1. RBOD Project-Environmental Vista
Naseer Memon

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

3. Drainage projects are environmentally sensitive development projects and need careful design & implementation, stringent mitigation measures and effective long term monitoring

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

22. Thank You