Regional: TAPI Gas Pipeline Project (Phase 1) - Asian ...

Environmental and Social Impact Assessment

Project Number: 52167-001 December 2020

Regional: TAPI Gas Pipeline Project (Phase 1)

Pakistan: Appendix H

Prepared by the TAPI Pipeline Company Limited for the Asian Development Bank.

This environmental and social impact assessment is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

http://www.adb.org/terms-use

ESMP_ Pakistan P a g e 1 of 362

IX H:


TABLE OF CONTENTS

DEFINITIONS 7

ABBREVIATIONS 8

1 INTRODUCTION 9

1.1 Overview 9

1.2 Objectives and Scope 9

1.3 Structure of the ESMP 10

2 PROJECT DESCRIPTION 11

2.1 Overview 11

2.1.1 Project Overview 11

2.1.2 Project Location 11

2.1.3 Project Feasibility Corridor and Right of Way 12

2.1.4 Project Schedule 13

2.2 Project Design Philosophy 15

2.3 Applicable Codes and Standards 15

2.4 Quantitative Risk Assessment 16

2.5 Phase I Project Components 17

2.5.1 Pipeline 17

2.5.2 Above Ground Installations 18

2.5.3 Access Roads 20

2.6 Phase I Project Activities 20

2.6.1 Phase I Construction 20

2.6.2 Phase I Commissioning/Start-up 39

2.6.3 Phase I Operation 41

2.6.4 Phase I Decommissioning 51

2.7 Phase II Project Components 52

2.8 Phase II Project Activities 53

2.8.1 Phase II Construction 53

2.8.2 Phase II Commissioning/Start-up 55

2.8.3 Phase II Operation 55

2.8.4 Phase II Decommissioning 58


3 LEGAL AND OTHER REQUIREMENTS 59

3.1 Overview 59

3.2 National Policy and Legal Framework 59

3.2.1 Constitutional Provision 59

3.2.2 National Policy Framework 60

3.2.3 National Legal and Regulatory Framework 63

3.2.4 Provincial Legal and Regulatory Framework 72

3.2.5 National Environmental Assessment Regulations and Procedures 79

3.3 International Conventions, Treaties, and Agreements 86

3.4 International Policies, Guidelines, and Standards 90

3.4.1 IFC Performance Standards and EHS Guidelines 90

3.4.2 ADB Environmental and Social Assessment Guidelines 96

3.4.3 AIIB Environmental and Social Safeguards 97

3.4.4 Equator Principles 99

4 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) 100

4.1 Overview 100

4.2 Environmental & Social Management Plan - Phase I 101

4.3 Environmental & Social Management Plan - Phase 2 188

5 ENVIRONMENTAL AND SOCIAL MONITORING PLAN 223

5.1 Monitoring Plan Objectives 223

5.2 Draft Monitoring Plan 224

5.2.1 Pre-Construction and Construction Phase 1 224

5.2.2 Commissioning and Start-Up Phase 1 245

5.2.3 Operational Phase 1 247

5.2.4 Construction Phase 2 256

5.2.5 Operational Phase 2 275

6 COMMITMENTS REGISTER 281

6.1 Overview 281

6.2 Phase I Commitments Register 282

6.3 Phase II Commitments Register 322

7 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM 337


7.1 Introduction 337

7.2 Objectives 338

7.3 ESMS Elements 338

7.4 Policies and Policy Objectives 338

7.4.1 Code of Conduct 339

7.4.2 Environmental Policy 339

7.4.3 Social Policy 339

7.4.4 Health and Safety Policy 339

7.5 Identification of Risks and Impacts 339

7.6 Management Programs 340

7.7 Organizational Capacity and Competency 340

7.7.1 Internal Interfaces 341

7.7.2 Roles, Responsibilities, and Authorities to Implement the ESMP 342

7.7.3 Communication and Training 348

7.8 Emergency Preparedness and Response 350

7.9 Stakeholder Engagement 351

7.10 External Communications and Grievance Mechanisms 351

7.10.1 Communication Process 352

7.10.2 External Communication Protocol 353

7.11 Ongoing Reporting to Affected Communities 354

7.12 Monitoring and Review 354

7.12.1 Definition 354

7.12.2 Monitoring Tools 355

7.12.3 Compliance Auditing and Review 356

7.12.4 Monitoring of EPC Contractor and Subcontractor Activities 358

7.12.5 Corrective and Preventative Action 359

7.12.6 Continual Improvement 360

7.12.7 Management of Change 360

8 REFERENCES 362


TABLES

Table 2-1: Contract Milestone Schedule 13

Table 2-2: Key Codes and Standards 15

Table 2-3: Construction Approach 21

Table 2-4: Key Equipment Requirements for a Typical Main Spread 29

Table 2-5: Proposed Location of Construction Camps and Pipe Yards 32

Table 2-6: Phase I Construction Water Needs 35

Table 2-7: Typical Wastes Generated during Construction of the Pipeline 38

Table 2-8: Phase I Operation Water Needs 47

Table 2-9: Phase II Construction Water Needs 55

Table 2-10: Phase II Operation Water Needs 57

Table 3-1: National Policy Framework 60

Table 3-2: National Legislative Framework 63

Table 3-3: Punjab Province Legislative Framework 72

Table 3-4: Balochistan Province Legislative Framework 73

Table 3-5: International Conventions, Treaties, and Agreements to which Pakistan is Signatory

86

Table 3-6: Overview of IFC Performance Standards 90

Table 3-7: Overview of AIIB Environmental and Social Standards 97

Table 4-1 – Phase 1 General Management Measures 101

Table 4-2 – Phase 1 Pre-Construction/Construction Phase Impacts and Mitigation Measures

103

Table 4-3 – Phase 1 Commissioning/Start-up Phase Impacts and Mitigation Measures 162

Table 4-4 - Phase 1 Operational Phase Impacts and Mitigation Measures 170

Table 4-5 – Phase 1 Decommissioning Phase 181

Table 4-6 - Phase 1 Non-routine Events / Emergencies (applicable to all Phases) 187

Table 4-7 – Phase 2 General Management Measures 188

Table 4-8 – Phase 2 Construction Phase Impacts and Mitigation Measures 190

Table 4-9 - Phase 2 Operational Phase Impacts and Mitigation Measures 211

Table 4-10 – Phase 2 Decommissioning Phase 217


Table 4-11 - Phase 2 Non-routine Events / Emergencies (applicable to all Phases) 222

