transmission expansion works was assessed and, for those impacts requiring mitigation, measures were proposed to reduce impacts to within acceptable limits.

All the extension and augmentation projects covered in this IEE will only involve work within an existing sub-station to either, (i) replace an existing transformer with one of a higher capacity (ITC or augmentation) or (ii) add a transformer (extension). Therefore in these projects that involve work within an existing sub-station to improve the network performance the sole stakeholder is LESCO. Therefore the requirement for public consultation (PC) can be seen to be satisfied by consultation with LESCO who are clearly in support of their own project. Therefore under ADB requirements, the need for environmental assessment process to include meaningful public consultation during the completion of the draft IEE can be seen to be satisfied by the support of LESCO for their own projects.

5 Critical areas as published by the PEPA on the website put in specific reference

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1.4 Policy and Statutory Requirements in PakistanDirect legislation on environmental protection is contained in several statutes. The Pakistan Environmental Protection Act (1997) has bearing on this IEE. Since the projects covered in this IEE will only involve work within an existing sub-station other environmental legislation will not be triggered.

The Constitution of Pakistan distributes legislative powers between the federal and the provincial governments through two ‘lists’ attached to the Constitution as Schedules. The Federal List covers the subjects over which the federal government has exclusive legislative power, while the Concurrent List contains subjects regarding which both the federal and provincial governments can enact laws. “Environmental pollution and ecology” is included in the concurrent list; hence both the federal and the provincial governments can enact laws on this subject. However, to date, with a few exceptions the federal government has enacted laws on environment, and the provincial environmental institutions derive power from the federal law.

1.5 National Environmental Quality StandardsThe PEPA covers the improper disposal of all solid and liquid waste and specific limitations are placed on wastes and emissions from particular industries. The National Environmental Quality (Protection and Quality Regulations 1990, 1996 and 2000) identify specific industrial sources for control and an Environmental Protection License is required to discharge waste to the environment under controlled conditions. Where the project contractors require cement, concrete or granite based products for power improvement the materials must be obtained from facilities having a relevant and current Environmental Protection License.

1.6 Solid waste managementThe vast majority of waste in Pakistan comes in the form of domestic refuse and the requirements for solid waste management from such sources are covered by local authority legislation which has allowed some reasonable control of waste management in some urban areas. Elsewhere in the country the municipal or village authorities or Tehsil (not typical of the areas in which the LESCO sub-projects are located) are responsible to ensure proper disposal. However the lack of technical and financial resources has frustrated waste management planning. Fly tipping of waste outside towns and villages away from habitation is not an uncommon sight outside some district centers of habitation.

There will be waste associated with the LESCO addition and augmentation projects but unusually in this case the majority of likely waste will be in the form of small amounts of construction waste and any leaked or residual transformer oil that may fall to the soil. The replaced transformers will be retained, stockpiled and reused.

1.7 Structure of ReportThis report reviews information on existing environmental attributes of the areas around the Study Area. Geological, hydrological and ecological features, air quality, noise, water quality, soils, social and economic aspects and cultural resources are included. The report predicts the probable impacts on the environment due to the proposed project enhancement and expansion. This IEE also proposes various environmental management measures. Details of all background environmental quality, environmental impact/pollutant generating activities, pollution sources, pollution control equipment, predicted environmental quality and related aspects have been provided in this report. References are presented as footnotes throughout the text. Following this introduction the report follows ADB guidelines and includes:

Description of the Project Description of Environmental and Social Conditions Assessment of Environmental Impacts and Mitigation Measures Institutional Requirements Environmental Management Plan

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Public Consultation Findings, Recommendations and Conclusions

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2. DESCRIPTION OF THE PROJECT

2.1 Type of ProjectThe sub-projects in this IEE are all improvements to the equipment that supports the power distribution network at twelve (12) existing distribution grid sub-stations (DGS) that have been prioritized by LESCO and selected to be included in the PDEMFF Tranche 2. The proposed works will all be within existing DGS according to LESCO. Scope of work of 1x40 MVa augmentation sub project is presented in Annex 2 .

The sub-projects include twelve augmentation subprojects (Table 1.1). The environmental assessments that have been carried out follow ADB Environmental Assessment Guidelines 2003 and GoP’s environmental assessment regulations and guidelines.

Table 2.1: LESCO Tranche2 Sub-projects

Sub Project Numbe

r

Sub Project Name Voltage Type New

Capacity

Existing CapacityReplaced

Existing Capacity

5.5.1 Allama Iqbal Town T-3 132/11 A 1x40 MVA 1x26 MVA 3x26 MVA

5.5.2 Said Pur T-3 132/11 A 1x40 MVA 1x26 MVA 3x26 MVA

5.5.3 Garden Town T-3 132/11 A 1x40 MVA 1x26 MVA 4x26 MVA

5.5.4 Fateh Garh T-3 132/11 A 1x40 MVA 1x26 MVA 3x26 MVA

5.5.5 Old Kot Lakhpat T-3 132/11 A 1x40 MVA 1x26 MVA 3x26 MVA

5.5.6 Rehman Park T-3 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.7 Shadman T-2 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.8 Wapda Town T-1 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.9 Badami Bagh T-2 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.10 Bhatti Gate T-2 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.11 Qartaba T-2 132/11 A 1x40 MVA 1x26 MVA 2x26 MVA

5.5.12 Manga Mandi 132/11 A 1x40 MVA 1x26 MVA 3x26 MVA

Source: TA Consultants.

2.2 Categorization of the ProjectCategorization is based on the most environmentally sensitive component of the Project and therefore the twenty eight sub-projects at the existing DGS are categorized as a Category B. Tranche 2 is also Category B under ADB requirements 2 and this IEE report is based on that assumption.

At this stage the methods to install or replace the transformers are fairly well defined. There are few if any potentially significant environmental impacts and the works will all be within the twenty five existing DGS and will not encroach on any land outside the sub-stations according to LESCO. There is no foreseeable significant disturbance outside the substations and waste disposal should not involve significant impacts if routine environmental management procedures and engineering controls are implemented thoroughly.

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The aspects of the project with potential for any likely environmental impacts have been assessed, focusing on significant impacts from the extension and augmentation and any knock on effects from impacts such as waste disposal.

2.3 Need for the ProjectPakistan is a country with an economy of improving performance with a wide network of power distribution. However the standards and conditions of the power distribution are inadequate to meet rapidly growing power demand. This situation limits reliable power distribution and therefore the contribution of the power sector to national development and economic growth. To cope with the constraints, the existing power distribution infrastructure has to be improved and upgraded. The overall contribution of power infrastructure also requires institutional arrangements and capacity that support strategic management of the sector, and planning and management of investments. Overall the proposed PDEMFF Project has been designed in addressing both investment and institutional aspects in the sector.

The Tranche 2 projects will contribute to the improvement of the overall performance of the power distribution sector, improving distribution efficiency, broadly widening access to power to drive economic opportunities. The beneficiaries of the sub-projects will be people, companies, and government and non-government agencies in Pakistan that use power distribution services directly and indirectly. Communities indirectly served by the sub-projects will benefit from improved, secure faster distribution services. Power users will benefit in terms of secure power and improved power safety and potentially increased productivity.

2.4 Location and Scale of Project The augmentation projects will all be within the twelve existing DGS (Figures 2.1 and 2.2, Attachment 1) and will not encroach on any land outside the sub-stations. Annex 1and 5 presents photographs and location maps which show : space for additional transformer; or space for replacement transformer ; sensitive receivers in the vicinity of the sub station ; and land features of the land adjoining the sub station boundaries . The tranch2 implementation schedule is presented as follow

1 2 I II III IV I II III IV I II III IV I II III IV I II III IV I II III IV I II III IV I II III IVLoan ProcessingLoan negotiation ADB EADTranche 2 Approval ADB EADLoan Effectivity EAD ADBBidding DocumentsBidding Documents Preparation PEPCO DISCOsEvaluation PEPCO DISCOsContract Awards PEPCO DISCOsConstructionDelivery of equipment Contractor Construction & Installation Contractor Testing & Commissioning Contractor Loan Closing ADB PEPCO

TIME SCHEDULE - TRANCHE 2 - DISTRIBUTION ENHANCEMENT PROGRAM Year 2011 Year 2012Responsibility Year 2015 Year 2016Year 2009 Year 2010 Year 2013 Year 2014

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The augmentation sub-projects will replace an existing transformer in an existing DGS with a transformer of a higher capacity (ITC or augmentation). The transformer that is replaced will not be wasted but will be removed and transferred to at another LESCO facility where it will be reconditioned, stored and eventually transferred to another DGS to be reused. The Project Proponent (LESCO) plans to have the T1 completed by mid to late 2009. The details for the implementation of the 12 augmentation sub-projects are in development.

