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E752 vol. 6 Revised Final Report May 30, 2003 Pakistan Highway Rehabilitation Project Resurfacing and Strengthening Projects, Phase I Environmental Management Plan ri~~~~~~ni Iran Balochistan - i StJ 18 M7,t' f C ~~~~~~India r * \ g? ~~~~~~~~Slndh (t National Highway Authority, Pakistan 1L C Q Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

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Page 1: Environmental Management Plan - Documents & Reportsdocuments.worldbank.org/curated/en/502761468286828782/pdf/multi0... · Environmental Management Plan ... Estimated Cost of Environmental

E752 vol. 6Revised

Final ReportMay 30, 2003

Pakistan Highway Rehabilitation ProjectResurfacing and Strengthening Projects, Phase I

EnvironmentalManagement Plan

ri~~~~~~niIran Balochistan - iStJ 18 M7,t' f C ~~~~~~India

r * \ g? ~~~~~~~~Slndh (t

National Highway Authority, Pakistan 1L C QPVn

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EMPfor PHRP Resurfacing and Strengthening Projects

Contents

1. Introduction ...... ..................... 1-11.1 Project Background ................................................ 1-11.2 Objectives of Environmental Management Plan . ........................ 1-31.3 Key Environmental and Social Components . ........................... 1-31.4 Regulatory Requirements and Applicable Standards . .................... 1-3

1.4.1 National Regulatory Requirements ............................................... 1-31.4.2 Environmental Standards .................. ............................. 1-41.4.3 Status of Regulatory Clearances ............................................... 1-5

2. Implementation and Supervision Plan . . ....................................... 2-12.1 Institutional Structure and Implementation . ............................ 2-1

2.1.1 Federal Structure ............................................... 2-12.1.2 Regional Structure ............................................... 2-12.1.3 Field Structure ............................................... 2-2

2.2 Specific Implementation Responsibilities .............................................. 2-22.2.1 Design Phase ............................................... 2-22.2.2 Construction Phase ............................................... 2-22.2.3 Operation Phase ............................................... 2-3

2.3 Role of Functionaries ............................................... 2-32.3.1 Project Coordinators ............................................... 2-32.3.2 Supervision Consultant ............... ................................ 2-3

3. Impact Assessment and Mitigation Plan . ..................................... 3-13.1 Environmental Baseline ............................................ 3-13.2 Corridor of Impact ................................................ 3-23.3 Overview of Impact Assessment ..................................... 3-2

3.3.1 Procurement of Borrow Material ............................................... 3-23.3.2 Location and Operation of Project Facilities ............................ ......... 3-33.3.3 Impact on Existing Avenue Plantation .............................................. 3-33.3.4 Obstruction of Corridor Drainage System ......................................... 3-33.3.5 Impact on Cultural and Community-Owned Assets .............. ............ 3-33.3.6 Impact on Pedestrian and Traffic Safety ........................................... 3-4

3.4 Mitigation Plan ................................................ 3-43.4.1 Design Phase ............................................... 3-43.4.2 Construction Phase ............................................... 3-6

05130/03 Contents

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3.4.3 Operation Phase .................................................... 3-9

4. Environmental Monitoring Plan . . ........................................... 4-14.1 Objectives .................................................... 4-14.2 Monitoring Roles and Responsibilities . .................................................. 4-1

4.2.1 Internal Monitoring ................ .................................... 4-14.2.2 Independent Environmental Monitoring ............................................ 4-34.2.3 Independent Social/Participatory Monitoring .................................... 4-3

4.3 Grievance Redressal System ...................... .............................. 4-34.4 Monitoring Parameters ..................................................... 4-4

4.4.1 Environmental Monitoring Parameters ............................................. 4-44.4.2 Social Monitoring Parameters .................................................... 4-4

4.5 Reporting Structure and Outcomes ................................... 4-44.6 Proposed Monitoring Budget ........................................ 4-5

5. Environmental Technical Assistance and Training Plan ............ 5-15.1 Environmental Training Program .................................................... 5-15.2 Social Training Program ..................................................... 5-1

6. Estimated Cost of Environmental Management .......................... 6-1

Appendices

Appendix A: Environmental Monitoring Parameters

Appendix B: Terms of Reference for Key NHA Staff

05130/03 Contents

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Exhibits

Exhibit 1.1: Sections Proposed for RSP Under Phase I ................................ .............. 1-1Exhibit 1.2: Project Corridor: Sections Proposed for RSP ........................................... 1-2Exhibit 3.1: Indicative Avenue Plantation Program .................................................... 3-9Exhibit 4.1: Environmental Monitoring Plan ........................................................ 4-6Exhibit 5;1: Personnel Training Program/TA Services ..................................... .......... 5-2Exhibit 6.1: Cost Estimates for Environmental Management of RSP, Phase I ........... 6-1

05/30/03 Exhibits111

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EMPfor PHRP Resurfacing and Strengthening Projects

1. Introduction

This document provides an overall approach for managing and monitoring environment-relatedissues and describes the institutional framework and resource allocations proposed by theNational Highway Authority (NHA) to implement the environrnental management plan (EMP)for resurfacing and strengthening (RSP) projects. The EMP accompanies the environmentalimpact assessment (EIA) carried out for the RSP works proposed under Phase I of the project.

1.1 Project BackgroundThe Government of Pakistan (GoP) is presently implementing the National HighwaysImprovement Program (NHIP) to address the increasing degradation of Pakistan's nationalhighway system. The World Bank will support the GoP's program by financing a distinctsegment of NHIP works under the multi-phased Pakistan Highway Rehabilitation Project(PHRP), sustaining essential reforms in the sector, as well as strengthening the capacity of theproject proponent, ie, the NHA. The development objective of the project is the sustainabledelivery of a productive and efficient national highway system contributing to lowertransportation costs.

Under Phase I of the PHRP, selected stretches along two sections of the N5 highway corridor willbe upgraded under resurfacing and strengthening projects (see Exhibit 1.1), ie, Gujranwala-Kharian, and Nowshera-Peshawar. The scope of this EMP covers the resurfacing andstrengthening of about 174 km of road altogether, which will be upgraded under four contractpackages. Following the contract award, the project phase will span a construction period ofbetween 15-20 months, and a post-construction defect liability period of 12 months.

Exhibit 1.1: Sections Proposed for RSP Under Phase I

ContractPackage Stretch to beNo. Section ContractPackage Upgraded Under

RSP (km)

1. Gujranwala-Kharan (ACW/NB) 12A 30Gujranwala-Kharian (ACW/NB) 12C 27

Gujranwala-Kharian (ECW/SB) 12D 492. Nowshera-Peshawar (ECW/ACW SB+NB) 14 68

Total 174Note:ECW: ExistUng (original) carriageway SB: SouthboundACW: Additional caniageway (constructed after ECW) NB: Northbound

See Exhibit 1.2 for a map of the project corridor, indicating the sections proposed for RSP underPhase I.

05130/03 Introduction1 -1

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V ~~~~~~~~~~~~~~~~N, ' ; z P {</> | N 9f~~~~~~~~~~~~~~~~~~~~~~Legnd

4 t -- t z A < China A ntema,naIBoundaryProvindal Boundary

, r 1, ,,,, _ _._ R 1 N5 Highway -

) i I I N S A) C 1a, I // I Hlghway (Other)NWFP. r-- UT.~~C~I Motorwy

Motorway (Poposed) .Nowshere Pesh MOWBva lr.-chang'~~~~~ - - * - >' > -- Toidn ) Motorway Interchanges

7 ~~~-1# -~~~PhasIY\jj ~~~~~~~~~Resurfacin and Strengftenlng ....Afghajnistan

r Gujrenwala -K.haflan

,____ ~ ~ ~ ~ ~ ~ ~ ~ - ---.------- ____"7:

an 502s 0 60 100 150bn

t_ ; \ ~~~~Khuza v*2\

EMP for PHRP_~ j Awantn \ ! 1tZ C l1dia Resurfacing Projects (Phase I)

Exhibit 1.2------ >, ;e- * > _eX J ST)Sections Proposed for.r;. l,rsI. ,,\ {.[ ;d Slndh 9 .RSP

Scale 1: 9,000,000

e Sure SOP, ..- ..Arabian Sea e * -~ - - - -- -- __ 5uDravng W3EO0PHR

:~, ' ' u ;~ _ .^ ... -; '.-' . .;' . .... 2 .' . Oat.. '- ,,' , ; Dd May 2003

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EMP for PHRP Resurfacing and Strengthening Projects

1.2 Objectives of Environmental Management PlanThe EMP will help the NHA address the adverse environmental impact of the project, enhanceproject benefits, and introduce standards of good environmental practice. The primary objectivesof the EMP are to:

1. Define the responsibilities of project proponents, contractors and other role players, andeffectively communicate environmental issues among them (see Section 2).

2. Facilitate the implementation of the mitigation measures identified in the EIA byproviding the technical details of each project impact, and providing an implementationschedule (see Section 3).

3. Define a monitoring mechanism and identify monitoring parameters to ensure that allmitigation measures are completely and effectively implemented (see Section 4).

4. Identify training requirements at various levels and provide a plan for implementation(see Section 5).

5. Identify the resources required to implement the EMP and outline correspondingfinancing arrangements (see Section 6).

1.3 Key Environmental and Social ComponentsThe key environmental and social issues associated with this project are as follows:

1. Appropriately locating temporary construction camps, asphalt plants, and waste disposalsites, and the environmental impact of operating these facilities

2. Regulating the procurement of borrow material and topsoil erosion during construction

3. Avoiding the obstruction of highway drainage system during construction and operation

4. Enhancing and maintaining avenue tree plantation along the entire length of the projectcorridor

5. Minimizing the impact on cultural sites or structures and community-owned assets duringconstruction and operation

6. Ensuring pedestrian and traffic safety during construction and operation.

Each of these is discussed in more detail in Section 3.