Table 5-1 – Pre-Construction / Construction Phase 1 224

Table 5-2 – Commissioning Start-up and Operation Phase 1 245

Table 5-3 – Operational Phase 1 247

Table 5-4 –Construction Phase 2 256

Table 5-5 – Operational Phase 2 275

Table 6-1 – Phase I Commitments Register 282

Table 6-2 – Phase II Commitments Register 322

Table 7-1: Key Positions, Roles, and Responsibilities 344

Table 7-2: Lines of Communication 352

Table 7-3: Checklist for Site Environmental Inspections (SAMPLE) 357

FIGURES

Figure 2-1: Pipeline Routing in Pakistan 14

Figure 2-2: Pipeline Construction – Regular Working Strip 24

Figure 2-3: Schematic of a Typical Open-Cut of Small Watercourse 25

Figure 2-4: Schematic of a Typical Open-Cut of Large Watercourse 25

Figure 2-5: Typical Crossing Drawing – Open-Cut of Small Watercourse 26

Figure 2-6: Typical Crossing Drawing – Open-Cut of Large Watercourse 26

Figure 2-7: Schematic of a Typical Pipe Bridge 27

Figure 2-8: Schematic Sequence of HDD Method 28

Figure 2-9: Typical Compressor Station 53

Figure 3-1: EIA Submission and Approval Process in Pakistan 81

Figure 3-2: Punjab EPA Environmental Approval for the TAPI Project 85

Figure 3-3: Balochistan EPA Environmental Approval for the TAPI Project 86

Figure 3-4: ESIA Process as Presented in IFC Performance Standards 95

Figure 7-1: Development Process of ESMS 337

Figure 7-2 External Interfaces 341


DEFINITIONS

Company : TAPI Pipeline Company Limited

Consultant : ILF Beratende Ingenieure GmbH

Contractor : Companies under contract with the Company for the performance of works/services for the Overall Project

Project : Turkmenistan – Afghanistan – Pakistan – India (TAPI) Gas Pipeline Project

ESIA Process : Environmental and Social Impact Study for the Afghanistan and Pakistan portions of the TAPI Pipeline Project

Subcontractor : Companies under contract with the Contractor for the execution of works/services for the Overall Project


ABBREVIATIONS

ESIA : Environmental and Social Impact Assessment

ESMP : Environmental and Social Management Plan

HSSE : Health, Security, Safety, and Environment

MAB : Environmental Consultancy and Studies LLC

NAFTEC : Specialized Technologies for Petroleum Engineering

SP : Social Performance

TAPI : Turkmenistan – Afghanistan – Pakistan – India

The Company or TPCL : TAPI Pipeline Company Limited


1 INTRODUCTION

1.1 Overview

This ESMP has been prepared to provide a tool for ensuring that all mitigation

measures defined throughout the ESIA process are implemented during all phases of

the Project.

The ESMP is consistent with the current conceptual design, which will be further

developed over the life of the Project. It has therefore been prepared as a dynamic

document that will be regularly reviewed and amended. Contractor(s) selected for

construction will be required to comply with the requirements of the ESMP.

The ESMP covers both Phase I and Phase II of the Project (refer to Section 2 below

- Project Description) separately. Where ESMP measures are generic for both

phases, they have been combined.

1.2 Objectives and Scope

The primary objective of this ESMP is to provide:

· An environmental and social management tool for use by management and staff

involved in the TAPI Project development, and to provide information to regulatory

authorities and Project lenders regarding the environmental and social

management practices that will be implemented throughout the life of the Project.

· An environmental and social management system which is a set of processes and

practices to consistently implement the Project’s policies to meet objectives and

that they are consistently followed by the Project teams. The management system

also helps to assess and control risks and is the key to lasting improvement. A

key feature is the idea of continual improvement – an ongoing process of

reviewing, correcting and improving the system.

The ESMP has the following main objectives:

· To describe environmental and social management and mitigation measures for

each identified significant environmental impacts/issue in each Project phase.

Along with describing how these will be managed by the TPCL environmental and

social team, relevant specific Management Plans and the timetable for

implementation. The potential impacts are different between the various Project

phases, therefore specific ESMPs will be developed during each phase.

· To identify the policies and principles that are to be put in to place to ensure that

the proposed mitigation measures are implemented and effective, including


managerial arrangements that will be applied in the event that the mitigation

measures prove ineffective or unforeseen environmental impacts arise; and

· To propose an environmental and social monitoring program to ensure that the

mitigation measures are implemented during the project execution and timely

corrective actions are taken, where required.

· To provide an environmental and social management system for the

implementation of the ESMP.

1.3 Structure of the ESMP

This document provides a general outline of the “framework document” for the future

ESMPs development. It includes the following sections:

· Section 1: Introduction (this Section)

· Section 2: Project Description

· Section 3: Legal and other Requirements

· Section 4: Environmental and Social Management Plan

· Section 5: Environmental and Social Monitoring Plan

· Section 6: Environmental and Social Commitments Register

· Section 7: Environmental and Social Management System.


2 PROJECT DESCRIPTION

2.1 Overview

2.1.1 Project Overview

As described in Chapter 1. Introduction, in January 2017, TPCL appointed ILF as the

Consultant to undertake the Project Management and FEED development for the

Pakistan and Afghanistan portion of TAPI Project (ILF, 2017).

The Galkynysh gas field, which is listed among the world’s largest natural gas fields

and holds 26.2 trillion m3 of gas reserves, will be the source of natural gas for the

TAPI Project. Turkmengas State Concern has already started the engineering and

initial phase of the construction works on this portion of the TAPI Project (ILF, 2017).

The length of the Pakistan and Afghanistan portion of the TAPI Project is 1,600 km.

The Pakistan and Afghanistan portion of the TAPI Project will be developed in two

phases. Phase I aims to pressurize gas at the last CS located in Turkmenistan and to

deliver gas free flow (reduced flow) to Afghanistan, Pakistan, and India without any

additional gas compression in Afghanistan or Pakistan. BSs, Scraper Stations (SS),

Metering Stations (MS), and OSs along the pipeline are within the scope of Phase I.

Phase II aims to finalize the full-scale project to fulfil the full flow gas delivery contract.

Phase II will include the construction and operation of new CSs (ILF, 2017).

TPCL will act as the employer in relation to the construction works and as the owner

of the Pakistan and Afghanistan portion of the TAPI Project. Turkmengas State

Concern has initiated Phase III of the development of the Galkynysh gas field to meet

its obligations to supply natural gas to the TAPI Project.

The overall Project’s key features across all Phases comprise of:

· A 56-inch diameter steel pipeline;

· Eight CSs (two in Turkmenistan, four in Afghanistan, and two in Pakistan);

· A pipeline length of 1,814 km from the Galkynysh gas field to the Pakistan-India

border;

· Three off-take points in Afghanistan, located at Herat, Nimruz, and Kandahar;

· Three off-take points in Pakistan, located at Quetta, Multan, and Jahanian;

· A final off-take point / interface at the Pakistan-India border (for India); and

· A design life of 40 years.

2.1.2 Project Location

The Pakistan section of the TAPI pipeline is approximately 817 km in length. The

pipeline corridor enters Pakistan northeast of Chaman, to run north of Quetta city and

cross the Sulaiman Mountain before reaching the Indus Plain area. Within the Indus

Plain, the route bypasses the Dera Ghazi Kahn city (north) and Multan city (south).