2.5 LESCO SubprojectsThe12 subprojects are in urban areas of Lahore and, in the urban fringe areas nearby, as well as in some other smaller towns and cities in the jurisdiction of LESCO. The areas surrounding the relevant DGS are described in the reviews of environmental implications (REI) that are presented in Attachment 2. Photographs of the DGS are presented in Attachment 3. The extension and augmentation projects are spread out around sites within the LESCO jurisdiction (Figures 2.1 and 2.2).

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132 kV Saidpur Sub project:

The SP propose an increase in Transformer capacity of Saidpur DGS by replacement of a 20/26MVA T1transformer by a 40MVA 132/11kV transformer, with allied equipment. Multan Road at north side of DGS. Sabzazar Colony at 500m. Primary and High School for Boys & Girls at 1 km. Many private clinics and Govt. Nawaz Sharif Social Security Hospital 1 km. Mansura Hospital at 2km. canal at 5 km. Shrine, mosque, graveyard across the road at 100 m in Sabzazar. Potable water is available. On North side Access to DGS on main Multan Road, Lahore, Sabzazar Society across the road at 100 m. on east side GSO Circle-II office adjacent to DGS wall. On south side 20 ft. road adjacent to DGS then settlements of Ravi Block, Allama Iqbal Town. On west side S.E., 2nd Circle, LESCO Office, then 10 ft. street.

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132 Garden Town sub project:

The SP proposes an Increase in Transformer Capacity of the Garden Town DGS, by replacing an existing 26MVA transformer by a 40MVA 132/11kV power transformer. Access to DGS is located on main Ferozepur Road. Many private schools for girls and boys, Cadet School for Boys and Superior College and Computer College at 800 m. Barkat Market at 2 km, Paktel Office, KFC restaurant at 2 km, canal at 3 km. Access to DGS, Main Ferozepur Road, Rasheed Hospital, and commercial area, Daewoo Bus Station across the road at 20 m, Shopping Plaza under construction, Rashid Latif Hospital at 500m. on North 10 ft street along the DGS, On East side of DGS College of Physical Education and offices of Sports Board and WAPDA PSO Petrol Pump, PCSIR Laboratory. On south side College of Physical Education and staff quarters of Qaddafi Stadium. On west side 10 ft. street, commercial area and houses.

132kV Grid Station Fateh Garh

The SP proposes an increase of transformer capacity of the 132kV Fateh Garh DGS by replacing of a 20/26MVA transformer by 40MVA 132/11kV transformer, with allied equipment. Nearest settlement of DGS is Fateh Garh. Water table in DGS is at 80-85ft There is a tube well in DGS. The total land of DGS is 7.5 acre. On north side adjacent to DGS is Grid colony and abadi but with separate wall. On east side adjacent to grid wall is special education school then abadi. On south side is located access to DGS at canal road. On west side Fateh Garh abadi with independent wall.

132kV Grid Station Old Kot Lakhpat

The SP proposes an increase in transformer capacity of the Old Kot Lakhpat DGS by replacement of a 20/26MVAT3 transformer by a 40MVA 132/11kV transformer, with allied equipment. Main Ferozepur Road, under the flyover bridge over railway line. Beacon House School across bridge (150 m), Govt.Primary and High School for Boys & Girls (1km). Children Hospital at 500 m, Nawaz Sharif Hospital at 500 m. River Ravi at 25 km. Lahore Canal at 5 km. Pakistan Electron Limited (PEL) factory for AC, deep freezers, refrigerators, etc., railway line at 10 m. On North side of DGS 5m road along DGS, Railway Line at 10 m. On East side Flyover Bridge and Kot Lakhpat green grocery wholesale market across the bridge at 250m Kot Lakhpat settlements, wastewater drain at 1 km. On south side PEL Factory. On west Graveyard.

132Kv Grid Station Rehman Park

The SP proposes an increase in transformer capacity of the Rehman Park DGS by replacement of a 20/26MVAT3transformer by a 40MVA 132/11kV transformer, with allied equipment. Access to the DGS is from PEPSI Road, Industrial Area, Gulberg. School: Many private schools (1-2 km), Govt. School 300m, Govt. Girls High School at 300m. Gulberg Middle School in Millat Colony. Al Kauser mosque with religious school (25 m), Ghausia Mos que 70 m. Open trunk drain (50m), Lahore canal 8km. On north side Houses adjacent to wall Rehman Park, Basti Allahoo 30m. on east side Katchi Abadi (slum area) adjacent to wall, road to railway line, Cavalry Ground. On south side Rehman park houses

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adjacent to wall. On west side PEPSI Road, Rehman Park across the road, Millat Colony (30m).

132 kV Grid Station Shadman

The SP proposes an Increase in Transformer Capacity of the Shadman DGS, by replacing an existing 26MVA T2 transformer by a 40 MVA 132/11kV power transformer. , Crescent Model School, Sethi Academy, Government Ichhra School for Boys and one for Girls, Qaumi Foundation Education, Educator, Yousaf Academy, Services Hospital, Punjab Institute of Cardiology, Mental Hospital and many private clinics and hospitals are located at 1-3 km. from DGS. Colleges: Fatima Memorial Hospital and Medical College, Computer College, Kinnaird College for Women, Lahore College University, and many other colleges. On North side of DGS Shadman Link Road, Sewage Drain, Crescent Model School. On east and south sides G.O.R. Road and GOR residences. On west side Access to DGS GOR road.

132kVGrid Station Bhati Gate GIS

The SP proposes an increase of transformer capacity of the 132kV Bhati Gate GIS by replacing of a 20/26MVAT2 transformer by a 40MVA 132/11kV transformer, with allied equipment. Nearest settlement is Bhati Gate Abadi, Balal Ganj Abadi and etc. Water table in DGS is at 100-150ft and WASA water supply. On north side there is 10 ft street and a park Badshahi Mosque at 2km. On east side covered drain and Bhati Gate Abadi across the Grid. On south side park Jamia Masjid Qaba at 50m. On west side access to DGS on Darbar Road and Abadi across the road, Peir Maki Shrine and Data Darbar Shrine at 300m.132Kv Grid Station Qartaba:

The SP proposes an Increase in Transformer Capacity of the Qartaba DGS, by replacing an existing 26MVAT2transformer by a 40MVA 132/11kV power transformer. Access to DGS is located at Bahawalpur Road on south side of DGS. Many private Primary and High schools for Girls and Boys at 2 km including Adabistan-e-Soophia at 200 m to 2 km. Lahore College, APWA College, Kinnaird College at 3 km. Many clinics and private hospitals at 200 m to 5 km, Service Hospital, Umar Hospital, Institute of Cardiology at 3 km. Graveyard adjacent to DGS wall on east side. River Ravi and Canal at 5 km. Potable water is available. On North side GOR Service Road, GOR, Residences across the road. On east side Janazgah Graveyard, CNG Petrol Pump, houses along the DGS wall and across the road. On south side GOR Service Road, houses across the road, Bahawalpur Road and DGS access. On west side GOR Service Road, houses across the road.132KV Manga Mandi:

The SP proposes an increase of transformer capacity of the 132kv Manga Mandi DGS by replacing 20/26MVA transformer by a 40MVA 132/11kV transformer, with allied equipment. DGS is located at Mauza Manga Mandi. The nearest settlement of the DGS is Kalewala Khoh. Water table of DGS is at 17m, hand pump bored at 33 to 50m but water is heavy and hard. There is also a tubewell in DGS bored at 117m with drinkable and sweet water. Total land of DGS is 8 acre. On north side of DGS 7 m road bearing a factory, checkpost of petrol police and 4-132KV double circuit lines from Chak 65, WAPDA town, Sarfraz Nagar. On east side cultivated land adjacent to DGS. On south side of DGS there are

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open plots of garden and nursery 132KV line fro Sarfraz Nagar. On west side access to DGS on Multan road and cultivated land across the road.132kVGrid WAPDA Town:

The SP proposes an Increase in Transformer Capacity of the WAPDA Town DGS, by replacing an existing 26MVA T3 transformer by a 40 MVA 132/11kV power transformer. The DGS is located in,J1block of WAPDA Town There are Primary and High schools for boys and girls and Wapda P.G.G High school at 1 km. There are many private clinics, Shaukat Khanum Cancer Hospital and Jinnah Hospital are at2and 3km from DGS Potable water is available. On North side of DGS is access to DGS on east and south and west sides are roads residences across the road

132 kV badami Bagh:

The SP proposes an Increase in Transformer Capacity of the Badami Bagh DGS, by replacing an existing 26MVA T2 transformer by a 40 MVA 132/11kV power transformer..Potable water is available.in the DGS. Medical facilities are available at 3-5km On North and west sides of DGS is Mughal Steel adjacent to DGS with separate wall. On east side access to the DGS on Noor road.Ilam Din and sons On south side furnace Malik Enginneers and residences adjacent to DGS wall.