1.4 Regulatory Requirements and Applicable Standards

1.4.1 National Regulatory RequirementsThe key regulatory requirements, in the context of environmental protection, applicable to theproject under Pakistan legislation are listed in Exhibit 1.3.

0530/03 Introduction1-3

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Exhibit 1.3: Applicable Regulatory Requirements (Environmental)

Instrument Requirement Action

Environmental Protection Act of Makes it mandatory for the project An EIA meeting the regulatoryPakistan, 1997 proponents to carry out an requirements was prepared and

environmental impact assessment submitted to the Pakistanand incorporate environmental Environmental Protection Agencyand social mitigation actions as on April 22, 2003part of the project planning

Makes it illegal to discharge any The design specifications of theeffluent or emission in violation of project require that the relevantthe National Environmental components will meet thisQuality Standards (NEQS) requirement

Sindh Wildlife Protection, Makes it illegal to undertake any No project activity has beenOrdinances Sindh, 1972 project activity inside a protected planned in a protected area.

area (national park, wildlife During construction, thesanctuary, or game reserve) Contractors will ensure that the

protected areas in the proximity(within 500 m) of the N5, ie, theThatta Faqirullah game reserveon the Gujranwala-Khariansection (see Section 4 of the EIA)are not entered.

1.4.2 Environmental Standards

Effluents

The National Environmental Quality Standards (NEQS) for industrial and municipal effluentsdefine the maximum allowable concentration of pollutants in effluents released into differenttypes of receiving bodies. This standard will apply to all effluents from project facilities (seeAppendix A for the NEQS).

Gaseous EmissionThe NEQS for gaseous emissions define the maximum allowable concentration of pollutants ingaseous emissions from industries. This standard will apply to all gaseous discharges fromproject facilities (see Appendix A for the NEQS).

Ambient Air QualityAs ambient air quality standards have not been introduced in Pakistan as yet, standards set by theWorld Health Organization (WHO), the United States Environmental Protection Agency(USEPA), and other international standards including the Japanese standard were reviewed. Forthe purpose of this project, the following values were used:

*' CO: 35 ppm over an averaging time of one hour corresponding to both the USEPA andWHO standards

* Nitrous oxides (NOx): 106 ppb over averaging time of one hour, corresponding to theWHO guidelines, which are less stringent than the USEPA limit of 53 ppb

* Sulfur oxides (SOx): 140 ppb over an averaging time of one hour, corresponding both tothe WHO guidelines and USEPA standards.

* PM1 O: 150 Ftg/m3 over an averaging time of 24-hours corresponding to the USEPAstandard.

05/30/03 Introduction1-4

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Noise

While standards for vehicle-generated noise are prescribed under the NEQS, noise standards forreceptors have not been set as yet. Standards set by the WHO for various categories of receptorswere used as reference points and are included in Appendix A.

Drinking Water

In addition to the NEQS that apply to effluents released from construction camps, WHO drinkingwater quality guidelines were used as reference points for determining water quality. These areoutlined in Appendix A.

1.4.3 Status of Regulatory ClearancesA sectoral social and environmental report for the entire project, as well as an RSP-specific EIA,EMP, and social assessment were submitted by the NHA to the Pak-EPA on April 22, 2003.According to the regulatory requirements, the federal EPA has to hold mandatory public hearingsfor the project and publish a mandatory 30-day Notice for Public Hearing in the national/localpapers prior to providing the environmental clearance. The provinces impacted by the projectmay also initiate their own hearings, which may require additional time and 30-day mandatorynotifications of the hearings. The federal and provincial EPAs are currently reviewing theenvironmental and social documentation to determine the scope and locations of the hearing(s).Based on its discussions with the EPA, the NRA anticipates that only one hearing will benecessary. Assuming that only one hearing will take place, the Environmental Approval from thefederaUprovincial EPAs is anticipated by late-July 2003. However, if each province requestsseparate hearings, the NOC may be expected to be issued by the end of August 2003.

05/30/03 Introduction1-5

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2. Implementation and Supervision Plan

This section describes how the EMP will be implemented in conjunction between the NHA,supervision consultant, and contractors.

2.1 Institutional Structure and ImplementationThe National Highways Improvement Program (NHIP) will be administered in three differentcapacities: federal, regional, and field. Each is described in more detail below, and is illustratedin Exhibit 2.1.

2.1.1 Federal StructureThe NHA's federal headquarters is based in Islamabad, and is responsible for managing theproject at a policy level. At the highest level, the NHIP will be directed by a Steering Committeeconsisting of the Chairman NHA, Member Operations, Member Finance, and Member Planning.A Project Director will be responsible for day-to-day project management, and report directly tothe Member Operations who will have ultimate responsibility for managing the implementationof physical works.

The Project Director will be assisted by the General Manager (GM) Environment/Social andLands, who will have overall responsibility for ensuring project compliance with the EMP. TheGM Environment/Social and Lands will be supported by a Director/Deputy Director (D/DD)Social/Infrastructure and Land Management, and a Director/Deputy DirectorEnvironment/Afforestation. Both D/DDs will be supported by their respective AssistantDirectors (AD). The specific implementation and supervision responsibilities of the GMEnvironment/Social and Lands' office are described in Section 2.2.

2.1.2 Regional StructureThe regional structure described in this section will operate in each of the three provinces inwhich improvement works are being carried out under the PHRP, ie, Sindh, Punjab, and NWFP.In each province, the implementation of the project will be managed by a regional GM assistedby a Project Coordinator. The regional GM will also be assisted by a regional DD/ADSocial/Infrastructure and Land Management, a regional DD/AD Environment/Afforestation, anda regional Director Operations. The DD/AD Environment/Afforestation will be supported by aForest Officer (one per region). Administratively, the DD/AD Environment/Afforestation willreport directly to the regional GM, although he will be functionally responsible to the federalD/DD Environment/Afforestation.

The specific implementation and supervision responsibilities of the regional DD/ADEnvironment/Afforestation and regional DD/AD Social/Infrastructure and Land Management aredescribed in Section 2.2.

There will also be a Social and Resettlement Committee operating in each province, consisting ofthe regional Director Operations, regional DD/AD Social/Infrastructure and Land Management,regional Project Coordinator, and federal D/DD Social/Infrastructure and Land Management.Each committee will be responsible for coordinating the project's social implementation andmonitoring issues in its respective province, and reporting to the regional GM and the GMEnvironment/Social and Lands. The committee will be required to convene quarterly, althoughmay need to meet on a monthly basis in the initial stages of the project.

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2.1.3 Field StructureEach regional office as described in Section 2.1.2. will be assisted by field units operating inspecific project reaches. The regional Director Operations will be assisted by a field-based DDOperations, who in turn will supervise an AD Operations and Management, and an ADMaintenance and Monitoring. Both ADs will oversee a team of field-based supervisors andinspectors. Of these, two or three supervisors or inspectors (one for each contract) will beassigned to the DD Environment/Afforestation in each region to assist in departmentalmonitoring.

2.2 Specific Implementation ResponsibilitiesThis section describes the implementation and supervision responsibilities of the GMEnvironment/Social and Lands and his staff, both at a federal and regional level. The detailedterms of reference for the GM Environment/Social and Lands, the D/DDEnvironment/Afforestation, and AD Environment/Afforestation are provided in Appendix B.Exhibits 2.2 and 2.3 illustrate how the environmental and social aspects of the project will beadministered and delegated, respectively.

2.2.1 Design PhaseAt the federal level, the GM Environment/Social and Lands and his staff are responsible forensuring that the project design and specifications adequately reflect the EMP. Specifically, theD/DD Environment/Afforestation will ensure the project's compliance with environmentalregulations and donor requirements; and ensure stakeholder participation in the project design.The specific responsibilities of the GM Environment/Social and Lands are as follows:

1. Setting up systems for environmental management.

2. Coordinating with regulatory agencies including EPAs, local NGOs, and community-based organizations (CBOs) that could assist the NHA in independent reviews ofenvironmental and social compliance.

3. Ensuring that the terms of reference for each project consultant adequately coverenvironmental and social issues and participate in short listing consultants whereappropriate.

4. Ensuring that the construction contractors develop and implement EnvironmentalImplementation Plans which are consistent with the EMP.

5. Supervising environmental and social assessments, and providing substantial inputs andguidance to the General Manager Planning in preparing engineering design and tenderdocuments

6. Having EIAs approved by the EPAs concerned

2.2.2 Construction PhaseThe GM Environment/Social and Lands and his staff will be responsible for the following:

1. Liaising between project staff (essentially the Project Coordinators in each province andthe Deputy Project Coordinators assigned to the contracts) and the SupervisionConsultant's staff to monitor environmental compliance during construction.

2. Supervising and providing technical support to project and operations staff to help ensurecompliance with the EMIP

3. Assessing the environmental impact of highway construction

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At the federal level, the D/DD Environment/Afforestation will oversee the project'senvironmental implementation, training, reporting and monitoring and may commission periodicenvironmental audits. Each regional DD Environment/Afforestation will assist the SupervisionConsultant in overseeing the supervision and reporting on the implementation of the EMP andafforestation program, and assist in training field and regional staff. As soon as the afforestationprogram (see Section 3) contract has been awarded, a Forest Officer will be assigned to eachregion to ensure that the Afforestation Contractor is developing adequate nursery stock of thetype, quality, and maturity required to meet the afforestation requirements; preparing plantationschemes for different locations; and stockpiling materials, etc. The Forest Officer will report tothe regional D/DD Environment/Afforestation concemed.