This routing is indicated on Figure 2-1.


The geographical diversity of Pakistan falls into three main categories: the northern

highlands, the Indus River plain, and the Balochistan Plateau (Penspen, 2015a). The

pipeline route runs through the Balochistan Plateau in the west of Pakistan, before

descending through the east of the Balochistan region and the agricultural lowlands

in the Punjab region. It crosses the range of Khwaja Amran Mountains near the

Pakistan-Afghanistan border (Balochistan Province) at about 1,450 meters above sea

level (masl) and ascends to a maximum elevation of about 2,500 masl. From the

highest point, the pipeline corridor descends into the Punjab region with steep slopes

(over 15%) within the Sulaiman Mountains, before remaining at low-lying levels (that

is, less than 1250 masl) throughout the rest of Pakistan, that is the Indus Plain area.

Within the Indus Plain, the pipeline route crosses the Indus River, Chenab River, and

the Sutlej River just before reaching the Pakistan-Indian border (ILF, 2017b). The

Pakistan section of the TAPI pipeline connects to India at an elevation of

approximately 175 masl (ILF, 2017g; Penspen, 2015a).

The Punjab part of the pipeline corridor is extensively covered by agricultural lands

and is the most intensively used by the local population. Most of the Balochistan part

of the corridor is dry, barren, and sparsely vegetated, with some spots of natural

vegetation and limited lands used for agriculture, and many scattered settlements.

2.1.3 Project Feasibility Corridor and Right of Way

A feasibility corridor of 500 m is considered for a potential change in the alignment of

the pipeline routing. For the purpose of this ESIA report, it has been assumed that the

pipeline routing runs down the center of this 500 m corridor.

A permanent Right of Way (ROW) width or safety zone of 18 m either side of the

pipeline (15 m safety distance + 3 m half of installation corridor) will be established

during the operation phase of the Project. The resulting total width of the permanent

ROW is 36 m. To provide access, a 4 m wide service road accessible by four-wheel

drive (4WD) vehicles is recommended within this permanent ROW in remote areas.

The land in the permanent ROW will be leased from the government and land use

restrictions will apply, including prohibition of all physical settlements of any kind. The

economic restrictions of land within the permanent ROW, in terms of agricultural uses,

have not yet been confirmed with the government; however, it is likely that certain

agricultural activities, including grazing and hay-making, may be able to continue

across the majority of the ROW, while ploughing and deep-rooted crops will not be

allowed.

During the construction phase, a temporary ROW of 38 m width will be established,

which will be sufficient for the majority of the planned construction activities. Only at

large crossings more land for lay-down and storage may be required. For a large

crossing, an additional 6 m either side of the pipe is realistic. The need for additional

land during construction will be established during detailed design of the crossings in

the next Phase of the Project.


Within the temporary ROW, all access, settlements, and economic activities will be

prohibited for the duration of the construction phase. (ILF, 2017e).

2.1.4 Project Schedule

According to the preliminary EPC schedule, the construction time for Phase I of the

Project will be approximately 36 months. To meet the schedule, the construction

phase will be separated into five spreads to be constructed in parallel.

Project approval is scheduled for Q4, 2021 and Phase 2 is scheduled to start with

updating the FEED in Q2, 2022.

TPCL’s anticipated dates for issuing the EPC Limited Notice to Proceed (LNTP) and

full Notice to Proceed (NTP) at Financial Investment Decision (FID) are taken from

the Effective Date. The EPC Contractor’s schedule for completing the key activities of

the Works by the Contracted Key Milestones Dates (CKMSD) are presented in the

Contract Milestone Schedule, as summarized in Table 2-1.

Table 2-1: Contract Milestone Schedule

KM CKMSD (Yes/ No)

Contract Milestone Schedule Key Milestone Activities

Period from Contract Commencement Date

0 No Effective date -1 Month

1 No Commencement date of LNTP Works (five Construction Main Camps and associated temporary works)

0 Month

2 No Completion of minimal facilities at Marshalling Yard Karachi 4 Months

3 No FID and TPCL issue of full NTP to EPC Contractor for Pakistan 6 Months

4 No Handover date at Marshalling Yard for first Long Lead Items quantities

7 Months

5 No Completion of LNTP Works (five Construction Main Camps and associated temporary works)

9 Months

6 No Handover date at Marshalling Yard for final Long Lead Items quantities

21 Months

7 Yes Contracted date for Mechanical Completion Pakistan Section 33 Months

8 Yes Contracted date for Provisional Acceptance Pakistan Section 36 Months

Notes:

KM = Key Milestone


Figure 2-1: Pipeline Routing in Pakistan

Source: Jacobs, 2018


2.2 Project Design Philosophy

The Project will be designed to meet a 40-year design life criterion, which will be

extended as needed through future maintenance. The design of the pipeline will

consider the corrosion characteristics of the process fluid and the surrounding

environment over the design life span. The gas composition provided by the supplier

indicates that the gas to be supplied is not corrosive (ILF, 2017c).

The design philosophy is to ensure that the Project complies with the prevailing

legislation applicable for the design, gaining of consent, permits, licenses,

authorizations, construction, and operation of pipelines in Pakistan, and that the

impact to natural and social environments is kept to a minimum. The pipeline and

AGIs will be designed in accordance with requirements resulting from:

· National and local regulations, where applicable;

· Safety of the people living close to the pipeline and of personnel working near the

pipeline;

· Protection of the environment;

· Protection of property and facilities, geotechnical, corrosivity, and hydrographical

conditions; and

· Requirements for construction, operation, and maintenance.

2.3 Applicable Codes and Standards

All Project facilities will be designed in general accordance with US codes and

standards (ILF, 2017c). Where there is a conflict with the existing national laws and

regulations, and the referenced codes or standards, the most stringent of the codes

or standards will prevail (ILF, 2017c - u).

The American Society of Mechanical Engineers (ASME) B31.8 Gas Transmission and

Distribution will be followed with regards to the construction of the pipeline, which

covers the design, fabrication, installation, inspection, testing, and other safety

aspects of operation and maintenance of gas transmission and distribution systems.

Key notable codes and standards that will be applied are presented in Table 2-2. It is

noted that the latest editions of all relevant codes and standards will be applied.