132kV Grid Allama Iqbal Town:

The SP proposes an Increase in Transformer Capacity of the Allama Iqbal Town DGS, by replacing an existing 26MVA T3 transformer by a 40 MVA 132/11kV power transformer.. On North side of DGS is Abadi College Block, adjacent to DGS wall there are Primary and High School for Boys & Girls at 500m. many private schools Science College and colleges 500m -1-kmMany private clinics and Frooq hospital ,Sheikh Zaid hospital Govt. Social Security Hospital 1 km. Mansura Hospital at 2km On east side is access to DGS on Wahdat road and comprehensive school for girls across the road, on south side College Block, and, on west side open ground Nearest habitation is College Block, Iqbal Town 200m.

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3. DESCRIPTION OF THE ENVIRONMENT

3.1 Sub-project Project AreasThe proposed sub-projects are spread out over most of Lahore district, both in the main Lahore city, as well as in the fringe areas of Lahore, For this reason, the general characteristics of the area of location of all the sites are basically similar for groups of sites. Thus the DGS located in central or urban areas have similar settings, while those in suburban and rural areas share more or less a common setting, which is typical of central Punjab region.

Most DGS are mostly in Tehsils and Districts of Lahore, Province of Punjab and no subproject is located in the adjoining Administrative units of Kasur, Okara and Sheikhupura Districts.

3.2 Topography, Geography, Geology, and SoilsLahore District is located between the central up-lands and alluvial lands of Ravi, having no hills or mountains of any kind. Ravi flows in the West of District along its boundary with Sheikhupura District. The general height of the area is 150-200m above sea level. The only minerals of value are Kallar and Kankar. They are used to manufacture crude saltpeter, and also as manure for top dressing of young cotton and tobacco plants. The soil is very different in character and generally inclined to be dry. However, it is rich in plant nutrients. No impact is expected on local soils and topography.

3.3 Climate and Hydrology There is negligible variation of altitude above sea level in the area over which the selected DGS are situated, which means no variation between the climates of the various sub-project areas. The climate in general is typical of that of the central Punjab.

The maximum temperature in summer reaches 45oC. In winter the minimum is 1oC. The mean maximum and minimum temperatures in summer are 41oC and 27oC; and in winter 19oC and 4oC respectively. The summer season starts from April and continues till October. May, June and July are the hottest months. The winter season on the other hand starts from November and continues till March, December, January and February are the coldest months.

The rainy season starts in July and ends in September. Annual rainfall is 628.7 mm. More rains occur in July and August than any other months. Most of the winter rains are received in the months of January, February and March.

3.4 Groundwater and Water SupplyIrrigation is largely dependent on the canals, but tube wells have also been sunk in the areas where water is fit for irrigation. The chemical quality of ground water in the district varies area wise and depth wise. Potable water is available in a belt five to twenty miles wide paralleling the river Ravi. In most agricultural areas, irrigation supplies are perennial, but tube wells have also been installed to make up the deficiencies. The water table is not seasonal, and dug wells do not generally run dry. There should be no impact on these sources of water by the construction of the GSS.

3.5 Surface waterRivers and Tributaries

The Ravi is the only river which flows through the district. It enters the district from Amritsar, by the village of Ichogil after a course of 55km leaves it on the borders of Kasur district. The Ravi is the smallest of the five rivers of the Punjab. After construction of the Bari Doab Canal, most of its flows are diverted. However In rainy season, it can have heavy floods. There are ferry services at Khudpur, Chung and Kariolwar.

Lakes and wetlands

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There are no lakes or marshes in the district. The only permanent body of water is the Hudyara Rohi (Nullah) which enters the district from Amritsar District (India) near the villages of Moujoki and Padhana, and the Lahore Branch canal (which flows through Lahore city). The Hudyara nallah runs parallel to Ravi and falls into the same near village Khudpur in Lahore district. During the monsoon season a huge volume of water comes down the Rohi and very often spills over its banks, causing loss to crops and other properties. The Lahore canal off-takes from the BRBD canal, supplying water to many minor canals on its way, and commands farms in the south of Lahore.

Surface drains

In addition there are 76 minor drains (collecting drains) which connect eight major drains namely Satto Kattla drain, Mian Mir drain, Lakshami drain, Sukh Nehar drain, Upper Chotta Ravi drain, Lower Chotta Ravi drain, Siddique Pura drain and Shahdara drain which ultimately connect into the river Ravi.

3.6 Air QualityThe project area is typical of Lahore with respect to air quality and there are some major sources of air pollution like industries or urban traffic, domestic sources such as burning of wood and kerosene stoves, etc. or fugitive sources such as burning of solid wastes.

The other major source of air pollution is dust arising from construction and other ground or soil disturbance, during dry weather, and from movement of vehicles on poorly surfaced or damaged access roads. It has been observed that dust levels from vehicles on existing roads may occasionally even be high enough to obscure vision temporarily.

Air quality in the subproject areas appeared very good during the study period. It should be possible to control and mange emissions from project activities at source, under the EMP. There will be a few items of powered mechanical equipment to be used in the construction of the GSS works, which may give rise to complaints of dust and other emissions; however these should be minor and easily dissipated. The project area is distant from major sources of air pollution like industries , domestic sources such as burning of wood and kerosene stoves, etc. or fugitive sources such as burning of solid wastes. Air quality in the project area appeared very good during the study period . Air quality measurements in major urban centers , carried out by Pak-EPA , revealed that CO, SO2 and NO levels were in excess of the acceptable levels in some areas but the average levels were found below WHO standards . Air quality testing by DISCOs (average values are : TSP 1.09 mg/m3 , CO 634 ppb , SO2 24.34 ppb, NO2 23.73 ppb )through various consultants has reveled that most sub stations have NO2, CO2 and CO values below international standards although TSP levels at some locations was higher than international standards .

There should be no significant source of atmospheric pollution from the subprojects. In the operational phase other nearby industrial facilities with fuel powered mechanical equipment will be the main polluters. All such emissions will be very well dissipated in the open terrain and there will be no cumulative effect from the project.

3.7 Noise and Vibration Noise from vehicles and other powered mechanical equipment is intermittent. There are also the occasional calls to prayer from the PA systems at the local mosques but there are no significant disturbances to the typical urban setting. However the construction from the proposed power expansion will use powered mechanical equipment. Subjective observations were made of background noise and also of individual vehicle pass by events typical of an urban setting. DISCOs have carried out noise level measurements at various sub stations and transmission line locations within the system .These analyzed to calculate Leq values have resulted in Leq values much below the 85 dBA limit prescribed under the NEQs established by the EPA or the 75 dBA used by DISCOs/NTDC/PEPCO in the

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equipment specifications . Typical values were : average 46.21 dBA ; high 63.14 dBA ; and low 34.35 dBA .

There are no national noise standards in Pakistan for power transmission noise that would apply in the operational stages. A criterion of 70dB(A)Leq (exterior, boundary of DGS) has been used for assessment in previous IEE studies.