2.2.3 Operation PhaseThe GM Environment/Social and Lands and his staff will be responsible for the following:

1. Coordinating with the operations staff working under the regional General Managers tomonitor environmental compliance during highway operation.

2. Advising on, and monitoring tree plantations along the highways

3. Reporting on the progress of environmental compliance to the federal and provincialEPAs

4. Assessing the long-term environmental impact of highway operation

5. Sustaining a working partnership among the NHA, EPAs, provincial agriculture, forestand wildlife departments, NGOs/CBOs and other related public/private sectororganizations.

At the federal level, the D/DD Environment/Afforestation will maintain the environmentalmanagement system; ensure continued compliance with environmental regulations; prepare anddeliver training programs to all NHA staff and contractor's staff and maintain close liaison withthe project's stakeholders.

2.3 Role of Functionaries

2.3.1 Project CoordinatorsThe Project Coordinators will be responsible for handling the NHA's (as the Employer)obligations with respect to the RMP contracts assigned to their respective provinces. The DeputyProject Coordinators assigned to these individual construction contracts will be responsible forensuring that the provisions of the EMP are implemented in their construction areas. The DDOperations in each province will assist by coordinating with the regional General Managerconcemed in order to manage traffic and construction activities within the RoW and corridor ofimpact.

2.3.2 Supervision ConsultantA Supervision Consultant appointed by the NHA under intemational competitive bidding (ICB)will be designated the "Engineer/Project Manager". The Supervision Consultant will beresponsible for:

1. Supervising the project's contractors and ensuring that all contractual obligations relatedto design and construction, as well as environmental and social compliance are met

2. Ensuring that day-to-day construction activities are carried out in an environmentallysound and sustainable manner

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3. Organizing periodic environmental training programs and workshops for the contractors'staff and NHA site staff in consultation with the NHA

4. Developing 'good practices' construction guidelines to assist the contractors and NHAstaff in implementing the EMP

5. Assisting the GM Environment/Social and Lands in coordinating with the EPAs,provincial agriculture, forest and wildlife departments, and other public/private sectororganizations.

05/30/03 Implementation and Supervision Plan

2-4

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Environmental Management of Pakistan Highway Rehibilitation Project Project Steering CommitteeMaster Organizational Chart for NHA ____ ___ _ __ ____ ___ ___ ___

Supervision Co.s9.atnt's Staff

SuperomisinConsultant Projec Director

Enolron nmental ___________________Specalist

i Genera !"^a~~~andagr |eGe ,. Ma..

Resident Engineer nrtan aadMegmM(One pet contrac) o

Asitan Directom Assistant Director

_ Afforestetion _&_ a Lrnd Management

Functional Reporting -Administative Reporting - DeputyProJe eroe |

Headquarters A (One per contract o

Regonal OfficeFeld-Based A Depaty Dirotorl Deputy DIrectorl/NHA staff on secondmeer Deputy Director AsAssistant Direcor Asistant Directorduring project c | Operaeions Environment | SoolaVlntnastocturtt

Temporarypnopdprssitons O ] .. L | ~~~~~~~~~~~~~~~~~Afforestation & Lend ManagementTemporary project positions C3&Ln laenn,

Note. -t----1. Position rrently filled by Deputy Director ILndArquisrlion2. Pulled out from regional field unt and deputed to Assistant Direcor Asaistant Director Forest Officer Collecori

Deputy DirectorAssistant Diretor EnironmrenVo Oporatiuns& Maintenance & Assistant LandAttorestation for environmental monitonng Munagement Moniorng Collection Offwr

3. At least one peo region Ptta,ur4 Seconded ftr duraton ot land acquisition process ru r - - - - f ------

Supervisors (2) Sapernisors 12) i Suporoiirwrl| | Inspetor (t) le Inspedotr (t) aInspector

Fleld Unit

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Environmental Management of Pakistan Highway Rehibilitation ProjectEMP Implementation and Monitoring (Environmental)

Supervision Consultant's Staff Implementation Monitoring

Supervision IConsultant General Manager GEnera naer

l~~~~~~~~~~~~~~~~~~~eea Manager Environment/Region ~~~~~~~~~Social/Lands

EnvironmentalSpecialist . Project

Coordinator Director/Deputy Director

Environment/Afforestation

Assistant DirDectoEnvironment/

! IOpiAfforestation

Director

Deputy Project Operations: I Coordinator

(One per contract) I 1

Resident Engineer . Deputy Director Deputy Director/(One per contract) ... .................................................... .Operations Assistant Director

/ _ / ~~~~~~~~~~~~~~~~~EnvironmenVAfforestation.X

Functional ReportingCoordination .......... NotesAdministrative Reporting 1. For RSP, Deputy Director Operations will replace Deputy Project CoordinatorHeadquarters i 2. Pulled out from regional field unit and deputed to Deputy Director/Assistant

Regional Office A Director EnvironmenV Afforestation for environmental monitoring Supervisor/ Forest Officer

Field-Based A 3. At least one per region InspectorFied-ase A .

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EMPfor PHRP Resufacing and Strengthening Projects

3. Impact Assessment and Mitigation Plan

This section outlines the potential impact of RSP works on the physical, biological, andsocioeconomic environment of the selected highway sections. It also provides a correspondingmitigation plan that focuses on countering the project's adverse environmental effects, andassigns responsibility for implementing these measures.

3.1 Environmental BaselineEnvironmental baseline conditions relevant to aspects of the EMP are briefly described below:

Soils

The Nowshera-Peshawar region contains alluvial deposits from the Kabul River that make thesoil here very fertile. The Kharian-Rawalpindi area contains both aeolian and alluvial depositsthat are coarse to fine textured.

Ambient Air Quality

Based on a study conducted for the Japan Intemational Cooperation Agency (JICA) for majorurban centers such as Karachi, Lahore and Rawalpindi/Islamabad (HBP, 2000), hourly CO levelswere found to average between I and 4 ppm for typical I 0-hour measurement periods, peaking inthe range of 2-7 ppm. CO levels are higher in areas with extensive ribbon development,irrespective of the traffic count. Hourly PM,o levels averaged between 74 and 206 jig/M3 fortypical 10-hour measurement periods, and peaked in the range of 89-242 ftg/M3. Levels above thesuggested limit of 200 gg/m 3 were recorded at three out of nine sampling locations.

Noise Levels

Average daytime and nighttime noise levels along the proposed RMP sections range between 64and 65 dBA at 50 m. When compared to the WHO noise guidelines that prescribe a limit of 55dBA for outdoor areas, the roadside noise level measurements for both day and night exceed theapplicable limit. Roadside noise level measurements taken at a distance of about 6 m from theedge of the highway were found to be well within the permissible limit of 85 dBA prescribed bythe National Environmental Quality Standards for motor vehicles.

Water Quality

The quality of groundwater in the project corridor ranges from fresh near the major rivers tohighly saline farther away. The disposal of untreated municipal and industrial wastewater, aswell as saline effluents from bordering agricultural areas, has led to significant deterioration inthe quality of groundwater. Samples collected from deep wells showed high levels of E. coli, andwere not deemed fit for drinking purposes.

Biological Environment

The Nowshera-Peshawar section is largely barren of vegetation, this being limited to bushes andsome denuded scrub forest on the Cherat and Pabbi Hills. The Gujranwala-Kharian section istraversed by the Thatta Faqirullah reserve forest at a distance of I km from the highway.However, as levels of disturbance along the project corridor have been high and the areasaccessible to humans for a long time, wildlife abundance and diversity in this area is very low.

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Socioeconomic EnvironmentA total of 120 structures fall within the RoW of the selected RSP sections (see Exhibit 4.16).Given that most of the resurfacing work extends to the edge of the shoulder or up to the toe of theembankment, none of the structures listed will be disrupted.

3.2 Corridor of ImpactAll construction activities will remain confined to the existing right of way (RoW). However,situations in which rehabilitation works will extend beyond the existing RoW include:

*. Establishing construction campsites and asphalt plants on temporarily acquired land

*o Borrowing soil material from temporarily acquired land

* Quarrying aggregate material

* Constructing haul tracks in order to transport construction material, etc.

For the purposes of this study, the Col has been divided into two zones, Col I and Col 2. TheCol 1 marks the limit within which the direct impact of construction activities is expected to takeplace. This includes the removal of vegetation or soil cover for construction. The CoI 2 marksthe limit within which the indirect impact of project activities is expected. This includes theeffects associated with noise, vibrations, vehicular emissions, toxic emissions and fugitive dustfrom batching and mixing plants, and the consumption of natural resources, such as earth fill andwater, required during construction.

3.3 Overview of Impact AssessmentThis section describes the potential impact of RSP works on the physical, biological, andsocioeconomic environment of the selected highway sections.

3.3.1 Procurement of Borrow MaterialAreas for extracting about 0.25 Mm3 of earth material for the rehabilitation of embankments willhave to be acquired on a temporary basis. The contractors or their suppliers will need to leaseabout 20 ha of land (assuming 50 cm-deep ditches are excavated) for this purpose from nearbyprivate farmlands on terms mutually acceptable to the owners and the contractors/suppliers. Theutilization of land for procuring borrow material will induce temporary as well as permanentchanges in the existing land use pattern, as well as in soil resource quality. These are describedbelow:

*o The loss of the fertile plough layer at campsites and asphalt plants, and a drop in theelevation of borrow areas will decrease land productivity.