Table 2-2: Key Codes and Standards

Code Description

AGA PR-237-9428 Water- Crossing Design and Installation Manual

API 1104 Welding of Pipeline and related Facilities

API 5L Specification for Line Pipe

API RP 2201 Procedures for Welding or Hot Tapping on Equipment in Service

ASME B31.8 Gas Transmission and Distribution Piping Systems

ASME V “Boiler and Pressure Vessel Code - Non-destructive Examination”


Code Description

ASTM D1557-78 Moisture density relations of soils and soil-aggregate mixtures using 10-pound (4.54 kg)

rammer and 18-inch (457 mm) drop

FGCC Standards and Specifications for Geodetic Control Networks

NACE RP0274 Standard Recommended Practice - High-Voltage Electrical Inspection of Pipeline

Coatings Prior to Installation

ACI 318-08 Building Code Requirements for Structural Concrete

ACI 350-06 Code Requirements for Environmental Engineering

ACI 530-08 Building Code Requirements for Masonry Structures

ASTM C150 Standard Specification for Portland Cement Test Method

BS 1199 & 1200 Building Sands from Natural Sources

BS 5499-5 Graphical Symbols and Signs. Safety Signs, Including Fire Safety Signs. Signs with

Specific Safety Meanings

BS EN 197-1 Cement. Composition, Specifications and Conformity Criteria for Common Cements

BS EN 14411 Ceramic Tiles. Definition, Classification, Characteristics, Assessment and Verification of

Constancy of Performance and Marking

BS EN ISO 9001 Quality Management Systems. Requirements

IBC Latest International Building Code

NFPA 80 Standard for Fire Door and Fire Windows

NFPA 75 Standard for the Fire Protection of Information Technology Equipment

UBC – 97 Uniform Building Code

AS 101 Standard Specification for Liquefied Petroleum Gases

NEQS National Environmental Quality Standard

PMGSR Pakistan Mineral Gas Safety Rule, 1960

OGRA Oil and Gas Regulatory Authority, Gas Transmission Technical Standards

BCP-07 Building Code of Pakistan - Seismic Provisions 2007

Source: ILF, 2017c - u

2.4 Quantitative Risk Assessment

A Quantitative Risk Assessment (QRA) has been conducted by ILF for the

Afghanistan and Pakistan portions of the TAPI Project, under operational conditions

(ILF, 2018a). The QRA evaluated the pipeline sections adjacent to the most populated

areas along the pipeline corridor, namely:

· 56-inch pipeline section at KP 589-599;

· 56-inch pipeline section at KP 665-675;

· 56-inch pipeline section at KP 1372-1382; and

· 56-inch pipeline section at KP 1385-1395.

The QRA calculated the individual and societal risks resulting from loss of

containment of pipeline gas and compared these values against risk criteria based on

regulations from the United Kingdom Health and Safety Executive (UK HSE). The

consequence calculations and risk summation were done using Safeti 8.11 from

DNV GL Software, with meteorological data provided via Meteonorm 7.0.


The QRA found that the individual and societal risks for the selected pipeline sections,

which are located adjacent to the most populated areas along the pipeline corridor,

were all within the acceptable range according to UK HSE limits. As such, the report

concluded that the individual and societal risks for all other sections of the pipeline

would also fall within the acceptable area according to UK HSE limits. The QRA did

not consider environmental risks resulting from catastrophic loss of containment.

2.5 Phase I Project Components

2.5.1 Pipeline

The total length of the current proposed pipeline corridor is approximately 1,814 km,

about 817 km of which are in Pakistan.

The 56-inch diameter pipeline will be constructed from 12 m long line pipes of high-

grade steel. The pipeline will be protected with coatings, including an internal fusion

bonded epoxy coating to reduce friction losses through the line and a three-layer

polyethylene coating as the external coating. The pipeline will be further protected

against corrosion by a cathodic protection system.

The length of open trench per single spread shall not exceed 5 km (cumulative length).

Open trenches create a serious hazard to livestock and the general public; therefore,

the EPC Contractor will specify additional means such as barricading and / or 24-hour

guarding of open trenches in the vicinity of populated areas or roads, in accordance

with a site-specific risk assessment.

The pipeline will have a design pressure of 100 barg (bars above atmospheric

pressure).

In Phase I (free flow), the maximum possible transport capacity of the Project system

will be approximately 10.9 bcm per annum. However, the pipeline system is designed

for a daily contract quantity gas flow of 80.11 million metric standard cubic meters per

day, which corresponds to a total throughput of 29.24 bcm per annum. This will be

achieved in Phase II (detailed in Section 3.7) after installation of the CSs.

Thicker-walled pipes will be used where added protection is called for, for example,

where the pipeline crosses major roads, watercourses, and railways, or where the

pipeline is routed through areas of high population density, or close to existing or

proposed developments. Where the pipeline crosses active fault lines, a 400 m long

section of thick-walled pipes with a design factor of 0.5 will be used. In these areas,

the pipes will be placed in a wider- and shallower-sided trench filled with pea-gravel

or an equivalent stone that will allow certain movement should the pipe suffer a

tremor. The trench will be typically approximately 2.7 m deep (from ground level to

trench bottom) in most areas; however, the depth will increase in areas such as roads,

rivers, and agricultural land.


For safety reasons and to minimize impacts to existing land uses (for example,

agricultural land), the buried pipeline will have a soil cover of at least 1 m from the

graded soil level where technically feasible, and 3 m or more below the bottom of the

body of large watercourses. Greater depths may be required when crossing existing

infrastructure (ILF, 2017).

2.5.2 Above Ground Installations

Various AGIs along the pipeline have been designed to allow proper and safe

operation for Phase I. The main station components of the pipeline system are as

follows:

· Offtake Stations PAK-OS01 and PAK-OS02;

· Scraper Stations PAK-SS02 and PAK-SS03;

· Metering Station PAK-MS01, combined with Scraper Station PAK-SS03; and

· Approximately 36 BSs to enhance pipeline safety.

The pipeline system has been divided into five spreads (ILF, 2017a) and the

distribution of AGIs across them are summarized as follows:

· Spread 1 (includes PAK-OS01 collocated with PAK-BS03 at Quetta and

PAK-BS01, 02, 04, 05, and 06) – Contains crossings of the main Quetta-Chaman

Road and N-50 Kuchlak-Zhob Highway, and crossings of the Chaman Bostan

Railway Link and of the Quetta Bostan Railway line. Spread 1 also contains three

river crossings and two seismic fault crossings, namely, the Chaman Fault and

the Ghazaband Fault;

· Spread 2 (includes PAK-BS07, 08, 09, 10, 11, and 12) – Contains four crossings

of the NH-70 Highway and five rivers crossings;

· Spread 3 (includes PAK-BS13, 14, 15, 16, and 17 and PAK-SS02 collocated with

PAK-BS13) – Contains three crossings of the NH-70 highway, a crossing of the

Main Railway Line–2 and two rivers crossings, two main crossings over ridges of

the Sulaiman Range reaching elevations of approximately 2020 masl;

· Spread 4 (includes PAK-OS02 collocated with PAK-BS24 at Multan, PAK-OS03

collocated with PAK-BS25 at Jahanian, and PAK-BS18,19, 20, 21, 22, 23, 24,

24b, and 25) – Contains eight road crossings of N-55 Highway, N-70 Highway,

Motorway and N-5 Highway. Spread 4 also contains four railway crossings and

three large river crossings, namely, the Indus, Chenab, and Sutlej Rivers,

together with wetlands in the vicinity of the river and channel crossings and

· Spread 5 (includes PAK-MS01, PAK-SS03 and PAK-BS26, 27, 28, 29, 30, 31,

32, 33, 34, 35, and 36) – Contains a road crossing at the Bahawalnagar Arifwala

Sahiwal Road, a railway crossing, the Sutlej River crossing, and wetlands in the

vicinity of the river and channel crossings.