Noise from construction of the improvements to substations is not covered under any regulations, however, in order to keep in line with best international practice it is recommended that no construction should be allowed during night time (9 PM to 6 AM) and 70dB(A)Leq should be the criterion at other times during the day measured at the boundaries of land from which construction noise is emitted.

Noise and vibration from compaction during construction of foundations may be a significant local impact, but there are no habitations so close to the works that they would be expected to be affected significantly.

3.8 Ecological Resources

Wildlife, Fisheries and Aquatic Biology

There is little wild life in this district, especially in urban areas. Mammals found occasionally include jackals, foxes, porcupines and mongoose, etc, and smaller animals and rodents like squirrels, rats, mice and bats. Reptiles and amphibians include many kinds of lizards, geckos, and snakes, frogs, toads, and turtles, etc. Common species of birds found in the district include the common house sparrow, crow, pigeon, dove, yellow and white eyed myenas, weaver bird, parrot, quail, humming bird, babblers, bulbul, the Indian roller, Indian robin, common kite, herons and egrets, etc, as well as some water birds like pintail, mallard, and teal etc, and seasonal visitors like swallows, bee eaters, quails and starlings etc. Aquatic life in the Ravi River, the Lahore Branch canal, and the drains, is now almost extinct. However, some local fishing takes place in the area.

The project area, which is not dry, is dominated by urban suburbs with occasional productive fields of grains, vegetables and fodder. Common floral species with rooted vegetation are also present in most of the water bodies of the area.

Vegetation cover and trees

Flora of the Lahore district has been greatly modified by human interventions. Few of the old open forests of small trees and shrubs now remain in Rakhs or portions of forests which are kept as grazing grounds for cattle etc.

There is wild growth of mesquite bushes and some eucalyptus trees in the areas near the works but natural forest cover in the district has been significantly reduced in the past. Some of the older stands of trees, especially fruit trees, still survive the onslaught of urbanization on this previously natural and agricultural area. Many large specimen trees of the Mughal and British periods have been destroyed in the wake of intensive urbanization.

Many DGS have some landscaping and ornamental plantations. Typically, land adjacent to substations is populated urban area, or vacant lots awaiting development. The extension works will be carried out in vacant areas allocated for the purpose in the yards of the DGS, which are normally covered with cobbles and stones. Augmentation will take place by replacing a transformer on the existing foundation. No impact on vegetation is therefore envisaged.

Protected and Religious Trees

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There are no protected or religious trees in the SP sites. The works, however, must deal with any trees that need to be lopped or removed for safety reasons, with the necessary permissions.

Protected areas / National sanctuaries

In Pakistan there are several areas of land devoted to the preservation of biodiversity through the dedication of national parks and wildlife sanctuaries. There are no protected areas near the DSS sites.

3.9 Economic Development Agriculture, Industries, and Tourism

After the separation of the Kasur and Chunian areas, the agrarian profile of Lahore district has changed altogether. It is now more industrial than before. Cash crops include tobacco, mutter (peas) wheat and sesame. It has been observed that wheat crop is producing more yield with smaller area in the district than in many other districts due to suitable soil conditions.

Vegetables are grown in abundance as the water and soils are suitable for cultivation, and include potato, carrot, lady finger, chili, onion, bitter gourd, cucumbers, coriander and cauliflowers. Fruits grown include; citrus, guava, mango, watermelons, banana and peach.

Lahore is the biggest trade centre in Punjab which exports and imports a sizable quantity of different types of goods. Its major industrial items of trade include electrical fans, motors, transformers and electrical goods, rubber and its products, bicycles and auto cycles, food products, beverages, body buildings, handicrafts, leather shoes, printing and publishing chemicals, photo goods and cinema films, as well as agriculture products and dry fruits.

After Karachi, Lahore is the biggest industrial area in Pakistan. There has been a steady expansion of industries in and around Lahore since independence. Industrial consumers are causing the greatest demand for electricity, and are also worst affected by power shut downs.

There are thousands of industrial and commercial businesses in the vicinity of the Tranche 2 extension and augmentation sub-projects reliant on the efficient distribution of electrical power. There are also agricultural businesses on the fringes of the urban areas and tourism is also an important business in Lahore.

Transportation

Lahore is linked with the rest of the country by air, rail and road. It lies on the Ground Trunk road or the Shahrah-e-Azam, which connects Kabul with Calcutta. The road was originally built by the Afghan ruler Sher Shah Suri in the 16th century.

There is a complete network of roads in the district. All major villages are connected with the district headquarters through highways. The first four lanes Motorway was constructed from Lahore to Islamabad. It also provides modern facilities to the passengers at international standards.

The main Karachi-Peshawar railway line passes through the district. It enters Lahore from the south near Raiwind and passing through Shahdara in the north leaves for Gujranwala. From Lahore Railway Station, a railway line goes up to Wahga at Pakistan-India border and then across the border to Amritsar in India.

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For air traffic, there is a modern International airport at Lahore. PIA and other air companies operate regular flights from Lahore other parts of the country as well as on international routes.

There are many places of interest that attract tourists and promote tourism e.g. Royal Fort Lahore, Shalimar Garden, Minar-e-Pakistan, Lahore Zoo, Badshahi Mosque, Wazeer Khan Mosque, Golden Mosque, Shrine of Data Hazrat Data Ali Havery, Shrine of Miran Shah, Anarkali Bazar, walled city, Jallo Park, Alhamra Art Center, Shakir Ali Museum, Tomb of Allama Iqbal, Town Hall, Chouburji and the Zamzama, etc.

The number of vehicles, notably private cars, has increased dramatically over the last few years, resulting in all kinds of environmental problems. Traffic load has far exceeded the carrying capacity of roads in Lahore city, as well as in adjoining smaller towns. Valiant efforts are being made to cope with the situation by widening existing roads, and constructing new roads, with a further series of impacts on the environment, and with little overall result.

Energy Sources

Reserves of fossil fuels the main sources of energy in Pakistan and other sources include hydropower. In the study area there is no major source of electricity generation. In the urban areas, the main sources of energy are electricity, piped and bottled natural gas, and fire wood. The sourcing of fire wood and other biomass (especially in suburban and rural fringe areas) is concentrated on home garden production of fuel wood and the extraction of wood from forests, woodlands, crop plantations and agricultural residues. The other significant energy sources in the area are kerosene and LPG. There are numerous petrol stations, and LPG and CNG dealers in the district.

The transmission lines for electrical power in the LESCO run in a complex grid with numerous local sub-stations (Figures 2.1 and 2.2).

3.10 Social and Cultural Resources

Population Communities and Employment

The total population of Lahore, Okara, and Kasur districts was 6,318,745 ,2,232,992,and2,375,875 persons , respectively , as enumerated in March, 1998. According to the 1998 Census, the population is predominantly Muslim, i.e. 93.9 , 98.0 and 95 0%. The next higher percentage is of Christians with 5.8,1,9 and 4%, followed by Ahmadis 0.2, 0.1and 0.1%. While other minorities like Hindu (Jati), Scheduled Castes etc. are very small in number. Punjabi is the predominant language being spoken in the districts, representing 86.2 and 88% of the population, followed by Urdu, Pushto and Siraiki spoken by 10.2, 6 1.9 ,7and 0.4 %. Sindhi is spoken by 0.1%.

Of the total economically active population 98.9 and 96% , rural and urban population ,were registered as employed in 1998. Nearly 52.6 and 73 % were self employed, 27.1and16 % private employees and 14.4 and 5% government employees. Un-paid family helpers were recorded as 1.1 and 4%. In 1998 of the total employed persons, 44.7 % had elementary occupations, followed by service workers and shop and market sales workers, 17.5 %, and professional, 9.2 %. In rural areas people having elementary occupations were again in majority, followed by skilled agricultural and fishery works and service workers and shop and market sales workers, represented 52.5, 23.7 and 8.4 % respectively.

The main occupation of women in rural areas of subproject area is house-keeping which includes attending to the cattle, extracting butter and ghee from milk, weaving and sewing of family clothes. In addition they generally help their men-folk on farms with the lighter

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duties like transplanting of seedlings, threshing and winnowing of grains and some times they also help in harvesting. In city women are house-wives or work as professional’s doctors, nurses, teaching and in offices.