* Soil erosion may also occur in workshop areas as a result of unmanaged runoff fromequipment washing-yards.

Io Potential conflicts may emerge with landowners regarding the restoration of borrowareas.

*m Borrow pits and other landscape depressions if left open, may prove hazardous to humanbeings, livestock and wildlife.

*m Open pits containing water are potential sources of mosquito breeding if left stagnant,and can create health problems.

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o In the long term, high embankments become increasingly prone to soil erosion, causingan increase in dust emissions, a fall in land productivity, and possible silting of nearbywater bodies.

3.3.2 Location and Operation of Project FacilitiesPhase I RSP works will be divided among four contract packages. The total area required forestablishing temporary RTP facilities, ie, campsites, equipment parking and washing areas,asphalt plants, and access tracks, is estimated at 50 ha. The location and operation of temporaryproject facilities, will induce the following impacts:

* The air quality in and around the selected RSP sections will be affected by fugitive dustand emissions from construction machinery, asphalt plants, and vehicular traffic duringthe construction phase. Emissions may be carried over long distances, depending onwind speed and direction, the temperature of the surrounding air, and atmosphericstability.

* Surface and subsurface water resources in the proposed sections may be contaminated byfuel and chemical spills, or by solid waste and effluents generated by the kitchens andtoilets at construction campsites.

*. Scarified/scraped asphalt and concrete materials, if not disposed of properly, maycontaminate soil resources.

*. The possible contamination of soil by oils and chemicals at asphalt plant sites, workshopareas, and equipment washing-yards may limit the future use of land for agriculturalpurposes.

3.3.3 Impact on Existing Avenue PlantationSince the improvement work is confined to asphalt overlay on the existing pavement and noexpansion of the carriageway is involved, there will be no clearing of trees under the RSPcontracts, unless trees or shrubs impinge directly onto sites demarcated for perrnanent works ornecessary temporary works.

3.3.4 Obstruction of Corridor Drainage SystemThe impact of RSP works on the corridor's drainage system is outlined below:

p. Natural streams and irrigation channels may become silted by borrow material (earth) inthe runoff from the construction area, workshops and equipment washing-yards.

* If cross-drainage structures are not adequately maintained, culverts and water channelstend to become choked with debris and eroded soil, adversely affecting agricultural lands.

*. Highway embankments tend to restrict cross-country drainage, causing the land on eitherside of the embankment to flood in case of heavy rains.

* Surface run-off from the impervious surface of the carriageway can further aggravate theflooding of embankment sides.

3.3.5 Impact on Cultural and Community-Owned AssetsThe project's impact on cultural sites/structures and community-owned assets located within theRoW is outlined below:

* Local water supplies will need to be tapped to meet campsite and constructionrequirements, bringing its use into competition with local use.

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*. Noise generated by construction machinery and subsequently by vehicles during theoperation phase, is likely to affect sensitive receptors located within about 50 m of theedge of the highway. These include five schools and two health centers under Phase I,none of which are currently protected by adequate noise barriers.

* Access to cultural sites such as mosques and graveyards/shrines, as well as roadsidebusinesses located within the RoW of the project corridor, may be hindered duringconstruction.

3.3.6 Impact on Pedestrian and Traffic SafetyThe project's impact on pedestrian and traffic safety is outlined below:

* The general mobility of both local residents and their livestock, as well as the operatorsof roadside businesses and their clientele in and around the construction area is likely tobe hindered

* Unmonitored construction activities, eg, blasting or the operation of constructionequipment in unfenced construction sites, may create an accident risk for local residents,particularly their children

*o Unchecked speeding may cause human and livestock injuries and fatalities as a result ofhighway accidents.

* The concentration of commercial activity along the project invariably causestraffic/safety hazards.

* The lack of bus bays and parking areas encourages bus drivers to stop their vehicles onthe carriageway when collecting passengers, creating hazards for oncoming traffic.

3.4 Mitigation Plan

This section provides a management plan to be followed under each RSP contract. Itrecommends measures that will help mitigate the project's adverse environmental effects, andassigns responsibility for implementing these measures. The mitigation plan has been presentedby project phase, and subdivided according to the key environmental and social impacts identifiedin Section 3.3 as and when they are triggered in a particular phase. The mitigation plan focuseson measures that will be triggered during the construction phase, or are required to beincorporated into the project design up front.

3.4.1 Design Phase

The design consultants engaged by the NHA have prepared an outline design for the proposedhighway. The Contractor will be responsible for preparing a detailed engineering designaccording to the criteria and specifications provided in the outline. The environmental and safetyfeatures being implemented during the design phase are described below.

Borrow Pit Management and Topsoil ConservationThe Contractor will identify and detail the location of sources of borrow material/earth-fill, as faras possible, demarcating natural areas with a high elevation for this purpose.

Location and Management of Project FacilitiesThe Contractor will identify and detail the location of key project facilities, includingconstruction camps and facilities, ie, storage, equipment parking and washing areas, aggregatequarries, asphalt plants, access roads for haulage, and disposal sites and procedures for the safedisposal of surplus construction and waste material. Subject to the approval of the Supervision

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Consultant, the Contractor will locate project facilities at a minimum distance of 500 m fromexisting settlements, built-up areas or wildlife habitats. As far as possible, construction campswill be established in areas with adequate natural drainage channels in order to facilitate the flowof treated effluents. Quarry areas and asphalt plants in particular, will be located at least 500 mdownwind from populated areas and contractors' camps, to minimize the impact of dustemissions. The Contractor is also responsible for preparing a sampling analysis plan formonitoring air quality, noise levels, and water and soil contamination as a result of project facilityoperation.

Enhancement and Maintenance of Avenue PlantationA tree plantation program has been incorporated into the outline project design to help abatepollution caused by emissions, dust, and noise during highway operation. In addition, theContractor will establish their campsites and asphalt plants on waste/barren land rather than onforested or agriculturally productive land, in order to minimize the clearing of trees.

Management of Corridor Drainage SystemThe Contractor will incorporate the following features into the detailed design:

* Assessment of repair works required on existing cross-drainage structures.

*. Assessment of appropriate locations and required capacities for new cross-drainagestructures across highway embankments, intersecting rivers, natural streams and canals,to protect nearby agricultural land and settlements from flooding. These structures willbe similar to the existing cross-drainage structures on the adjoining (more recentlyconstructed) additional carriageway (ACW).

p Outfalls for the highway median and side drains to divert surface run-off from thecarriageway, and protect ribbon development areas and settlements.

P Median drains designed with outlets leading into either natural streambeds or open areaswhen no natural streams are located nearby.

p Measures for slope protection, ie, vegetation and stone pitching.

Protection of Cultural and Community-Owned AssetsSubject to the approval of the Supervision Consultant, the Contractor will locate project facilitiesat a minimum distance of 500 m from existing settlements, built-up areas, and archaeological andcultural monuments.

Pedestrian and Traffic SafetyHighway safety audits and improved road markings/signage have been included in the outlinedesign, and accident-prone junctions demarcated in order to improve the horizontal and verticalgeometry, and reduce conflicting movement during operation, particularly along inhabitedstretches of road. In addition, the contractor and supervision consultant will include the followingprovisions for highway safety to reduce the safety risks faced by pedestrians:

* Improved intersections on side roads and village tracks, and eliminating bottlenecks.

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*. Roadside furniture and traffic control devices, including information and cautionarysigns, signals', traffic diversion and flow markings, particularly where the highway liesnear inhabited or protected areas.

* Public facilities, including bus bays with passenger waiting sheds and latrines, servicelanes, footpaths, pedestrian-crossing facilities, and fences.

*. Traffic diversion routes, detour roads, and temporary pedestrian/livestock crossings to beoperational during construction

Protection of Cultural and Community-Owned AssetsThe Contractor will raise the level of boundary walls or construct new walls for buildingssurrounding sensitive receptors such as schools and hospitals to reduce the impact of noisegenerated during construction and operation. As part of the construction contracts, a total of3,400 rft of ten-foot high wall will be constructed for the five schools and two health centers thatare located within 50 ft of the proposed sections. This will be carried out in consultation with thebuilding owners and occupants.

Pedestrian and Traffic SafetyThe NHA in conjunction with the National Highway and Motorway Police (NHMP) will initiate aroad safety awareness campaign among roadside communities settled along project reaches.

3.4.2 Construction PhaseBorrow Pit Management and Topsoil ConservationThe Contractor will be responsible for carrying out the following activities to regulate theprocurement of borrow material and protect topsoil from erosion:

* The excavation of earth fill will be limited to an approximate depth of 50 cm.

* Where the use of agricultural land is unavoidable, the top 30 cm of the plough layer willbe stripped and stockpiled for redressing the land after the required borrow material hasbeen removed.

*. Where deep ditching is to be carried out, the top I m layer of the ditching area will bestripped and stockpiled. The ditch will initially be filled with scrap material fromconstruction and then leveled with the stockpiled topsoil.

* Low embankments will be protected from erosion by planting indigenous grasses that canflourish under relatively dry conditions

* High embankrnents, ie, over 2 m, will be protected by constructing stone pitching or ariprap across the embankment.

*. Ditches or borrow pits that cannot be fully rehabilitated will be landscaped to minimizeerosion and to avoid creating hazards for people and livestock.

