shehri Letter to sepa

6. Annexure-1
Dirty electricityARDESHIR COWASJEE
PUBLISHED NOV 28, 2010 12:52AM
WE now know that Karkey Karadeniz Elektrik Uretin (KKEU), a Turkish power company, has
anchored a barge-mounted power station in the Korangi Creek, connecting it to KESC‟s thermal
powerhouse transmission lines to deliver 220MW into the starved electricity network (the powerless
awam expect much from the bijli ka jehaz). At the inauguration ceremony of this furnace oil-
guzzling smoke-belching mini-monster, Raja Pervaiz Ashraf, our „knowledgeable‟ minister for water
and power, informed us that the “ship-borne system is a state-of-the-art power plant to provide
electricity to Karachi”.
He is only partly right: although the barge has been rented for five years by Lakhra Power Generation
Company (GENCO-IV) and its electricity is being „wheeled‟ into the National Transmission and
Dispatch Company (NTDC)/Pepco‟s nationwide system, its output will be utilised by the KESC as a
low-loss part of the 650MW supply to be provided by Wapda. With proper relaying, this output will
remain available to KESC even if the inter-tie to Wapda drops off.
On Nov 24, this newspaper reported that KESC will pay some Rs9/kWh to Wapda/NTDC, with
KKEU‟s sale price to Wapda/NTDC being around Rs16/kWh. In its January 2010 rental power
review report, the Asian Development Bank (ADB) found “the Rental Service Agreements (i) are
weak in their legal structure; (ii) do not balance the risk sharing between the seller and buyer; and
(iii) have many inconsistencies”. It also calculated that KKEU had the highest cost among the 12
furnace-oil rental power plants reviewed.
What Raja Pervaiz Ashraf did not mention was that the barge will horrendously pollute the
habitations, air and sea around Karachi.
In mid-March 2010, my advisor on environmental engineering affairs, Shehri‟s Roland deSouza,
attended a public hearing held by the Sindh Environmental Protection Agency (Sepa) on the
Environmental Impact Assessment (EIA) report submitted by KKEU and emerged sceptical.
This report essentially stated that whatever environmental problems emerged during the operation
would be studied/tackled by KKEU as they occurred. This is unbelievable. If such a procedure is to
be accepted for scrutiny by EIAs, then Sepa‟s NOCs and public hearings are meaningless.
As per Section 9 of the Review of IEE & EIA Regulations 2000, Sepa must conduct a “preliminary
scrutiny” to confirm that the EIA is complete for purposes of initiation of the review. It obviously
was not. Had it been, the agency should have insisted that all environmental issues be assessed in
detail, technical studies and accurate analyses be conducted, and detailed mitigation measures
finalised in advance.
For instance, without engineering studies, KKEU vaguely stated that plant noise would be tackled
with acoustic enclosures only “if the noise levels exceed the National Environmental Quality
Standards (NEQS) guideline values”. An unrealistic figure of 85dB(A) was quoted as the standard,

7. although residential areas (e.g., Ibrahim Hyderi Goth) should not be subjected to more than 45dB(A)
of sound at night.
Further, KKEU loosely promised that seawater temperature-rise thermal-plume modelling of their
once-through cooling-system would be undertaken “in case the temperature difference is found to be
beyond the NEQS”.
The NEQS prohibit the discharge into the sea of any effluent (without regard to concentration of
pollutants or temperature-rise) within 10 miles of the mangroves (in Korangi Creek). ADB reported
in 2006 that the average temperature rise of the sea cooling water at KESC‟s Korangi power-house
was 7Ú°C (exceeding the maximum 3Ú°C allowable). Excessive heat from the KKEU barge will
exacerbate this situation, and further adversely affect marine life and the livelihood of fishermen in
adjacent goths.
No details were provided of the complex treatment/disposal required for the contaminated
wastewater generated from washing the furnace-oil or from other hazardous chemicals. (Polluters in
Pakistan tend to isolate themselves from this process by using sub-contractors who, after bribing
officials, remove contaminated waste for remote dumping.)
With the burning of dirty furnace oil, bereft of de-sulphurisation equipment, increase in air-
pollution is a major concern in the already degraded air shed around the KESC power house.
The coloured contour maps generated by KKEU’s air-dispersion modelling fraudulently show
the prevailing wind as coming from the northwest rather than the southwest.
Thus, the deposition of pollutants from the barge is stated to be over the Korangi Creek rather
than onshore onto the thickly populated areas of Ibrahim Haidery Goth and Korangi
Township.
The EIA report states that the alternative Chinna Creek and Bin Qasim sites were not considered
suitable as habitations existing close to the barge locations would be adversely affected by the power
plant. How then is the Korangi location, with millions of people downwind within a few kilometres,
acceptable?
Myriad other details and mitigation measures that should have been spelled out and examined by
Sepa and the public have not been addressed.
A perusal of the pathetically drafted, conditional NOC issued by Sepa in April makes incredulous
reading. It vaguely and generally states that the project proponent “shall do” this or “shall do” that;
that standards of the World Bank “shall be observed”; that emergency/contingency plans shall be
made; and equally meaningless directions. For example:
“Temperature, TSS and pH of all effluents and gases being released will be controlled through
effective equipment and technologies.” Is it not the function of Sepa and the public hearing to
evaluate and approve the effectiveness of the proposed mitigation measures?
Does the government realise that degradation of the environment at the World Bank-determined rate
of six per cent of GDP is far greater than the three to 3.5 per cent increase in GDP being brought
about by „economic development‟ with dirty electricity? Do they expect the impotent environment
ministry or the corrupt EPAs to rectify this? Are we not on the path to ecological suicide?