There are many important cultural or archeological sites in Lahore as mentioned above, but no cultural and archeological site is located near any of the subprojects.

3.11 Education and Literacy

The literacy ratio in the district has increased from 48.4 19% in 1981 to 47.7 36% in 1998. The literacy ratio for males is 69.1,48 % as against 59.7,23 % for females.

Lahore is a first class seat of learning in Pakistan. The world famous and the oldest university of Pakistan i.e. University of the Punjab is located in this city. The pioneering University of Engineering and Technology is also in Lahore. There has been a significant development in the educational sector of this district. University of the Punjab has been extended and its new campus is constructed along the Lahore branch of Upper Bari Doab canal. There are also a number of government and private schools, colleges and technical institutes.

Main medical colleges in Lahore include the King Edward Medical College, the Allama Iqbal Medical College and the Fatima Jinnah Medical College, as well as several private and chartered medical universities and colleges.

Institute Number EnrolmentSchools

Primary 1257 115000

Middle 155 36000

High 142 90000

High Secondary

(I-XII Classes)5 8099

Degree 12 6943

Mosque Schools 469 13406

Source: Punjab Development Statistics, Bureau of Statistics, Punjab

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Type of InstituteInstitute Enrolment Teaching

Staff

Male Female Male Female Male FemalePrimary 764 571 73,000 40,000 2,492 1,491Middle 139 75 37,000 17,000 1,541 769Secondary 101 35 62,000 24,000 2,088 774Higher Secondary (Class l-Xll) 2 1 2,691 1,774 12 55Intermediate and Degree colleges 5 4 3,636 1,771 150 75

Mosque schools 282 - 6,528 - 419 -Total 1293 686 184,855 84,545 6,702 3,164

3.12 Health Facilities

Good medical and health facilities are available in the Lahore Metropolitan Corporation area and its suburbs. Shaukat Khanum Hospital is a recent addition in the medical care facilities in Lahore for the most dangerous disease in the country i.e. cancer. There are also other hospitals of voluntary organizations which provide health cover to the general public. King Zaid Bin Sultan Hospital is also a very advanced addition in the medical care for Lahore. Among the prominent hospitals are General Hospital, Lady Aitchison Hospital, Lady Wellingdon Hospital, Mayo Hospital, Fatima Jinnah Hospital, Services Hospital, Gulab Devi Hospital, Ganga Ram Hospital, Shalimar Hospital, Combined Military Hospital and Ittefaq Hospital. Besides, a number of private medical practitioners, hakims and homeopathic doctors are also practicing in the city.

The medical facilities available in Okara district are one Divisional Head Quarter Hospital ,two Tehsil Head Hospital at Renala and Haveli,32 dispensaries,89 BHU,6 Mother and Child Health Centers and one Dental Clinic .care. Basic health units ,are located in each affected village In addition to government health facilities there are also private hospitals and clinics which are providing health facilities. No health facilities are closer to 500m to sub project. All these facilities provide 631 beds for patients.

There is a district headquarters hospital in Kasur, besides one tehsil headquarters hospital each at Chunian and Pattoki Tehsils. Over all in district Kasur a number of dispensaries, rural health centre, Basic Health Units, etc. are providing health services to the people of Kasur. There are 4 hospitals with 233 beds, 34 dispensaries with 44 beds, 12 rural health centers with 240 beds, 81 basic health units with 160 beds, 1 T.B. clinic and 9 M.C.H. centers.

Cultural Heritage and Community Structure

There are no official heritage sites or historic, religious or archeologically important sites located in the close vicinity of any subproject works areas. There are no major historic or archaeological features of note, but there a few places of worship within about 500m of many of the proposed works. Some DGS have a mosque within the attached residential colony.

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4. SCREENING POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

4.1 Project Location Impact Assessment and MitigationThe Tranche 2 augmentation sub-projects will involve expansion of facilities within existing sub-stations (DGS) and in most cases the sensitive receivers (SR) are set well back from the power equipment outside the DGS boundaries. In a few cases for some of the augmentation sub-projects there are some sensitive receivers (SR) within a few metres of the DGS boundary walls and the SRs are in the form of residential buildings, some schools and shops in the surrounding villages as presented in Attachment2.

The location and scale of the works are very important in predicting the environmental impacts. This process of impact prediction is the core of the IEE process and it is critical that the recommendations and mitigation measures are carried out according to with reference to the conditions on the ground in the affected areas in the spirit of the environmental assessments process. In this section the potential environmental impacts are reviewed. If impacts are predicted to be significant enough to exceed accepted environmental standards, mitigation is proposed in order to reduce residual impact to acceptable levels and achieve the expected outcomes of the project being implemented. Therefore, it is essential that a proper analysis is carried out during the project planning period. In this regard, the impact prediction plays a vital role as these predictions are used for developing mitigation measures and any alternative options, if appropriate. When the detailed designs are completed the impacts and mitigation measures will need to be further reviewed to take account of how the contracts are set up and in the light of any fine tuning of the sub-projects.

The environmental management plan (Section 5 and EMP matrix Attachment 4) has been compiled based on the available information and shall be reviewed in due course at project inception and through construction in order to feed back and provide updated mitigation requirements for any significant unpredicted impacts. The analysis primarily focuses the key environmental issues likely to arise from sub-project implementation, to prescribe mitigation measures to be integrated in the project design, to design monitoring and evaluation schedules to be implemented during sub-project construction and operation, and to estimate costs required for implementing sub-project mitigation measures. The EMP plan must be reviewed when the sub-projects reach the inception stage by the project management and be approved before any construction activity is initiated, to take account of any subsequent changes and fine tuning of the proposals.

4.2 General Approach to MitigationDuring the preparation for the sub-project construction phase the future contractors must be notified and prepared to co-operate with the executing agency, project management, supervising consultants and local population in the mitigation of impacts. Furthermore the contractor must be primed through bidding stages and the contract documentation to implement the EMP in full and be ready to engage trained environmental management staff to audit the effectiveness and review mitigation measures as the project proceeds. The effective implementation of the EMP will be audited as part of the loan conditions and the executing agency (PEPCO) must be prepared for this. In this regard the LESCO must fulfill the requirements of the law and guidance prepared by FEPA on the environmental aspects of power projects and the recommendations already made for sub-projects in this IEE and under Pakistan’s PEPAct law.

The location of the residences, mosques, temples, schools, hospitals and civic cultural and other heritage sites has been reviewed in Section 3. Few if any of the residences and schools is close enough to sub-projects that there will be potential impacts in the construction stage from disturbance and significant noise and dust. Water is available in the study area and although surplus water may not always be available to suppress dust at many locations in the dry season major dust impacts should not arise form the scale of works envisaged.

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4.3 Prevention of ground contaminationBest international practice includes control measures to contain oily residues. Transformer oil and lubricants that may be released in the operational stage from maintenance and from a catastrophic failure that would result in loss of all transformer oil. Transformer oil is supplied in drums from an imported source and tap tanks are topped up as necessary on site. There are also facilities in some sub-project DGS maintenance yards for recycling (dehydrating) oil for breakers.

The transformers, transformer oil stocks and the transformer oil dehydration machines or are not installed on impervious surfaces. Therefore in order to be in line with best international practice some mitigation measures are required to prevent soil contamination.

The areas upon which the new transformers, transformer oil stocks and the transformer oil dehydration machines located should have an impervious surface with bunds and high enough edges to capture 110% of the total volume of oil that is housed within the bunded area (Attachment 6). Oil and oily residues should therefore be captured at source and maintenance should take place in these dedicated areas away from surface water resources. With such mitigation installed no impacts should arise in sub-projects. A programme to introduce bunding in all substations should be introduced in the medium to long term as the transformers are upgraded (ITC) or replaced as resources permit.

4.4 Cultural Heritage, Temples, Religious Sites, Social InfrastructureThe location of mosques, temples and other cultural and other heritage SR sites with respect to the sub-projects has been reviewed in Section 3. No temples or religious sites are so close to the works in the DGS as to cause a nuisance. There will be sufficient buffer distance between the works and the SR such that no major significant impact would be expected from the works. However provision should be made for public consultation to be undertaken at the implementation stage to ensure no nuisances arise.