* Landowners will be compensated according to the terms of lease agreements negotiatedwith the landowners, and the restoration actions agreed upon by the Contractor will beduly carried out.

Highway safety devices to match the specifications of the (NTRC) manual of signs, signals and roadmarkings, July 1989.

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Management of Project FacilitiesThe Contractor will be responsible for managing the operation of the construction campsite so asto minimize the impact of construction activities on ambient air; ensure adequate provisions forwaste disposal, and protect the health and safety of construction workers:The impact of construction activities on ambient air will be minimized by:

* Equipping asphalt, hot mix and batching plants with dust control equipment such asfabric filters or wet scrubbers to reduce the level of dust emissions.

> Where dust emissions are high, surface treating or overlaying diversion tracks withshingle; where necessary, and subject to the availability of water, sprinkling water acrossdiversion tracks at least twice a day.

* Ensuring that haul-trucks carrying asphalt-concrete mix and/or aggregate fill materialsare kept covered with tarpaulin to help contain construction material being transportedbetween sites.

* Enforcing the NEQS applicable to gaseous emissions generated by construction vehicles,equipment, and machinery (see Appendix A).

The Contractor will carry out the following activities to manage the disposal of constructionwaste:

> Wastewater effluent from contractors' workshops and equipment washing-yards will bepassed through gravel/sand beds to remove oil/grease contaminants before discharging itinto natural streams.

* Construction workforces will be trained in the storage and handling of materials andchemicals that can potentially cause soil contamination.

* Solid waste generated during construction and at campsites will be properly treated andsafely disposed of only in demarcated waste disposal sites approved by the supervisionconsultant.

* Debris generated by the dismantling of existing pavement structures will be recycledsubject to the suitability of the material and the approval of the supervision consultant, orotherwise safely disposed of.

* Pre-laid impervious liners will be used while disposing of scarified/scraped asphalt inborrow pits and natural depressions, and then covered with soil. Altemative bids for thecomplete or partial recycling of the existing asphalt pavement will be considered from thelowest bidder during the tender process.

The contractor will be required to adopt good engineering practices to minimize safety and healthhazards among its workers as well as the local population. Mitigation measures will include thefollowing:

P Complying with safety precautions for construction workers as per the IntemationalLabour Organization (ILO) Convention No. 62 as far as applicable to this contract

* Training workers in construction safety procedures, equipping all construction workerswith hard boots, helmets, gloves, and protective masks, and monitoring their proper andsustained usage.

Management of Corridor Drainage SystemThe Contractor will carry out the following activities to manage the flow of the corridor'sdrainage system:

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*. Median drains will be designed with outlets leading into either natural streambeds oropen areas when no natural streams are located nearby.

* Outfalls for the highway median and side drains will be designed to safely dispose ofsurface run-off from the carriageway, and protect ribbon development areas andsettlements.

* A number of bridges and culverts will be repaired/rehabilitated or constructed across thehighway embankments and across intersecting rivers, natural streams and canals toensure adequate waterways.

* High embankments along cross-drainage structures will be protected by constructingstone pitching or a riprap across the embankment.

* Earth and stone material will not be allowed to block existing cross-drainage structureson sections along or close to water channels.

* Retention work will be carried out on roadside drainage channels as per the drainagedesign to prevent silting.

Protection of Cultural and Community-Owned AssetsThe key issues that will arise during the construction phase in this regard include the impact ofconstruction activities on local community water resources, the impact of noise generated byconstruction machinery, and any chance discovery of historical importance. The Contractor willcarry out the following activities to mitigate these impacts:

*' Construction activities will be limited to daylight hours in sections along denselypopulated areas, to minimize the impact of noise generated by construction machinery.

* Guidelines will be established to minimize the wastage of water during constructionoperations and at campsites.

* The Contractor will be required to maintain close liaison with local communities toensure that conflicts, if any, related to the utilization of water for project purposes areresolved quickly.

*. Construction camp staff will be trained to identify and report possible archaeologicaldiscoveries to the contractor

* Any discovery of archaeological artifacts will be reported to the Department ofArchaeology and Museums, Government of Pakistan

Protection of Existing Avenue PlantationThe Contractor will ensure that there is minimal disruption to the area's vegetation. Trees orshrubs will be felled only if they impinge directly onto sites demarcated for permanent works ornecessary temporary works, and with prior approval from the supervision consultant/forestdepartment.

Pedestrian and Traffic SafetyThe Contractor will carry out the following activities to ensure pedestrian and traffic safetyduring construction:

* Waming signs will be clearly displayed along the construction site; sites within 500 m ofdensely inhabited settlements will be fenced off; local communities will be warned wellin advance of any blasting; and protective devices (eg, wire containment mats) will beused to enhance blasting safety.

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*. All necessary measures will be taken to ensure the safety of traffic during construction,including barricades (including signs, pavement markings, flags, and lights) erected asrequired by the NHA/NHMP. All such barricades will be set up as per local regulations.

*. As far as possible, construction work will be coordinated such that one carriageway at atime is upgraded on any one section, leaving the other available to serve dual traffic.

* Construction vehicles, machinery and equipment will remain confined within theirdesignated areas of movement.

* The contractor will be required to ensure that construction work does not hinder localpeople's access to the highway and their ability to cross it safely. Constructingtemporary ramps and diversion routes will facilitate pedestrians and livestock whencrossing the highway.

* Well-planned traffic diversions will be provided at construction sites to avoid trafficbottlenecks. At most places, the ACW can be used to divert traffic, but where this is notpossible, the diversion route plan will use the space available within the RoW as far aspossible.

* A detailed traffic control plan will be drafted and implemented with the approval of theSupervision Consultant.

3.4.3 Operation PhaseEnhancement and Maintenance of Avenue PlantationAbout 42,900 trees (approx. 130 avenue-km at 330 plants per avenue-km) will be planted to abatedust emissions and noise, provide shade, and enhance aesthetics along the highway. The NHA iscurrently considering different options including a tree plantation policy, which inter aliaprescribes that "in future, all forestation projects of NHA shall be executed, maintained andmanaged preferably by the local Forest Departments as deposit works", or awarding theimplementation of the median and RoW plantation to a Contractor through competitive bidding.

Exhibit 3.1: Indicative Avenue Plantation Program

Proposed No. of Plants to be Pooe pceSection Chainage (km) Avenue-km of Planted Proposed Species

Plantation

Gujranwala-Khanan 1,320-1,410 80 26,400 To be decided aftersite survey

Nowshera-Peshawar 1,657-1,695 50 16,500 As above

Total 130 42,900

Note: The exact avenue-km to be planted will be finalized following a detailed survey of the proposedplantation sites.

Under the five-year program, the 'Afforestation Contractor' will carry out a detailed survey of thePhase I RMP sections, and prepare to-scale linear maps indicating the land available for plantingin the RoW and median, the availability of water; choice of species to be planted; the proximityof urban and rural areas; and the spacing of plants in the RoW, ie, 3 m x 3 m row to row and 3 mbetween plants. A central row of dwarf evergreen omnamental plants maintained at a height ofabout 2 m will be planted along the median of each section, with a second row at 2 m x 2 mspacing. A third row of larger flowering shrubs at 5 m x 5 m spacing will also be planted if there

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is sufficient width. The Afforestation Contractor will prescribe an optimum plant size for trees tobe planted, with a preference towards three-year-old trees. The Afforestation Contractor will alsoensure that only grass, rather than trees, is planted in areas within 100 m of U-tums to protectvisibility, and that approaches to large towns are properly landscaped. The maximum allowablereplacement rate of plants during the second and third years of the program are 20% and 10%respectively (cumulative 30%).

The RoW and median will be handed over to the Afforestation Contractor immediately after allconstruction work has been completed along a particular section, such that the RoW is cleared ofall debris and encroachments; an external boundary has been marked with masonry pillars; andthe median pavement has been broken, and the earth filled and graded. The NHA will hand overcompleted highway sections allowing sufficient time for spring planting (mid-December) ormonsoon planting (mid-May).

The Afforestation Contractor will use water tankers for watering plants during the early momingor late evening, in order to avoid peak traffic hours. The Afforestation Contractor will also erectclearly visible signs to warn oncoming traffic of the presence of water tankers on that section.

Management of Corridor Drainage System

In order to maintain the corridor's drainage system during highway operation, the NHA willensure that all cross-drainage structures, storm drains, and highway drainage systems areperiodically cleared by the NHA's routine maintenance contractors to maintain storm water flow.The NHA will also work with local tehsil (administrative unit) govemments to prevent theaccumulation of solid waste and impoundment of water along highway drainage inlets and opendrains.

Protection of Cultural and Community-Owned Assets

In the long term, the NHA will carry out the following activities to minimize the impact of trafficnoise levels on sensitive receptors:

* Monitor noise levels and facilitate EPAs in enforcing vehicle noise standards asprescribed in the NEQS.

* Alter the occupation and utilization pattems of these buildings to shift frequentlyoccupied areas away from the highway. The Supervision Consultant will assess thecurrent noise levels and advise occupants on the suitability of available altematives.

* Under highway regulations, the construction of buildings is not allowed within 34 m fromthe centerline of the highway. The NHA will strictly monitor such irregularities in future,and seek the assistance of the NHMP in keeping the highway clear of encroachments.

Pedestrian and Traffic Safety

The NHA will carry out the following activities to maintain pedestrian and traffic safety duringhighway operation:

* Traffic management plans will be prepared and implemented by the NHA in conjunctionwith the NHMP and roadside commuters to reduce congestion and traffic hazards.