Construction camps and pipe yards will also be required during construction along the

pipeline route.


2.5.2.1 Off-take Stations

All OSs are located at future CS locations. Each OS will include heaters and one

emergency diesel generator set, taking up a total of approximately 6,000 square

meters (m2) of land per station (ILF, 2018b). The OSs will be equipped with fiscal

metering, flow/pressure control valves for the offtake gas quantities, and a gas heating

system (ILF, 2017c).

Three off-take points, located at Quetta, Dera Ghazi Khan, and Multan are proposed

along the Pakistan section of the TAPI pipeline, as follows:

· Quetta OS PAK-OS01, at CS PAK-CS01 located approximately 15 km northwest

of Pishin town next to the Hejezai Bypass Road;

· Multan OS PAK-OS02, located approximately 12 km south of Multan town near

an asphalt road; and

· Johanian OS PAK-OS03, which will include SS PAK-SS03 located approximately

9 km northwest of Johanian city near an asphalt road.

2.5.2.2 Metering Stations

All MSs will be strategically located to measure the outgoing gas quantities at the

border of each country. A MS will include a custody metering system, two gas

generators (1.04 megawatts) to supply power located within the Power Generation

Area, one Emergency Diesel Generator (240 kilowatts) and a vent stack

approximately 30 m high for emergency venting.

One custody MS (PAK-MS01) will be located at the eastern end of the route at the

Pakistan-India border, approximately 6 km south of Sulaimanke town, to measure and

control the outgoing gas quantities from Pakistan to India.

PAK-MS01 will have a footprint area of approximately 65,000 m2, which includes a

safety strip and residential area (ILF, 2018c). The MS dimensions are expected to be

approximately 300 m2 (ILF, 2018c).

2.5.2.3 Scraper Stations

SSs are used for routine pipeline inspection and maintenance purposes. Scraper

traps will be installed at the incoming (scraper receiver trap) and outgoing pipeline

(scraper launcher trap) in order to allow insertion and removal of various types of

scrapers/PIGs. The scraper traps are sized for handling intelligent PIGs and designed

according to the respective pipeline code (ASME B31.8) considering design pressure

and temperature rating of pipeline and respective station.

Three SSs are proposed along the Pakistan section of the TAPI pipeline.

2.5.2.4 Block Valve Stations

BSs enable the operator to sectionalize the pipeline in case of necessity, which can

include leakages along the pipeline, maintenance and refurbishment, and test runs.


Block valves are located along the pipeline to limit the amount of piping that may need

to be depressurized for tie-ins and maintenance and to reduce the amount of gas that

would be lost in the event of a line break.

36 stand-alone BSs are proposed along the Pakistan section of the TAPI pipeline. On

average, each BS will have a footprint area of approximately 15,000 m2

2.5.3 Access Roads

The location for camps and pipe yards were identified during the FEED stage based

on the following selection criteria:

· Proximity to the pipeline;

· Availability of existing road infrastructure; and

· Security considerations.

The locations need to be further evaluated and confirmed by the EPC Contractor

during detailed design.

Access roads to AGIs were also identified during FEED using the same selection

criteria and need to be further evaluated and confirmed during detailed design. The

details of the proposed access roads, based on preliminary Project information, are

provided in Appendix A. The majority of new and upgraded roads proposed will lead

through barren land; however, a number of the new roads will lead through natural

vegetated and cultivated / planted land. Most of the access roads will be removed

following construction and the land will be reinstated to previous conditions prior to

commencement of operation. Depending on the needs of the local communities,

certain access roads may be left in place. Discussions are ongoing with local

authorities.

The number of temporary access roads to the pipeline ROW is not yet defined. This

will be done during detailed design.

All key material will be shipped through Turkmenbashi, then onwards to the

Turkmenistan-Afghanistan border and Project area by road.

2.6 Phase I Project Activities

2.6.1 Phase I Construction

2.6.1.1 Overview

Construction methods will be based on best available engineering design and

construction planning information at the time of drafting this document. Construction

methods and activities are further detailed herein.


As summarized in Table 2-1, the construction period is expected to be 33 months.

Where required, parallel contractors and teams will work simultaneously to ensure

construction works are completed in the timeframes required.

2.6.1.2 Pre-Construction

Pre-construction activities that will be carried out by the appointed Contractor prior to

the start of the Project construction activities include (ILF, 2017):

· Pipeline route finalization;

· Detailed design finalization;

· Pre-construction survey for the determination and assessment of detailed

construction quantities, specific construction methods, required resources and

equipment, and overall planning aspects for the performance of the construction

works. This survey will determine special construction measures, crossing

methods, and methods for work in environmental sensitive areas. It will form the

basis for the construction procedures and work method statements, which will in

turn define the construction works in detail;

· Survey of depth of topsoil to prepare for careful removal and separate storage;

· Planning of the construction works, including manpower and equipment / material

resources;

· Preparation of construction drawings, including allocation of hot bends, method

statements and work procedures;

· Pre-construction environmental mitigation works;

· Agreements with landowners on any special requirements prior to entry onto their

properties; and

· UXO survey and mine clearance for the pipeline, AGI, temporary installations,

and newly constructed access roads, including identifying, marking, and

clearance of UXO and explosive remnants of war from the PAI to a safe location

for disposal.

2.6.1.3 Pipeline Construction

The pipeline will be assembled as a series of linear spreads, as discussed in

Section 2.5.2 and summarized in Table 2-3, which will move along the route at

2,500 m per day (depending on manual or automatic welding technology) (ILF, 2017).