The clinic/hospitals are all well separated from the boundary walls of the sub-project DGS and there will be sufficient buffer distance between the works and the SR such that no major significant impact would be expected from the works. However consideration should be made not to construct at night to avoid nuisances.

The location of schools and some residences places them within 10m from the edge of the sub-project DGS boundary wall in many cases. Whereas the scale of the works for Tranche 2 augmentation sub-projects is well within the DGS boundary wall there should be sufficient buffer distance between the works and all the SR such that no significant impacts can be expected from the works, particularly in terms of noise, vibration and dust. However provision should be made for public consultation to be undertaken at the implementation stage to ensure no nuisances arise.

4.5 Potential Environmental Impacts in ConstructionEncroachment, Landscape and Physical DisfigurationThe extent of Tranche 2 augmentation sub-projects is well within the existing DGS boundary wall and therefore no additional encroachment, landscape or impacts associated with physical disfiguration of the urban cityscape or rural landscape are expected from construction.

Potential disfiguration of the landscape can however result from the uncontrolled excavation of raw materials such as rock, gravel and sand from neighboring areas. Extraction of rock based materials is not necessary on these sub-projects and is already banned by the authorities except under license.

Cut and Fill and Waste DisposalThe Tranche 2 augmentation sub-projects should not require any significant cutting and filling but minor excavations and piling may be required in some of the DGS where the new transformers are to be located to create the footings.

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Mitigation measures must focus on the minimization of impacts. If surplus materials arise from the removal of the existing surfaces these can be used elsewhere on the sub-project DGS before sourcing additional soil rock, gravel or sand extraction is considered. The use of this immediately available material will minimize the need for additional rock based materials extraction. The extraction of raw materials should be minimized by the re-use on-site for landscaping of all rock and soil based materials extracted for excavation of foundations etc.

If off-site disposal of surplus materials is necessary this must also be negotiated through local authority approvals prior to the commencement of construction.

Contractual clauses should be included to require each contractor to produce a materials management plan (one month before construction commences) to identify all sources of cement and aggregates and to balance cut and fill. The plan should clearly state the methods to be employed prior to and during the extraction of materials and all the mitigation measures to be employed to mitigate nuisances to local residents. Mitigation measures shall seek to control the impacts at source in the first place. The construction supervising consultant (engineer) shall be responsible to update the cut and fill estimates and create Materials Master Plan to facilitate materials exchange between the different contracts in the Tranche 2 sub-projects to provide an overall balance for materials and minimize impacts on local resources.

4.6 Trees, Ecology and Protected AreasSurveys have been made at all sub-project locations and whereas trees are present in some sub-stations there should not be any need for disturbance of trees in the Tranche 2 extension and augmentation sub-projects.

If for some unforeseen reason Reserved Trees or other trees do need to be removed permission should be obtained from the forest authority after written justification.

A requirement shall be inserted in the contracts that no trees are to be cut in the DGS without the written permission from the Supervising Consultant who may permit the removal of trees if unavoidable on safety and technical engineering grounds after written justification.

4.7 Hydrology, Sedimentation, Soil ErosionThe Tranche 2 augmentation sub-projects are all on flat sites and should only require minor excavations and piling. Therefore there is little potential for the works to have impact on local water resources. There should be no need for erosion control and there should not be any significant runoff from stockpiles.

4.8 Air Pollution from Rock Crushing, Cut, Fill, & AsphaltThe material (cement, sand and aggregate) requirement of a typical 132 kV sub station (about 150 cu m) and a 132 kV transmission tower (4.8 cu m, or 40 bags of cement per tower) are not large. In transmission line construction sand and aggregate are delivered directly to the tower location from the quarry / source, there is no intermediate or bulk storage of these materials .Similarly construction materials for the sub station are stored within the sub station site are scheduled as per the work progress (which is staggered as the buildings which require bulk of the construction materials are built in phases over 6 to 12 months period ) , which means that at any given point in time the amount of construction material stored is not significant .The quantities of construction material required for a typical sub station or transmission tower are not so larger that they potentially represent a traffic hazard , these requirements are time dispersed in case of sub stations and time and space dispersed in case of transmission lines . The contractor will be , however, required to provide a traffic management plan before commencement of work at site .Field observations indicate that ambient air quality is generally acceptable considering the urban and urban fringe environments where the Tranche 2 sub-projects are located. Any local emissions from powered mechanical equipment needed for the construction will to be rapidly dispersed and no impacts are expected.

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Major earthworks are not envisaged but minor excavations and piling will be required in the DGS where the new transformers are to be located and to create the footings and bunds for containment of leaked oily waste. Where earthworks are required they will contribute to increasing dust. However the scale of the works at any one location is not likely to cause excessive dust. Therefore dust control from works at this scale should be easy to achieve at little extra cost. In order to avoid complaints of dust nuisances the following mitigation measures should be carried out as a matter of good housekeeping:

(i) Dust suppression facilities (back pack water sprayer) shall be available where earth and cement works are required.

(ii) Areas of construction (especially where the works are within 20m of the SRs) shall be maintained damp by watering the construction area.

(iii) Construction materials (sand, gravel, and rocks) and spoil materials will be transported trucks covered with tarpaulins.

(iv) Storage piles will be at least 30m downwind of the nearest human settlements.(v) All vehicles (e.g., trucks, equipment, and other vehicles that support construction

works) shall be well maintained and not emit dark or smoky emissions in excess of the limits described in the NEQS.

The need for large stockpiles should be minimized by careful planning of the supply of materials from controlled sources. If large stockpiles (>25m3) are necessary they should be enclosed with side barriers and covered with tarpaulins when not in use and at the end of the working day to enclose dust.

Bitumen will not generally be required. If bituminous compounds are to be applied by hand labor methods and melted in heaters the fuel used shall be kerosene, diesel or gas fuel. Fuel wood shall not be used for heating bitumen; neither should bitumen be used as fuel.

Bitumen drums should be stored in a dedicated area, not scattered around the sub-project and any small accidental spills of bitumen or chemicals should be cleaned up immediately. The waste including the top 2cm of any contaminated soil and disposed of as chemical waste to an approved landfill or approved local authority disposal site.

4.9 Noise, Vibration and BlastingThere will be no requirement for blasting for the Tranche 2 augmentation sub-projects. At this stage the specific methods for installation of transformers with regard to supporting civil works is not known but soft ground is not generally present and piling should not be needed and would not be a preferred method for foundations in vibration sensitive DGS. Therefore noise and vibration should not be an issue during constructions of Tranche 2 extension and augmentation sub-projects.

4.10 Sanitation, Solid Waste Disposal, Communicable Diseases The main issues of concern are uncontrolled disposal of waste by construction workers, unmanaged disposal of solid and liquid wastes into watercourses and natural drains. There should not be any significant amounts of waste from the works and because the works will be under close supervision of the LESCO authority within the DGS these issues can be controlled at source.

In order to maintain proper sanitation around construction sites the workforce will be allowed to use the flush toilet facilities in the sub-station control buildings.

Vectors such as mosquitoes should not be a significant consideration bearing in mind the type and scale of works for the Tranche 2 extension and augmentation sub-projects.

4.11 Potential Environmental Impacts in OperationAir Pollution and Noise from the Enhanced Operations

Based on observations of many different types of transformer at numerous Tranche 2 augmentation sub-project sites, noise and vibration should not be a nuisance to any nearby SRs. Although one transformer will be added for the extension projects the incremental

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addition to noise levels will not cause a significant disturbing effect for the SRs in the vicinity of the sub-projects.

Some switchgear that may be installed may contain SF6. Typically losses of the SF6 gas are very minor in the operational phase but it is noted that all halogenated gases can potentially accrue “greenhouse gas effects” if they are released in significant quantities. However well installed SF6 equipment should not leak significant amounts of gas and in leakage is checked routinely from all such equipment. Six monthly reports are already made in case there is a need for SF6 to be topped up. The maintenance of the equipment should be geared to achieve a gradual reduction in SF6 usage (leakage) which can therefore be monitored to slowly eradicate any such impacts. If SF6 leakage becomes excessive the respective plant will be overhauled to reduce eradicate the leakage.

If there is a suspicion that there has been a leak of sulphur hexafluoride or by products at any substation the immediate substation area should be evacuated, the controlling engineer must be informed, pending investigation by an authorized person. Thus atmospheric environmental impacts from SF6 can be mitigated and are not expected to be significant.