* The NIA will negotiate improved roadside facilities for road users, with major oilmarketing companies and other service providers operating along the main highways.

* The NHA will work closely with the newly established NHMP to ensure that drivers aswell as pedestrians observe traffic rules and that the safety of the pedestrians is notcompromised.

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4. Environmental Monitoring Plan

This section provides a monitoring plan that identifies the roles and responsibilities of projectstaff involved in environmental and social monitoring, and lists the parameters that will be usedin the monitoring process.

4.1 ObjectivesThe main objectives of the pre-construction and construction phase monitoring plans will be to:

* Monitor the actual project impact on physical, biological and socio-economic receptors.This will indicate the adequacy of the EIA.

* Recommend mitigation measures for any unexpected impact or where the impact levelexceeds that anticipated in the EIA.

* Ensure compliance with legal and community obligations including safety onconstruction sites.

* Monitor the rehabilitation of borrow areas and the restoration of construction campsitesas described in the EMP.

* Ensure the safe disposal of excess construction materials.

The main objectives of monitoring during the operation phase will be to:

* Appraise the adequacy of the EIA with respect to the project's predicted long-termimpact on the corridor's physical, biological and socio-economic environment.

* Evaluate the effectiveness of the mitigation measures proposed in the EMP, andrecommend improvements in the EMP, if necessary.

* Compile periodic accident data to support analyses that will help minimize future risks.* Monitor the survival rate of roadside plantations.

4.2 Monitoring Roles and Responsibilities

4.2.1 Internal Monitoring

The project staff engaged in social and environmental monitoring are listed below, followed bydescriptions of the monitoring responsibilities specific to each post:

* Director/DD Environment/Afforestation (federal)

* DDs EnvironmentlAfforestation (regional)

* Director/DD Social/Infrastructure and Land Management (federal)

* Contractor

* Supervision Consultant.

DirectorlDD EnvironmentVAfforestation

The federal DirectorlDD Environment/Afforestation will have overall responsibility forenvironmental monitoring and evaluation (M&E). This includes the following:

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* Ensuring the availability of human and material resources required for environmentalmonitoring

p Generating periodic monitoring reports and disseminating these among the managementand appropriate staff members

* Ensuring that the required environmental training is provided to the staff concemed

* Contracting out extemal monitoring to independent firms (see Section 4.2.2) andensuring that periodic environmental audits are carried out.

DDs Environment/Afforestation

The regional DD Environment/Afforestation and his team will be responsible for carrying out ad-hoc visits to the construction sites to review the environmental performance of the constructioncontractors and report to the federal D/DD Environment/Afforestation. To enable the regionalteam to carry out its functions, each team will be provided with a GPS, a digital camera, a mobilephone and a noise meter. A computer system with access to the Intemet will be made available ateach regional office to enable the team to compile and send its weekly reports in time. Each teamwill also be provided with a four-wheel-drive vehicle to meets its logistical requirements.

Director/DD Social/lInfrastructure and Land ManagementThe federal Director/DD Social/Infrastructure and Land Management will be responsible formonitoring:

* The progress of social activities, eg, pedestrian access and highway safety, based onprogress reports submitted by the regional DDs Operations.

* The status of the project's consultation strategy, based on progress reports submitted bythe regional DDs Operations.

At the end of Year 1 of project implementation, the NHA will review the efficacy of the M&Earrangements for social, resettlement, and land management issues, and refine the arrangementsaccordingly.

Contractor and Supervision ConsultantThe Contractor and Supervision Consultant will be responsible for carrying out periodic routinemonitoring. Environmental monitoring methods and parameters will include:

* A weekly check of noise levels using a portable noise meter operated near majorconstruction equipment and machinery

* Visual checks of exhaust emissions from equipment and vehicles on a daily basisi. Visual checks of airbome dust on temporary access roads, material stockpiles, disturbed

soil, and haul tracks.

The Supervision Consultant will be further required to:

* Systematically observe the activities carried out by the contractors or any other personassociated with the project

* Verify that the activities carried out comply with the EWAIEMP and other conditionsidentified by the NHA

* Maintain a record of all incidents of environmental significance as well as related actionsand corrective measures.

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The Supervision Consultant will also monitor and report the activities of the Contractor includingtemporary land acquisition, leasing agreements, and any other issues such as potential conflictswith landowners regarding the restoration of borrow areas.

4.2.2 Independent Environmental MonitoringThe NHA will engage an independent monitoring firm on the basis of clearly defined criteriaincluding their experience and resources, to ensure the widespread monitoring of the project'scompliance with the EMP, and to document the status of the project environment at periodicintervals. These monitoring records may be used for compliance purposes as legal records ofenvironmental performance on construction sites. The firm's terms of reference will define aclear work plan, including monitoring indicators, and reporting structures and timelines. TheNHA will provide the necessary logistical support to facilitate the selected firm in the monitoringprocess. The firm engaged for independent monitoring will report its findings on a quarterlybasis directly to the regional GMs, regional Project Coordinators, federal GMEnvironment/Social and Lands, and the Resettlement and Social Committee.

4.2.3 Independent Social/Participatory MonitoringIn addition to internal monitoring, the NHA will select independent monitoring agenciesincluding NGOs and/or local community-based organizations (CBOs) operating along variousproject reaches to ensure the widespread monitoring of the project's social compliance with theEMP. These agencies' terms of reference will define a clear work plan, including monitoringindicators, and reporting structures and timelines. The NHA will provide the necessary logisticalsupport to NGOs/CBOs to facilitate them in the monitoring process. The NGOs/CBOs engagedfor independent monitoring will report their findings on a quarterly basis directly to the regionalGMs, regional Project Coordinators, federal GM Environment/Social and Lands, and theResettlement and Social Committee.

National Highway and Motorway PoliceThe role of the National Highway and Motorway Police (N-MP), which is presently limited totraffic management, will be expanded to provide field-level support in safety management.

4.3 Grievance Redressal SystemThe DD Operations assigned to each construction contract will maintain a communitycomplaints-management register (CCNIR) for that particular reach, to document complaintsbrought forward by the local community, and to ensure that these are appropriately redressedunder the project's M&E system (see Section 4.4.2). The DPC will report directly to the regionalProject Coordinator. The information recorded in the register will include the date of thecomplaint and particulars of the complainant; a description of the grievance; the follow-up actionrequired; the person responsible for implementing the action; and a target date for its completion.Affected communities and their representatives will be identified during the project preparationstage. The DPC will visit each community once a month, while his office will maintain a recordof these visits (date visited, persons met, issues discussed, and complaints brought forward) usingthe CCMR. The DPC will work towards resolving the grievances recorded in the CCMR inconjunction with the Supervision Consultant within seven calendar days. After this deadline, anyunresolved issues will be forwarded to the regional Project Coordinator. The Project Coordinatorwill, in turn, seek to resolve outstanding issues referred to him within seven calendar days,keeping the regional GM and the federal GM Environment/Social and Lands informed. In allcases, the NHA's response will be formally communicated to the complainant in writing.

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The CCMR and feedback from the NGOs/CBOs engaged in monitoring will be periodically (atleast quarterly) reviewed at a high-level meeting at the regional GM's office, and the necessaryactions taken to redress outstanding issues as soon as possible, with a formal NHA responsecommunicated to the complainant in writing. Local NGOs and CBOs will also follow up ongrievances that have not been redressed.

4.4 Monitoring Parameters

4.4.1 Environmental Monitoring ParametersThe following environmental parameters will be monitored at locations to be identified during theconstruction phase (eg, location of asphalt plants, construction camps, etc.).

* Ambient air quality (mainly PM 0o)

* Asphalt plant emissions (smoke, dust, etc.)

* Ambient noise levels

* Water quality

op Avenue plantation.

A monitoring plan for the project indicating environmental parameters, frequency, locations andapplicable standards, is presented in Exhibit 4.1. Appendix A contains standards set under theNEQS and WHO for various categories of receptors used as reference points.

4.4.2 Social Monitoring ParametersSocial monitoring will be carried out based on the following indicators:

* Number and nature of consultations carried out, as well as targeted stakeholders

* Record of any problems due to restricted access to the highway during construction, andwhether ramps/diversions have been provided where required

* Number of grievances recorded and redressed

4.5 Reporting Structure and OutcomesOverall, progress reporting will be the responsibility of each regional Project Coordinator whowill provide inputs to the Supervision Consultant to be collated and submitted to the NHA. TheSupervision Consultant will be responsible for submitting a monthly environmental/social reportfor the project, which will be copied to the NHA's Member Operations, GM Operations, regionalGM, and the World Bank. The Supervision Consultant's monthly progress report will include thefollowing environmental information:

* Contract-wise breakdown of environmental non-compliances and rectification by thecontractors

* The results of monitoring environmental and social parameters carried out by the DDsstationed in each region

In addition, each regional DD Environment/Afforestation will prepare a quarterly reportencompassing environmental concerns, and following review by the GM Environment/Social andLands, submit the report to the federal/provincial EPAs and the World Bank.

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4.6 Proposed Monitoring BudgetThe monitoring program to be carried out by the NHA spans a two-year construction period, andthe first three years of highway operation. The cost of the program is estimated at Rs 18.67million, and includes both environmental and social monitoring. Operation phase monitoring willcontinue through the first three years of operation to evaluate environmental performance and toassess the degree of impact relative to that predicted in the ELA. Following the first three years,the monitoring system may be revised and be made less intensive depending on the results of thefirst three years of operation. The cost of daily monitoring to be carried out by the Contractor andthe Supervision Consultant will be included as part of the contract price. The cost of the programis included in the RMP budget.