8. Annexure-2
Mr. Naeem Ahmed Mughal Shb.
Director General
Environmental Protection Agency
Government of Sindh
SUBJECT: OBSERVATIONS ON LIKELY DAMAGES TO PQA INDUSTRIAL UNITS RESULTING
FROM EMISSIONS FROM PROPOSED COAL YARD AT BERTH 3 & 4 AND COAL
CONVEYOR BELT FROM PIBT THROUGH PQA NORTH WEST INDUSTRIAL ZONE
(NWIZ).
This is to register our disappointment over the complete disregard of our grievances on
the above-mentioned projects, which were forwarded to you vide our following letters:
i) June 1, 2016;
ii) July 14, 2016;
iii) August 15, 2016;
Copies of the above letters are attached herewith.
We are further discouraged by the fact that instead of receiving a response from you,
we find an advertisement to hold public hearing on one of the above projects on
22nd September 2016. The appearance of this advertisement shows that despite of
potentially being highly disastrous to the environment, the projects are being rushed
through in haste, in view of the following:
i) The SEPA regulations require 15 days public review period for each project. The said
15 days period does not include the gazetted holidays like Eid-ul-Azha. Your office
has violated these regulations by publishing the advertisement.
ii) The advertisement does not show that the EIA has been placed on any website.
The EIA document was however not made available from your office on the plea
that the concerned staff has since proceeded on Eid-ul-Azha leave.
iii) We find this practice to be inappropriate and inconsiderate to genuine
stakeholders who have been denied access to information which is crucial for
evaluating the near- and long-term impact of these projects. It is not unusual to
find a few copies of the short summary of the executive summary on demand at
public hearing but this is not enough since it is not a replacement of the main
document; we strongly object to this unusual behavior.
We, Bin Qasim Association of Trade & Industry, reiterate:
1. Our apprehensions on the highly negative impact of emissions particularly coal dust
on the assets of our members at and along the Corridor of Impact (CoI) of
Coal Transshipment – Coal Storage Yard – Conveyor Belt – Railway Line and onward

9. transportation to the hinterland in Punjab through Sindh, and Conveyor Belt from
PIBT through NWIZ to Coal Stockyard and its handling & transportation to inland
destinations.
2. We apprehend that the lesson from the decision of the Honorable Sindh High Court
on KPT Coal Yard has not been learnt. Consequently there are reasons to believe
that coal dust emission from the above mentioned operations are likely to damage
the assets of the industrial units on which there is considerable stake of the local and
international investors.
3. We are constrained to write this letter because the EIA process seems to have been
carried out without due consideration being given to the potential threats that
emission from coal dust poses to the CoI of the two projects as well the air-shed of
macroenvironment that includes the hinterland in Sindh. The process also seems to
have ignored the main issue of coal dust fall and emission during the scoping
session, it at least could not satisfy any of our members.
4. At the request of our members, we appointed a consultant with expertise in EIA and
got a copy of the EIA reports through an engineers’ forum. After careful review, we
found some serious deficiencies in the EIA documents which were not addressed,
such as:
 Alternatives are supposed to be a major part of an EIA as per SEPA guidelines
but the same have been only summarily mentioned. This is a serious omission on
part of the EIA consultants because an obsolete technology that has not been
tried elsewhere is being transferred over to Pakistan. Above ground conveyor
belts of such a large dimensions have not been a success as demonstrated by
the conveyor belt unit installed at the Pakistan Steel Mills.
 Coal Terminal at Berth 3 & 4 and Coal Conveyor Belt through NWIZ were never
part of PQA master plan. As such they seem to have been included as an adhoc
arrangement. All adhoc arrangement have a large foot print on the
environment and social values of the society. As such there desirability and
legality is questionable?
 The EIA document of Coal Transshipment from Berth 3 & 4 has totally ignored the
establishment of Pakistan International Bulk Terminal (PIBT) that is the only coal
terminal designated in the PQA master plan and has the capacity to meet the
requirements of coal handling upto 4  8  20 million tons coal. As such this add
on is undesirable. In our opinion the at berth 3 & 4 should not have been
considered by the consultants and then SEPA to start with. This also shows that
the project is being thrust on the sustainability of the ecosystem of the Coastal
area of Karachi at the cost of development in Punjab.
 The EIA of PIBT approved by SEPA 4-5 years ago had stipulated that the coal
transportation from PIBT to the upcountry destinations in Pakistan would be by
railways for which the railways would be extended upto the PIBT. The coal
terminal at berth 3 & 4 and the 4.5 km long conveyor belt are both marginalizing