Pollution from Oily Run-off, Fuel Spills and Dangerous GoodsControl measures will be needed for oily residues such as transformer oil and lubricants. Transformer oil is supplied in drums from an imported source and tap tanks are topped up as necessary on site. There are facilities in some sub-project DGS maintenance yards for recycling (dehydrating) oil for breakers. However the areas upon which these recycling facilities are located have no dedicated drainage which can capture run-off. Oily residues and fuel should be captured at source and refueling and maintenance should take place in dedicated areas away from surface water resources. No significant impacts should be allowed to arise in sub-projects. No significant impacts from oily residues such as transformer oil and lubricants are expected to arise in this subproject. However control measures will be needed for oily residues such as transformer oil and lubricants in the case of accidental or unexpected release. Transformer oil is supplied in drums from an imported source and tap tanks are topped up as necessary on site. There are facilities in some subproject DGS maintenance yards for recycling (dehydrating) oil from breakers. However the areas upon which these recycling facilities are located have no dedicated drainage which can capture run-off. Oily residues and fuel and any contaminated soil residues should be captured at source by installing bunds (Attachment 6) and refueling and maintenance should take place in dedicated areas away from surface water resources. Contaminated residues and waste oily residues should be disposed at a site agreed with the local authority . DISCOs are served by the Technical Services Group (TSG) , TSG prepare a detailed routine maintenance schedule for each piece of hardware .TSG also supervise and monitors the implementation of this schedule by Grid System Operation (GSO) .Transformer oil has a long life (typically over 15 years, which depends upon the level of load the transformer serves ) .Oil spills are very rare and are preempted by routine maintenance .TSG and GSO have a written down procedure to deal with oil spills .

If for some reason there are oily releases they should be cleaned up immediately. The waste including the top 2cm of any contaminated soil and disposed of as chemical waste to an approved landfill or approved local authority disposal site. TSG ensure that the maintenance schedule of each piece of hardware is adhered to . DISCOs have also established a safety unit, which among other tasks , investigates all accidents .Frequency of accidents, on average is about 1 per DISCO per year (based on last 4 years record), about 60 % of these are non-fatal .Most accidents occur due to staff and supervision negligence .Detailed report of each accident is prepared .

4.12 EnhancementEnvironmental enhancements are not a major consideration within the numerous Tranche 2 augmentation sub-project sites. However it is noted that it is common practice at many such sites to create some local hard and soft landscaping and successful planting of fruit

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trees and shrubs has been accomplished in many sites. This practice should be encouraged on all sites as far as practicable.

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5. INSTITUTIONAL REQUIREMENTS & ENVIRONMENTAL MANAGEMENT PLAN

In this section, the mitigation measures that are required, for Tranche2 augmentation sub-projects, to reduce residual impact to acceptable levels and achieve the expected outcomes of the project, are discussed. The Environmental Management Plan is based on the type, extent and duration of the identified environmental impacts for Tranche2 augmentation sub-projects. The EMP has been prepared following best practice and by reference to the ADB Environmental Assessment Guidelines 2003.

It is important that the recommendations and mitigation measures are carried out according to the spirit of the environmental assessment process and in line with the guidelines. The EMP matrix is presented as Attachment4. The impact prediction (Section 4) has played a vital role in reconfirming that typical mitigation measures and approaches will achieve the necessary environmental controls based on the feasibility and detailed design assumptions available at this stage.

Prior to implementation and construction of the sub-projects the EMP shall be reviewed by the LESCO and amended after detailed designs are complete. Such a review shall be based on reconfirmation and additional information on the assumptions made at the feasibility stage on positioning, alignment, location scale and expected operating conditions of the sub-projects. For example, in this case if there are any additional transmission lines or extension of the sub-station boundaries to be included, the designs may be amended and then the performance and evaluation schedules to be implemented during project construction and operation can be updated, and costs estimates can be revised. The IEE and EMP should than be revised on a sub-project by sub-project basis.

The IEE and EMP plan must be reviewed by the project management and if approved by the PEPA (if required) before any construction activity is initiated. This is also an ADB requirement in order to take account of any subsequent changes and fine tuning of the proposals. It is recommended that before the works contract is worked out in detail and before pre-qualification of contractors that the full extent of the environmental requirements for the subproject(s) and the IEE and EMP are included in the bidding documents. Past environmental performance of contractors and awareness of environmentally responsible procurement should also be used as indicators for prequalification of contractors.

In order to facilitate the implementation of the EMP, during the preparation for the construction phase the LESCO must prepare the future contractors to co-operate with all LESCO and any stake holders peripheral to the substation in the mitigation of impacts. Furthermore the contractor must be primed through the contract documentation and ready to implement all the mitigation measures. LESCO will need to make provision to recruit, engage retain and replace trained environmental management staff and these staff should audit the effectiveness and review mitigation measures as the sub-projects are rolled out. LESCO will also need to confirm that contractors and their suppliers have complied with all statutory requirements and have appropriate and valid licenses and permits for all powered mechanical equipment and to operate in line with local authority conditions.

The effective implementation of the EMP will be audited as part of the ADB mid term review of loan conditions and the executing agency must prepare for this at the inception stage.

The details of EMP given in the Attachment4 are for the Tranche 2 augmentation sub-projects. The EMP matrix will be different for the more complicated sub-station and line projects that involve impacts to land outside the existing sub-stations and for which separate dedicated IEEs and EMPs have been prepared.

The impacts have been classified into those relevant to the design/preparation stage, construction stage and operation and maintenance stage. The matrix provides details of the mitigation measures recommended for each of the identified impacts, time span of the implementation of mitigation measures, an analysis of the associated costs and the responsibility of the institution. The

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institutional responsibility has been specified for the purpose of the implementation and the supervision. The matrix is supplemented with a monitoring plan for the performance indicators. A tentative estimation of the associated costs for the monitoring is given with the plan. The EMP has been prepared following best practice and the ADB environmental assessment guidelines 2003.

The EMP (Attachment 4) was prepared taking into account the limited capacity of LESCO to conduct environmental assessments of the sub-projects. LESCO has engaged an environmental specialist and a Sociologist (as already in post LESCO). It is expected that a graduate environmental specialist will remain in post for the foreseeable future while the loan is active. However it is also strongly recommended that for sub-projects in future Tranches that the LESCO be prepared to engage more environmental specialists where necessary especially if full scale EIAs are required for some line and substation subprojects (e.g. senior environmental specialist with at least 10 years experience in environmental management five years site experience in environmental monitoring and auditing) to guide the subsequent formal assessment and submission process under the PEPAct and monitor compliance with the EMP. As of August 2007, the LESCO has not yet shown much commitment to developing in-house environmental and social capability.

The newly appointed environmental staff members will need a good level of awareness and will be responsible for addressing environmental concerns for sub-projects potentially involving hundreds kilometers of distribution lines and DGS. Whereas some of their work may in future be delegated to consultants they will need more training and resources if they are effectively provide quality control and oversight for the EMP implementation. They will require robust support from senior management staff members and the management consultant if they are to address all environmental concerns for the sub-projects effectively. Specific areas for immediate attention are to appoint environmental specialist(s) have them experienced or trained in EMP auditing, environmentally responsible procurement, air, water and noise pollution management and ecological impact mitigation. It is recommended that an environmental specialist consultant with 10 years experience be made available to all the DISCOS through the TA attached to the PDEMFF to cover these aspects full time for at least the first six months of the PDEMFF project and that on a call off basis with local support those services are retained for the life of the PDEMFF loan. The newly appointed graduate environmental staff members can than shadow the environmental specialist to improve awareness and hopefully provide independent quality control and oversight for the EMP implementation within 12 months.

In order to achieve good compliance with environmental assessment principles the graduate environmental staff for the project implementation team must be actively involved, prior to the outset of the implementation design stage, to ensure compliance with the statutory obligations under the PEPAct. It is also recommended that LESCO Board allow direct reporting to Board level from the in-house Environmental and Social Unit (ESU). If the ESU requires resources for larger sub-projects then environmental specialist consultants could be appointed through the relevant project implementation unit to address all environmental aspects in the detailed design. It is recommended that the project management unit (PMU) which is functional at present, should liaise directly with the ESU to address all environmental aspects in the detailed design and contracting stages. The graduate environmental staff will cover the implementation of environmental mitigation measures in the project packages.