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Exhibit 4.1: Environmental Monitoring Plan

Project Stage Parameters Details Standards Responsibilityto be Applied Location Frequency Duration

Air QualityPre- PM1o, S02, NOx, 15 m from the edge of the USEPA NAAQS Four selected locations on Baseline, once prior to Continuous 24 hoursconstruction CO, HC, 03 pavement downwind WHO Air Quality each highway section construction

GuidelinesConstruction PM1o, HC 40 m from the hot mix plant USEPA NAAQS Wherever the contractor Once every four months Continuous 24 hours or

in downwind direction WHO Air Quality decides to locate the hot- during construction over one full workingGuidelines mix plant period day

PM1o 15 m from edge of the USEPA NAAQS Stretch of highway where Once every four months Continuous 24 hours orpavement downwind WHO Air Quality construction is in progress during constnuction over one full working

Guidelines period dayOperation PM1o, S02, NO., 15 m from the edge of the USEPA NAAQS Four selected locations on 3 samples in a week, Continuous 24 hours

CO, HC, 03 pavement downwind WHO Air Quality each highway section once a year for threeBackground concentration Guidelines yearsNear a residential areaAt a sensitive location eg, ahospital or school

Water QualityPre- Pb, total coliforms, Community groundwater WHO Drinking Two selected locations on Once, about a fortnightconstruction and faecal coliforms source near the edge of the Water Quality each highway section before construction

RoW Guidelines starts

Continues...

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Continued...

Project Stage Parameters Details Standards Responsibilityto be Applied Location Frequency Duration

Construction Pb, total coliforms, Community groundwater source WHO Drinking Two selected Once in the middle andand faecal near the edge of the RoW Water Quality locations on each once at the end of thecoliforms Guidelines highway section construction period

Operation Pb, total Community groundwater source WHO Drinking Two selected Once a year in thecoliforms, and near the edge of the RoW Water Quality locations on each summer, just beforefaecal coliforms Guidelines highway section monsoon season

Noise Levels

Pre- Noise levels on Four locations: WHO Noise Four selected Once, one to two weeks 24 hours, readings taken atconstruction dB(A) scale 15 m from the edge of the Guidelines locations on each before start of 15 s intervals over 15 min.

pavement highway section construction every hour, and then

Background noise averaged

A sensitive location

Residentiallcommercial area

Noise levels on 7 m from the equipment whose Pakistan EPA At equipment yard As and when necessary Readings taken at 15 sdB(A) scale noise level is to be determined NEQS (Noise), and road or as instructed by NHA intervals over 15 min. every

1997 construction site hour, and then averaged

Construction Noise levels on 15 m from the edge of the WHO Noise One selected Once every four months 24 hours, readings taken at

dB(A) scale pavement Guidelines location on each during construction 15 s intervals over 15 min.highway section phase every hour, and then

averaged

Continues...

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Continued...

Project Parameters Details Standards ResponsibilityStage to be Applied Location Frequency Duration

Operation Noise levels on Four locations: WHO Noise Guidelines Four selected locations on Once a year 24 hours, readingsdB(A) scale 15m from the edge of the each highway section taken at 15 s

pavement intervals over 15packgroundtnoise min. every hour, andBackground noise then averagedA sensitive location

Residential/commercial area

Soil

Construction Oil and grease Threshold for each Five selected locations in As per occurrencecontaminant to be set contractors' equipment of spillsusing USEPA's IRIS yards on each highwaydatabase until national section as identified by thestandards are established supervision consultant

Operation Oil, metals and Parameters to be analyzed Threshold for each Spill locations involving As per occurrencechemicals according to nature of the spill contaminant to be set vehicles carrying fuels and of spills

using USEPA's IRIS hazardous materialsdatabase until nationalstandards are established

Vegetation Cover

Pre- Number of Only marked trees will be felled As per detailed design of All along the project corridorconstruction trees felled project

Operation Survival rate of On each visit, the number of The survival rate should be Plantation sites Every year fortrees and re- surviving trees to be compared to at least 70%, below which three years orvegetation the number of saplings planted re-plantation shall be done more depending

on the survival rate

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5. Environmental Technical Assistance andTraining Plan

An environmental and social training and technical assistance (TA) program will be carried out tobuild the NHA's capacity to effectively implement this ETP, as well as to facilitate the improvedenvironmental management of future highway projects by increasing the environmental andsocial awareness of NHA staff in general. Initially, the training program will target a smallportion of the NHA staff directly associated with the project, but this is expected to trigger aprocess that will enable the NHA to integrate social and environmental issues into its day-to-dayoperations and project management, and into future transport development projects.

The NHA will engage an international technical assistance (TA) consultant to manage theenvironmental training program. The objective of the TA will be to help establish appropriatesystems, and to train senior NHA staff responsible for managing environment, operations, andplanning, who can then impart training at a broader level within and outside the NHA (ie, thetraining of trainers). The TA consultant will organize foreign and in-country training courses forNHA staff; train NHA staff in specialized areas such as air and noise pollution modeling; developenvironment operation manuals in consultation with the NHA D/DD Afforestation/Environment,and train senior NHA staff in applying these manuals.

In addition to the training arranged and imparted by the TA consultant, the supervision consultantwill train the staff working under the project's contractors in environmental compliance and thedaily monitoring of construction projects. The cost of this training will be included in the budgetof services provided by the supervision consultant.

5.1 Environmental Training ProgramThe strategy adopted for the project consists of training and exposing the senior staff to social andenvironmental issues associated with highway projects. The group of senior staff will then form acore group that on one hand can provide training to other staff of the NHA and on the other handcan be the catalyst of change. At the same time, the inspectors/supervisors and the regional teammembers responsible for overseeing the implementation and monitoring will be trained on thespecific issues associated with the implementation of the EMP. These may include theenvironmental regulations; environmental aspects of the project; the mitigation measures andtheir objectives; duties and responsibilities of the different role players; public consultation;liaison with the stakeholders; supervision and monitoring; and reporting.

The Supervision Consultant will be the main conduit through which training will be provided toNHA and contractor's staff on implementation, compliance reporting, internal monitoring, etc.The project also provides budget and resources for regional and international training for selectedNHA staff and seed funds for developing procedure for ISO 14000 certification.

5.2 Social Training ProgramThe project's social training program will consist of:

*. A six- to ten-day skills training session program designed to develop specific skills inmonitoring and evaluation, and NGO/CBO partnerships. This program will target allconcerned NHA project staff, and provide hands-on skills training in areas required forproject implementation.

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The success of environmental management on this project relies on the expertise and experienceof the personnel involved in implementing it. As contemporary approaches towardsenvironmental management for highway construction and operation are relatively new to theNHA, personnel training both in Pakistan and abroad will be needed. The overseas training willtake place in countries with well-established environmental management systems for highwaydesign, construction and operation.

The details of this training program are presented in Exhibit 5.1. The cost of the trainingprogram is included in the RMP budget.

Exhibit 5.1: Personnel Training Program/TA Services

Type Provided By Contents Trainees/Events Duration

Foreign Institutions recommended Structured course on the Six Oneby TA consultant environmental month

management of highwayconstruction and operation

Foreign Institutions recommended On-the-job field training in Six 6 daysby TA consultant the environmental

monitoring of highwayconstruction and operation

In-country TA consultanV Short seminars and Eight seminars for 2 daysorganizations specializing courses on: project staffin environmental Environmental laws andmanagement and regulationsmonitoring Daily monitoring and

supervision

In-country TA consultanV Short seminars and Eight seminars for 4 daysorganizations specializing courses on: project staffin Social management and Social awarenessmonitoring

In-country TA consultanV Short seminars and Two seminars for 10 daysorganizations specializing courses on: relevant projectin Social management and Specific social issues, such staffmonitoring as resettlement

In-country Institutions recommended ISO 14000 management Seminars andby TA consultant institutional support

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6. Estimated Cost of Environmental Management

Cost estimates of mitigation and other environmental management measures are summarized inExhibit 6.1. All these costs have been incorporated into the project budget, except whereindicated.