10. the PIBT on one hand and negatively impacting the assists along the 4.5 km
route on which there is a considerable stake of members of the BQATI.
 The Proponents concerned have not taken cognizance of the decision of the
Honorable Sindh High Court regarding KPT Coal Yard. The EIA study of the KPT
Coal Yard Project had identified the disasters caused by the operations at the
Coal Terminal during its handling of 7-9lacs tons each day. The residents of the
settlements around the coal terminal as well the workers were not found to have
normal health. The workers were apparently suffering from short breath. The
unhygienic and unhealthy environment had spelled on quality of life since they
were regular visitors of the hospitals and clinic; their expenditure on health had
increased. The sufferers from the impact were compelled to seek justice on this
important environmental health issue and filed a petition for the safeguard of
their life and property. The baseline produced by the consultants is
challengeable. Any decision taken in disregard of the lessons from the KPT issues
is likely to amount to contempt of court and hence would be challenged in the
court of law.
 It is also a matter of concern that coal is being dumped at marginal wharves 3 &
4 without any environmental control measures and without waiting for the
decision of SEPA on the EIA.
 The EIA should have included an environmental audit of the existing site of berth
3 and 4 to quantify the damages done to the environment from the existing coal
handling operations at berths 3 and 4 that is still going on without SEPA approval.
 There are number of sensitive units around berth 3 & 4 and along the 4.5 km long
conveyor belt; all of them maintain air condition units and suck ambient air into
their system. it may be pointed out that the ambient air of the air-shed is already
in the state of saturation with regard to the primary pollutants particularly
particulate matter. Exceeding the limit of saturation will be at the cost of the
processing units which need to be free of any amount and size of dust.
 Names of some of BQATI office bearers and members have been used in a
manner implying they were taken onboard, whereas no response was offered to
their grievances. Our members have complained about this omission and have
suggested that there observations must be included in the environmental
assessment. We therefore strongly suggest that the EIA process should be
repeated giving due cognizance to the observations of our members. The EIA
process cannot be carried out without addressing concerns of all industrial units
and residential areas within the corridor of impact and quantifying the impact of
coal dust emission on each unit. It is pertinent to note that there are a number of
environmentally sensitive units operating along the corridor; such as Food
Processing Units, Pharmaceutical and Chemical Units, Water Purification Units,
Edible and Crude Oil Refineries, Automobile manufacturers and Petrochemicals.

11.  In our earlier submissions we had requested due consideration to be given to the
problems emanating from wind erosion and loss of fine particles of coal dust
from: i) the Corridor of Impact (CoI) of Coal Transshipment – Coal Storage Yard –
Conveyor Belt – Railway Line and onward transportation to the hinterland in
Punjab through Sindh, and ii) Conveyor Belt from PIBT through NWIZ to Coal
Stockyard and its handling & transportation to inland destinations, however the
EIA Consultant has failed to quantify the total loss in tons and magnitude of dust
fall on each and every industrial unit along the route.
 The slope of ground is towards the sea, the leachate and the percolations from
the heaps in the coal yard will flow towards the sea shore. In the absence of
compact surface the surface of the yard is likely to be rendered more saline than
at present & therefore the already saline ground water will be contaminated
further with leachates. The EIA consultant should have estimated if not quantified
the impact in the EIA through an environmental audit.
 The EIA should have assessed the cumulative impact of all the coal related
projects which have been approved by SEPA to estimate the impact of coal
handling on such large scale in PQA. The air-shed will be converted into polluted
category after the berth 3&4 coal terminal and coal conveyor belt projects.
 Sindh EPA should also take cognizance that the Coal Yard being planned at
Berth 3 & 4 and the 4.5 km long conveyor belt is not included in the PQA master
plan per se; this necessitates a Strategic Environmental Assessment (SEA)
including environmental impact assessment by a competent environmental
consultant.
We hope that you will finally appreciate the gravity of the observations cited above as
they are likely to have serious negative impact if not recognized at the outset.
We, the members of BQATI, therefore earnestly stress the rejection of the EIA documents
in the present form.
With Regards,
Abdur Rehman Ismail
Secretary General, BQATI