Table 2-3: Construction Approach

Spread Length

Spread 1: KP 815.8 – KP 977.0 161,200 m

Spread 2: KP 977.0 - KP 1170.0 193,000 m

Spread 3: KP 1170.0 - KP 1299.0 129,000 m

Spread 4: KP1299.0 – KP 1438.0 (including Indus and Chenab Rivers) 139,000 m

Spread 5: KP 1438.0 – KP 1634.6 (including Sutlej River) 196,600 m

Source: ILF, 2017c


A typical pipeline spread is a unit of equipment and personnel required to construct a

pipeline. Individual operations, each performed by a specially trained crew, usually

proceed in a definite sequence as follows (ILF, 2017):

· ROW preparation, as follows:

- access roads to enable ROW crews to access the working areas where

access from public roads is not available;

- clearing of existing obstacles once the centerline and boundary of a section

is marked / staked;

- drainage systems that cross the ROW or pipe trench will be cut and closed

off or connected to new drain collectors, leading to next suitable discharge

location. All drainage cut-off works will commence immediately after the

ROW clearing;

- grading will comprise of a crew of personnel and equipment including mainly

large heavy tracked dozers and excavators to form the right of way onto the

land;

- top soil stripping prior to excavation. The topsoil containing the seeds needed

for post construction bio-restoration will be carefully removed and stored

separately;

- preparation of the construction road, bridge or flume pipe access, protection

of existing services by excavator mats, re-grading of existing ground

contours to assist access, the erection of goalposts and safety signs at

overhead electric power lines and telecommunication cables, the placement

of hard standings as required for car parking and the controlled

blasting/removal and re-grading of rock areas or outcrops to provide a level

and safe excavation line/temporary construction road along the entire

pipeline route. If controlled blasting will be required for preparation of ROW,

written approval of the local authorities, supervising authorities or entities,

and TPCL will be required;

- secondary ground investigations will involve the Contractor confirming and

evaluating the possibility of excavating the soil by secondary geotechnical

ground investigations based on available geotechnical information; and

- pre-construction terrain and ground stability at locations where there is a risk

of ground movement that could result in safety risks to the construction

activities;

· Stringing of the line pipes will be undertaken once the ROW has been prepared;

· Bending will take place in parallel to stringing, where the bending surveyor will

engineer the cold bending required for pipeline installation to follow the contours

of the land and the required line and level as details from the bending survey;

· Welding of the pipeline will commence a few days after stringing and cold

bending. Double jointing would be carried out prior to pipeline stringing, with

double jointing welds performed with a fully automatic weld. Welding will take

place following manual and automatic methods depending on various

requirements;


· NDT inspections will be carried out on all welds on the pipeline, using a

combination of the principle methods of Radiography and Automatic Ultrasonic

Testing;

· Field joint coating will be undertaken to prevent corrosion starts a few days after

welding;

· Trenching will be undertaken in accordance with secondary ground

investigations, including trial hole surveys, where classify the ground is classified

in ease of exaction. Depending on the soil classification and availability of

equipment trenching will be undertaken with the use of medium-sized excavators,

large and powerful excavators, ripping / hydraulic hammer, controlled

blasting/hydraulic hammer, or wheel trenchers. If controlled blasting is required

for preparation of trench, written approval of the local authorities, supervising

authorities or entities, and TPCL will be required;

· Lowering in of the pipe into the trench. Before lowering can take place, pipe

bedding material will be placed at the bottom of the trench, which will consist of

stone free material. At this point, the pipeline will be inspected for any damages

to the pipe coating prior to the pipe entering the trench;

· Backfilling of the trench will start immediately following the placement of the line

pipe in the trench and the undertaking of the as build survey. The pipeline will be

bedded on fine-grained, stone free material. The thickness of the bedding later

will be approximately 30 millimeters (mm) thick;

· As-built survey will be undertaken of top of pipe at each pipe joint in three-

dimensional (3D) coordinates; and

· Reinstatement of areas along the ROW will be undertaken. The current approach

is to acquire a 38 m wide construction ROW on a permanent basis. With regards

to reinstatement, it needs to be distinguished between the core area of 8 m over

and adjacent to the installed pipeline where the permanent pipeline road will be

constructed, and where the remaining area that will be reinstated but not

revegetated, as it will not be allowed, and the remaining areas on either side of

the pipeline that will be reinstated and vegetated.

The regular working strip as shown on Figure 2-2 requires a width of approximately

38 m, consisting of 20 m on the side boom side (including second lane) and 18 m on

the side boom opposite side (storing of excavated soil and storing of top soil). In areas

where there are construction constraints (for example, environmental or land use

constraints) and in general where limited room is available, the working strip may be

reduced from 38 m to 28 m (ILF, 2017b).


Figure 2-2: Pipeline Construction – Regular Working Strip

Source: ILF, 2017w

2.6.1.4 River, Canal, and Karez Crossings

The proposed pipeline will cross 863 rivers and 345 canals of different widths (as

detailed in Appendix C3), and approximately two karezes based on aerial images.

The majority of river crossings will be undertaken using open-cut., two major rivers

(namely, the Chenab and Sutlej) are foreseen to be crossed via a pipe bridge, and

the Indus River is recommended for HDD.

2.6.1.4.1 Open-Cut

Open-cut is undertaken by means of an open excavation, as indicated on

Figures 2-3 to 2-6. This method is best employed when the rivers are dry; otherwise,

diversion of water flow upstream and downstream will be undertaken. The trench in

the river will be excavated for the full length of the crossing prior to the installation of

the pipe. Excavated materials will be reused for bedding and backfilling as far as

possible. The surface (river or stream bed) is then reinstated close to its original

condition after the trench is backfilled.


Figure 2-3: Schematic of a Typical Open-Cut of Small Watercourse

Source: CAPP, 2005

Figure 2-4: Schematic of a Typical Open-Cut of Large Watercourse

Source: CAPP, 2005


Figure 2-5: Typical Crossing Drawing – Open-Cut of Small Watercourse

Source: ILF, 2017ab

Figure 2-6: Typical Crossing Drawing – Open-Cut of Large Watercourse

Source: ILF, 2017ac

2.6.1.4.2 Pipe Bridge

A pipe bridge comprises a series of vertically and horizontally aligned, reinforced

concrete pillars topped by a concrete cap structure, as indicated on Figure 2-7. The

pillars are founded on reinforced concrete piles. The length of the piles depends on

the load, the soil conditions and the expected scour depth. Rollers are installed on top

of the pillar cap, which support the future gas pipeline. During pipe installation, the

pipe string will be pulled in from one side to the other onto the rollers. It is

recommended to construct the piles during dry season when active channel shrinks

to the minimum possible width and maximum proportion of work may be completed

on dry land. In active channel special barges are used to support the equipment. The

entire length of the above ground pipe is exposed to temperature variations. These

variations in temperature produce expansion and contraction of the pipe. In order to

keep the crossing free of the stresses induced by a restrained pipe, expansion


S-structures will need to be installed at the two ends of the crossing, which absorb

the thermal effects.

Pipe bridges are the chosen method for the Chenab and Sutlej Rivers as there is local

experience and equipment are available. A difficulty in employing HDD tunneling

techniques at these major crossings is their large width and the huge volumes of water

and associated scour effect associated with certain times of the year. Water use for

the HDD is estimated at 20,000 m3. The technical feasibility of tunneling under these

circumstances is uncertain.