Exhibit 6.1: Cost Estimates for Environmental Management of RSP, Phase I

Mitigation Area Description Quantity Cost, Budget DetailsRs million Component

I. Monitoring CostsAir quality, noise - - Included in Project Monitoringand water the RMP budget services to bemonitoring budget procured by

the NHANGO monitoring of - - Included in Project Monitoringsocial/resettlement the RMP budget services to be

budget procured bythe NHA

Monitoring - Included in Projectequipment and the RMP budgetvehicles budget11. Mitigation CostsNoise mitigation - 3,400 rft 4.86 = Civil works 10 ft high wallmeasures approx. to act as noise

0.84 million barrier, @ RsUSD 1,000/rft

Air quality and Avenue plantation 915 Included in Projectnoise mitigation avenue the RMP budget

km budget1II. Training Costs

Staff training and TA and training costs - Included in Civil worksISO 14000 the RMP + project

budget budget

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Appendix A: Environmental MonitoringParameters

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Exhibit A.1: National Environmental Quality Standards for Industrial andMunicipal Effluents

MaximumConcentrationNo. Parameter in Inland

Water1 Temperature or temperature increase =<30C

2 pH value 6 to 9

3 Five-day bio-chemical oxygen demand (BOD)s at 80200C

4 Chemical oxygen demand (COD) 1505 Total suspended solids (TSS) 200

6 Total dissolved solids (TDS) 3500

7 Grease and oil 10

8 Phenolic compounds (as phenol) 0.1

9 Chlorides (as Cl') 1000

10 Fluorides (as F') 10

11 Cyanide total (as CN') 1.0

12 Anionic detergents (as MBAS) 20

13 Sulphates (SO4) 60014 Sulphides (s') 1.0

15 Ammonia (NH3) 40

16 Pesticides 0.15

17 Cadmium 0.1

18 Chromium (trivalent and hexavalent) 1.0

19 Copper 1.0

20 Lead 0.5

21 Mercury 0.0122 Selenium 0.5

23 Nickel 1.0

24 Silver 1.0

25 Total toxic metals 2.0

26 Zinc 5.0

27 Arsenic 1.028 Barium 1.5

29 Iron 8.030 Manganese 1.5

31 Boron 6.0

32 Chlorine 1.0

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Exhibit A.2: National Environmental Quality Standards for Gaseous Emissions

No. Parameter Source of Emission Existing Revised StandardsStandards1. Smoke Smoke opacity not to exceed 40% or 2 on 40% or 2 on

Ringlemann scale Ringlemann Scaleor equivalentsmoke number

2. Particulate matter (a) Boilers and fumaces:i) Oil-fired 300 300ii) Coal-fired 500 500iii) Cement kilns 200 300

(b) Grinding, crusling, clinker 500 500coolers and relatedprocesses, metallurgicalprocesses; converter, blastfumaces and cupolas

3 Hydrogen chloride Any 400 4004 Chlorine Any 150 1505 Hydrogen fluoride Any 150 1506 Hydrogen sulphide Any 10 107 Sulphur oxides Sulfuric acid/sulph6nic acid . 400 5000

plants

Other plants 400 17009 Lead Any 50 5010 Mercury Any 10 1011 Cadmium Any 20 2012 Arsenic Any 20 2013 Copper Any 50 5014 Antimony Any 20 2015 Zinc Any 200 20016 Oxides of nitrogen Nitric acid manufacturing unit 400 3000

Gas-fired 400 400Oil-fired 600Coal-fired 1200

05130103 Appendix AA-3

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Exhibit A.3: WHO Guideline Values for Community Noise in Specific Enviromnents

Specific Environment L(AdB)q fast (dB)

Outdoor living area 55 -50 -

School class rooms and pre-schools (indoors) 35 -

School, playground (outdoors) 55 -

Hospital, ward rooms (indoors) 30 4030 -

Hospital, treatment rooms (indoors) #1

Industrial, commercial, shopping and traffic areas 70 110(indoors and outdoors)

#1: As low as possible

Exhibit A.4: WHO Drinking Water Quality Standards

RecommendedConstituent, mg/L Limited

(1961 European)

Ammonia 0.5

Chlorides 350

Copper 0.0 5a

Fluorides 1.5

Iron 0.1

Magnesiumb 125b

Manganese 0.1Nitrates 50

Oxygen 5.0

Phenols 0.001

Sulfates 250

Zinc 5.0

aMay be higher for new piping

bif 250 mg/L S04 is present, Mg not to exceed 30 mg/L

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Appendix B:Terms of Reference for Key NHAStaff

B.1 General Manager (Environment/Social and Lands)

Qualifications and Experience

* Master degree in Environmental Engineering. Preferably Bachelor degree in civilengineering.

* Over 15 years of working experience related to Environmental documentation,Knowledge of Environmental Laws and NEQS, the design, construction andoperation of highway projects. Experience in project management, landmanagement, construction management and operational maintenance will be anasset.

i Ability to develop environmental friendly policies to take National HighwayAuthority into new state of art era for constructing Highways and Motorways inPakistan

*. Ability and interest in acquiring and assimilating information, and implementingthe relevant state-of-the-art practices in the engineering-environment interface.

* Interest in gathering experience to develop an integrated perspective towards themanagement of road projects which include the incorporation of GOP and theWorld Bank environmental safeguards.

* Good verbal and written communication skills in English and Urdu and otherregional languages.

* Preferably have work and project implementation experience involvingconsultations and community involvement.

Principal Duties

* Ensure that the TOR for each project consultant adequately covers environmentaland social issues and participate in short listing process and selection ofconsultants where appropriate.

* Ensure that the project design and specification adequately reflect theEnvironmental Management Plan (EMP) and the RPF/RAP.

*. Ensure that the Construction Contractors develop and implement EnvironmentalImplementation Plans which are consistent with the EMP.

*n Ensure that the land acquisition process has been followed as per the approvedRPF and resettlement plan

* Ensure the compliance of resettlement and relocation as per approved guidelines.

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* Coordinate with the Regional General Manager on an ongoing basis.

*. Liaise with Contractors, Supervision Consultants and Project Coordinators of thedifferent packages on the implementation to the environmental andsocial/resettlement matters.

* Liaise with the relevant GOP agencies such as EPAs, Forest Departments onenvironmental and other regulatory matters. Ensure timely regulatory clearances.

* Report to member Operation of the NHA on environmental engineering mattersincluding those pertaining to the World Bank-funded proposed National HighwayImprovement Program.

B.2 Director/Deputy Director (Environment/Afforestation)

Qualifications and Experience

*. Bachelors degree in Civil Engineering with masters degree in environmentengineering.

* Over 10 years of working experience related to Environmental Documentation,Environmental Laws and NEQS, design, construction and operation ofinfrastructure (preferably transportation) projects.

*. Ability and interest in acquiring and assimilating information, and implementingthe relevant state-of-the-art practices in the engineering-environment interface.

*. Interest in gathering experience to develop an integrated perspective towards themanagement of road projects, which includes the incorporation of Government ofPakistan (GOP) and World Bank environmental safeguards.

*. Good verbal and written communication skills in English and local language.

Principal Duties

*. Organise and setup the Environment/Afforestation Unit.

* Develop training / sensetization programs for the Environment/Afforestation staffand other NHA staff in collaboration with the Supervision Consultant(Environment).

* Ensure that the project design and specifications adequately address theEnvironmental Management Plan (EMP).

*. Ensure that the Construction Contractors develop and implement EnvironmentalImplementation Plans, which are consistent with the EMP.

*. Liaise with the Contractors, Supervising Environmental Consultants and theDeputy Project Coordinators of the different packages on the implementationaspects pertaining to the environmental matters.

* Liaise with the relevant GOP agencies such as Forest Departments,Environmental Protection agencies, Fisheries and Wildlife on environmental andother regulatory matters.

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o In collaboration with the D/DD SociaVLands, establish ongoing dialogue with theNGOs and Community Groups impacted by the project and ensure that theirlegitimate concems and suggestions are incorporated in the project.

* Review environmental performance of the project through an assessment ofperiodic environmental monitoring reports (air, water, soil, treeplantation/survival, enhancement measures, etc.) and environmental supervisionreports submitted by the Supervision Consultants; provide a summary of ongoingenvironmental issues to the GM Environment/Social and Lands; and initiatenecessary follow-up actions.

* Provide support and assistance to the Government Agencies and the World Bank /Donor Agencies to supervise the implementation of the EnvironmentalManagement Plan during the construction and operational phases of the project.

* Collate and prepare good practice/guidance notes on integrating environmentalissues into engineering design and on implementing environmental measures inthe road construction and maintenance programs. Disseminate the same to theregional DD/AD and the EPAs.

* Assist the NHIP staff and Supervising Consultants in resolving environmentalissues associated with the project.

* Coordinate with the D/DD Social & Lands on an ongoing basis.

*. Report to GM Environment/Social and Lands on Environmental/Afforestationmatters pertaining to project.

B.3 Deputy Director/Assistant Director (EnvironmenVAfforestation)

Qualifications and Experience* Bachelors degree in CiviVEnvironmental Engineering. Preferably a masters

degree in Transportation/Highway engineering/Environmental Engineering.* About 3-5 years of working experience related to the design, construction and

operation of engineering projects. Experience in project management,construction management and operational maintenance will be an asset.

* Ability and interest in integrating environmental and social issues in the design,construction and operation of transport projects.

*' Good verbal and written communication skills in English and local language.

Principal Duties

* Review the implementation plan of the contractor alongwith the EnvironmentEngineer of the Supervisory Consultant.

* Supervise and assist the contractor in the implementation of the EMP along withthe Environment Engineer of the Supervisory Consultant.

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* Coordinate with the Supervision Consultants and the Contractors theimplementation aspects pertaining to the environmental matters.

*n. Coordinate with the relevant GOP agencies such as Forest Department, EPAs etcon environmental and other regulatory matters during pre-construction,construction and operation phase.

* Check and supervise periodic environmental monitoring (air, water, soil, treeplantation/survival, enhancement measures, etc.) and provide a summary ofongoing environmental issues to the D/DD Environment/Afforestation (HQ); andinitiate necessary follow-up actions.

*n Provide support and assistance to the Government Agencies and the WorldBank/Donor agencies to supervise the implementation of the EnvironmentalManagement Plan during the construction and operational phases of the project.

i* Collate and prepare good practice/guidance notes on integrating environmentalissues into engineering design and on implementing environmental measures inthe road construction and maintenance programs. Disseminate the same to otherregional offices,consultants and contractors at site.

*n Coordinate with the Social Development and Redressal Cell at regional level onan ongoing basis during pre-construction and construction phase.

*n Compile quarterly and annual reports for dissemination to the NHA Management,EPAs, and the World Bank as appropriate.

05/30103 Appendix B

B4