The graduate environmental staff specialist will:

a. work in the PMU with LESCO to ensure all statutory environmental submissions under PEPAct and other environmentally related legislation are thoroughly implemented;

b. work in the PMU with LESCO to ensure all environmental requirements and mitigation measures from the environmental assessment of sub-projects are included in the contract prequalification and bidding documents;

c. work with LESCO to execute any additional IEE and IEE requirements needed due to fine tuning of the sub-projects and that environmental performance targets are included in the contracts prior to project commencement;

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d. work in the PMU with LESCO to ensure all environmental requirements and mitigation measures from the IEEs and IEEs and environmental performance criteria are incorporated in the sub-project contracts or variations and that the EMP is effectively implemented;

e. work with management (consultants), supervising consultant and contractors to manage and monitor the implementation of the project EMP.

f. work with management to ensure that the Environmental Assessment Review Framework (EARF) is fully applied, adequately resourced and implemented for future Tranches of the PDEMFF.

Overall implementation of the EMP will become LESCO’s responsibility. Other parties to be involved in implementing the EMP are as follows:

Contractors:

Responsible for carrying out the contractual obligations, implementing all EMP measures required to mitigate environmental impacts during construction; and

Other government agencies:

Such as regional PEPA and state pollution authorities, Department of Forests, Department of Wildlife Services, who will be responsible for monitoring the implementation of environmental conditions and compliance with statutory requirements in their respective areas and local land use groups at the local level.

Considering that other government agencies that need to be involved in implementing the EMP, training or harmonization workshops should be conducted for all ESUs in all DISCOS every six months or twice each year, for the first 2 years (and annually thereafter) to share the monitoring report on the implementation of the EMP in each DISCO and to share lessons learned in the implementation and to achieve a consistent approach decide on remedial actions, if unexpected environmental impacts occur.

The monitoring plan (Attachment5) was designed based on the project cycle. During the pre-construction period, the monitoring activities will focus on (i) checking the contractor’s bidding documents, particularly to ensure that all necessary environmental requirements have been included; and (ii) checking that the contract documents’ references to environmental mitigation measures requirements have been incorporated as part of contractor’s assignment and making sure that any advance works are carried out in good time. Where detailed design is required (e.g. for power distribution lines and avoidance of other resources) the inclusion and checking of designs must be carried out. During the construction period, the monitoring activities will focus on ensuring that environmental mitigation measures are implemented, and some performance indicators will be monitored to record the Sub-projects environmental performance and to guide any remedial action to address unexpected impacts. Monitoring activities during project operation will focus on recording environmental performance and proposing remedial actions to address unexpected impacts. The potential to use local community groups contacts for monitoring should be explored as part of the activities in setting up the Environmental and Social Unit which should have regular meetings with the NGOs as a matter of good practice and to discuss matters of mutual concern.

At this stage, due to the modest scale of the new power distribution projects and by generally keeping to non-sensitive and non-critical areas the construction and operational impacts will be manageable. No insurmountable impacts are predicted providing that the EMP is implemented to its full extent and required in the contract documents. However experience suggests that some

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contractors may not be familiar with this approach or may be reluctant to carry out some measures. In order that the contractors are fully aware of the implications of the EMP and to ensure compliance, it is recommended that environmental measures be coasted separately in the tender documentation and that payment milestones are linked to environmental performance, vis a vis the carrying out of the EMP.

The effective implementation of the EMP will be audited as part of the loan conditions and the executing agency must be prepared for this. In this regard the LESCO (the IA) must be prepared to guide the design engineers and contractors on the environmental aspects.

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6. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE

The public consultation (PC) process with various stakeholders for Tranche2has been approached so as to involve public and other stakeholders from the earliest stages. Public consultation has taken place during the planning and design and viewpoints of the stakeholders have been taken into account and their concerns and suggestions for possible improvements have been included where appropriate. Much of the PC process to date has revolved around concerns for the mitigation of construction impacts and the possible side effects from the proximity of high voltage power lines. PC has therefore been conducted for the sub-station and line sub-projects that may incur some impacts over land outside existing sub-stations and that PC is reported in the dedicated IEEs for those sub-projects. There is also ongoing consultation for land acquisition and resettlement (LAR) and the completion of the Resettlement Plan (RP) is documented separately. It is expected that this process will continue through all stages of the sub-projects in order to accommodate stakeholders' aspirations and to orient the stakeholders positively towards the project implementation and where possible to harness co-operation over access issues in order to facilitate timely completion.

The Tranche 2 augmentation sub-projects the whole of each sub-project in design, construction and operational stages is only likely to affect the areas within the DGS premises. There are unlikely to be any significant impacts outside the DGS except for perhaps temporary minor inconveniences to traffic when new transformers are transported to site. Therefore LESCO is the major relevant stakeholder and LESCO are in favor of and support their own sub-project proposals. However some consultation was also conducted with residents and other stakeholders near the LESCO augmentation subprojects and the major concerns of the public, based on consultation at the substation projects, seems to be to get employment in the construction phases.

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7. FINDINGS RECOMMENDATIONS AND CONCLUSIONS

7.1 Findings and Recommendations

This study was carried out at the planning stage of the project. Predominantly secondary data and site reconnaissance were used to assess the environmental impacts. The potential environmental impacts were assessed in a comprehensive manner. The report has provided a picture of all potential environmental impacts associated with the sub-projects, and recommended suitable mitigation measures. This study recommends that some further follow up studies are undertaken during project processing in order to meet the ADB requirements.

There are some further considerations for the planning stages such as obtaining clearance for the project under the Pakistan Environmental Protection Act (1997) but environmental impacts from the Tranche 2 extension and augmentation sub-projects will mostly take place during the construction stage. There are also some waste management issues for the construction and operational stage that must be addressed in the detailed design and through environmentally responsible procurement. At the detailed design stage the number of and exact locations for transformer extensions and augmentations and other enhancements may change subject to detailed surveys but the impacts are likely to be broadly similar at most locations and impacts have been reviewed in the environmental impact section of this IEE report.

The Tranche 2 augmentation sub-projects require a number of key actions in the detailed design phase. Prior to construction the LESCO must disclose the projects to Federal EPA and receive clearance certification from the PEPA. LESCO may need to complete an EMP that will be accepted by the PEPA and agreed by the contractor prior to signing the contract. The information provided in this report can form the basis of any further submission to PEPA as required in future.

The augmentation sub-projects are restricted to the enhancements indicated in this report but further details are required if land is required or for any other improvements along the alignment where land acquisition, resettlement and compensation may need to be considered. Based on the other sub-projects providing further documentation for any new future proposed alignments should not be difficult tasks and this can be conducted as the detailed designs are worked out and to dovetail with the existing system and minimize adverse impacts and maximize benefits. Social impact assessment and due diligence has been completed in tandem with this IEE for relevant sub-projects.

During the commissioning phase waste disposal monitoring should ensure that statutory requirements have been met. Monitoring activities during project operation will focus on periodic recording environmental performance and proposing remedial actions to address any unexpected impacts.

7.2 ConclusionThere are no insurmountable environmental impacts for the Tranche 2 augmentation sub-projects that are feasible and sustainable options from the power distribution, engineering, environmental, and socioeconomic points of view. Implementation of the EMP is required and the environmental impacts associated with the sub-project need to be properly mitigated, and the existing institutional arrangements are available. Additional human and financial resources will be required by the LESCO to complete the designs and incorporate the recommendations effectively and efficiently in the contract documents, which should be linked to payment milestones. The proposed mitigation and management plans are practicable but require additional resources.

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This IEE, including the EMP, should be used as a basis for an environmental compliance program and be included as an Attachment to the contracts. The EMP shall be reviewed at the detailed design stage. In addition, any subsequent conditions issued by Pakistan EPA as part of the environmental clearance should also be included in the environmental compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions for work and environmental clearance, and monitoring of the environmental impact related to the operation of the Tranche 2 augmentation sub-projects should be properly carried out and reported at least twice per year as part of the project performance reports.

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