Figure 2-7: Schematic of a Typical Pipe Bridge

Source: ILF 2017aa

2.6.1.4.3 Horizontal Directional Drilling

The Indus River has high environmental sensitivity, with critical habitat

characterization in the crossing area due to the presence of the Indus Dolphin. HDD

will be used at the Indus River crossing.

HDD is an alternative technology used for long crossings where trenching or open

excavation is not feasible or where the environmental impacts of open-cut is not

acceptable (Figure 2-8). With HDD, the pipeline is bored under the crossing to emerge

at a target point on the opposite side. A large area of temporary land is required on

either side of the proposed crossing to accommodate the equipment, drilling fluid

management system, and laydown area for the pipe. HDD gives a good degree of


accuracy; however, due to over cutting of the tunnel, a small amount of settlement

can be experienced.

Installation of an open-cut crossing can take anything from one to three working days,

with minimal periods of in-stream activity. HDD typically requires more time than open-

cut crossing. In addition, a larger area is needed for HDD pipe laydown than for open-

cut crossing. Another disadvantage of HDD is that drilling muds, such as fluid

bentonite clay, are used which are forced down the hole to stabilize the hole and

remove soil cuttings. Bentonite is an inert material which has to be handled carefully

to avoid impacts to the watercourse being crossed.

Figure 2-8: Schematic Sequence of HDD Method

Source: ILF 2017aa


Karezes

The current estimated number of karez crossings is two, based on interpretation of

aerial images collected by detailed geohazard mapping. More detailed information will

be collected during detailed design and pre-construction surveys.

All known karezes will be included in the Special Crossings List for special

consideration by the EPC Contractor. The EPC Contractor will be required to:

· Identify and mark all karezes along the pipeline route;

· Investigate the orientation, extent, and current level of use of each identified

kareze;

· Provide a work execution plan for crossing or working near a karez; and

· Consult the local communities and authorities on the best way forward.

2.6.1.5 Above Ground Installation Construction

The following construction steps will be undertaken for the AGIs:

· Surveying;

· Preparation of the construction site;

· Earthworks;

· Preparation of foundations (including piling where required);

· Erection of equipment and buildings (installation of underground structures might

require the use of sheet piling for stabilization of construction pits);

· Laying of cables and electrical works;

· Piping and mechanical works; and

· Installation of operational and instrumentation systems.

2.6.1.6 Machinery and Equipment Transportation

Although the Project is large in scale, it will be a conventional civil engineering project,

and will not require unusual or unfamiliar equipment or construction techniques.

Machinery and equipment required will include dozers, excavators, graders, soil

removal trucks, large, heavy lift cranes, standby generators, bending machines, side

booms/pipe layers, welders, and pay loaders (ILF, 2017).

Key equipment requirements for a typical pipeline spread, as minimum, are presented

in Table 2-4. More equipment may be required and will be included in the final

equipment plan during detailed design.

Table 2-4: Key Equipment Requirements for a Typical Main Spread

Construction Sequence Equipment

ROW Preparation · 4X4s and pick-up trucks

· Dozers, Cat D8 or equivalent

· Excavators, Cat 235 or equivalent

· 1 Grader

· Refueling truck

· Water bowser


Construction Sequence Equipment

Stringing · 3 Dozers, Cat D8 or equivalent

· 10 Trucks 6 x 4

· 4 Mobile cranes

Bending · 2 Bending machines

· 4 Side booms

Welding and NDT · Automatic welding spreads

· Paywelders (with 4 welding services)

· 4 Side booms

· 1 Excavator

· 1 Automatic Ultrasonic Testing equipment (6 x 4 mounted cabin)

Trenching · 6 Excavators, Cat 240 (40 tons) or equivalent

· Trenching machines (wheel or chain trencher)

Lowering-In · 2 Welding services (4 welders)

· 6 Side Booms

Tie-Ins · Use of lowering crew (part time) in addition required:

· 2 x 2 Pipe layers

· 2 x 2 Welding sources (2 x 2 welders)

Bedding and Padding · Mobile sieving plant

· 2 Payloaders Cat 966 or equivalent

Backfill · 2 Dozers, Cat D8 or equivalent

· 3 Excavators Cat 235 or equivalent

Reinstatement · 2 Dozers, Cat D8 or equivalent

· Excavators Cat 235 or equivalent

· Smaller size equipment (e.g. tractors) for reinstatement in agricultural areas

Source: ILF, 2017

2.6.1.7 Construction Logistics

Equipment and material for construction will be transported by truck using existing

and new infrastructure.

The total steel pipe weight exceeds 700,000 tonnes. Shipping of pipes will be to the

Port of Karachi or the Port of Bin Qasim. There will be five pipe yards along the route

and the main national highways utilized will be the N25 through Balochistan and the

N5 and N55 through Sindh and Punjab. Vehicle movements will be required to move

the steel pipe to the pipe storage yards, which will have a large impact on traffic on

these major routes for up to an 18-month period.

There is expected to be a minimum of 65 laden trucks leaving the Main Marshalling

Yard situated close to the ports on a daily basis during this period. This does not

include unladen vehicles returning to the port or vehicles collecting pipes directly from

the vessel and delivering to the Main Marshalling Yard. This will equate to an

additional 65 to 70 truck movements on the main highways and up to 400 individual

short truck movements per day between the vessel and the Main Marshalling Yard.

In addition, there is expected to be significant transportation requirements for each

pipeline spread along the route. In order to keep the transport logistics and the camp

installation efficient, the different work steps will follow in short distance / timing of

each other to keep the pipeline construction in compact shape, restricted and

controlled length. (ILF, 2017).


Large earth moving machinery and other special items of equipment will be required

to prepare the construction working strip, to excavate the trench and lay the pipeline.

Based on experience of other similar pipeline construction projects, the following

indicative estimates of additional construction traffic are predicted:

· Approximately 30 two-way light vehicle movements (60 movements) per day to

transport workers to site (from the construction camps to construction area);

· Approximately 5 truck movements per day to move construction equipment

(where possible, construction equipment will be transported along the

construction working corridor);

· Approximately 50 two-way truck movements (100 movements) per day to bring

material to the construction working corridor (such as pipes and sand for

bedding); and

· Approximately 10 two-way truck movements (20 movements) per day to take

material away from the construction working corridor (such as excavated rocks

that cannot be backfilled, clearing, and grading timber).

A Traffic Management Plan detailing all issues pertaining to access, traffic, and

transport will be developed by the EPC Contractor in consultation with the competent

authorities and implemented throughout construction. A Traffic Management

Framework has been developed, as presented in Appendix F, to serve as guidance

for the EPC Contractor in developing the detailed plan.

2.6.1.8 Construction Camps and Pipe Yards

Pipe yards are for security reasons proposed to be located as close to construction

camps as possible and aim to fulfil the following requirements (ILF, 2017v):

· Sufficient storage yard capacity;

· Suitable location in flat terrain;

· Appropriate access to the main roads ensuring reliable and immediate receipt

and supply of pipes;

· Handling and transportation equipment will meet specific requirements;

· Trained labors for safe and secure handling and transportation of line pipes and

other materials;

· Appropriate design suitable to the existing road infrastructure / ground pavement;

and

· In order to avoid extensive improvements of the ground due to poor conditions,

appropriate handling equipment will be selected. Such equipment may require

international sourcing and a considered additional lead-time.

All key material such as pipes, components of the CSs, and special construction

equipment will be shipped to the Port of Karachi or the Port of Bin Qasim (ILF, 2017v).

Construction camps and pipe yard locations have been proposed based on the

following criteria and assumptions (ILF, 2017):


· Camps and pipe yards to be located close to each other if possible (security

issues);

· Camps and pipe yards to be located at future AGIs (land allotment issue);

· Camps and pipe yards will serve approximately 100,000 m length of pipeline

construction;

· Camps and pipe yards will be located close to large river crossings;

· The requested area for a camp housing 500 people has been estimated with

approximately 70,000 m2;

· The requested area for a pipe yard (including area for pipe bending and some

spare area) has been estimated as approximately 315,800 m2 inside the 500 m

corridor and 1,768,500 m2 outside the 500 m corridor;

· Camps and pipe yards will be located in plain area if possible and outside of

seasonal water flows (such as gullies); and

· Camps and pipe yards will be located as close as possible to public access roads.

One combined Construction Main Camps and pipe yard location and two Satellite

(Fly) Camps will be provided for each of the five pipeline spreads (that is, a total of

five Construction Main Camps and ten Fly Camps will be established in Pakistan for

the Project).

The Construction Main Camps will comprise temporary residential units, medical

facilities, parking lots, warehouses, laydown and working areas, and material storage

areas. The camps will be securely fenced self-contained units with their own

generators, kitchens, and packaged sewage treatment plants.

The construction camps will vary in size depending on the activities they support. The

Construction Main Camps (supporting between 500 and 600 people) are needed to

accommodate the construction spread crews.

All construction camps are temporary facilities and the life of the camps will be

dependent on the activities they support. The camps will typically be operational for

between 6 to 12 months but may extend up to as long as 36 months.

Proposed locations of all Construction Main Camps and Fly Camps are presented in

Table 2-5. The proposed location of Construction Main Camps, which will also

accommodate pipe yards, are shown on Figure 2-1. The location and size of additional

camps are still being considered and a final decision will be made on appointment of

the EPC Contractor.

Table 2-5: Proposed Location of Construction Camps and Pipe Yards

Spread Name (Type) Approximate KP

within Pakistan Latitude Longitude

1 PAK-SP1-CMP1 (Main, with pipe yard) KP27.5 30º48’ N 66º36’ E

PAK-SP1-CMP2 (Fly) KP81.5 30º30’ N 66º59’ E


2 PAK-SP2-CMP1 (Main, with pipe yard) KP190 30º30’ N 68º01’ E

PAK-SP2-CMP2 (Fly) KP254 30º19’ N 68º36’ E



Spread Name (Type) Approximate KP

within Pakistan Latitude Longitude

3 PAK-SP2-CMP1 (Main, with pipe yard) KP377 30º28’ N 69º43’ E









Note: The locations presented in this table are approximate and subject to re-confirmation by TPCL and

EPC Contractor after the Contract Effective Date.

Source: TPCL, 2020

2.6.1.9 Services and Utilities

Where sites are established close enough, and there is sufficient capacity, services

and utilities (including water supply, wastewater and sanitation services, electricity

supply, potable water supply, and solid waste management) will be purchased from

local suppliers. Local utilities will be commissioned to extend transmission lines or

water pipes to worksites. Where local capacity is insufficient, contractors will establish

their own site facilities. Fuel, lubricants, and other chemicals required for the operation

of construction machinery and vehicles will likely exceed local supply capabilities and

will need to be imported.

2.6.1.10 Workforce

It is estimated that at least 25% of the workforce on the Project will be made up of

local people. The staffing of an individual pipeline spread, such as management,

administration, and engineering, is estimated in the order of 600 to 700 people (ILF,

2017). With a total of five spreads, this will equate to approximately 3,000 to 3,500

people employed during the construction phase in Pakistan.

2.6.1.11 Use of Resources and Project Emissions

2.6.1.11.1 Raw Material

The following materials are, or can be, produced locally:

· Sand, as fill material for road embankments, levelling terrains, production of

concrete, and infill of the trench;

· Rock and gravel, for the same purpose as sand, in addition to slope protection);

· Wood, for skids during stringing and welding;

· Cement, for various structures and buildings;

· Gas, as raw material to be transported; and

· Diesel (a couple of thousand liters [L] per day during construction).


The major quantity of raw materials will be consumed during the construction phase

of the Project, which typically consist of steel, concrete, gravel and wood. At this

stage, no quantities estimations of raw materials are available.

In order to avoid any damage to the pipeline coating, the bottom of the trench and the

padding material consist of well-graded, round material. If the excavated material from

the trench is suitable (such as sandstone), it will be recycled for bedding and padding.

Sand and aggregate will be obtained from local designated and approved sources.

Wood should be sourced from plantation forest. The use of wood from natural forests

or hardwood is to be avoided.

Where excavation disturbs topsoil, the first layer of excavated material (topsoil) will

be stored separately so that it can be replaced on the surface when the excavated

area is restored.

All equipment and machinery, fuel, lubricants, and other chemicals required for the

construction activities will be imported.

The total steel pipe weight exceeds 700,000 tonnes and will require various suppliers

for line pipes. This will enable a diversity of supply route and the possibility of delivery

to country by rail and sea.

2.6.1.11.2 Water Consumption

Water needed during Phase I construction includes the following:

· Drinking water. Based on experience from similar construction projects, the

amount of drinking water required is approximately 3 L per person per day.

Assuming an average number of around 3,000 people (600 people per spread),

this will amount to a daily consumption of drinking water of 9,000 L per day

(1,800 L per spread). As the availability of clean drinking water in the Project area

is likely to be very limited, it is suggested that, as on other construction sites,

drinking water be brought on site by a vendor. Typically, large canisters of

drinking water are supplied. Empty canisters will be taken offsite by the vendor

and replaced with full ones;

· Water for canteens. An average volume of 20 L per person per day will be needed

in the canteens. The water quality will be of drinking/potable water standard that

meets national requirements. As the availability of drinking/potable water in the

Project area is likely to be very limited, it is likely to be tankered in / brought on

site by a vendor. Assuming an average number of around 3,000 people (600

people per spread), the expected water demand for this purpose is 60,000 L per

day. As there are five spreads, a total of 12,000 L per day per spread will be

needed during the whole construction period;

· Water for sanitary facilities. An average volume of 100 L per person per day will

be needed for sanitary facilities. For water uses where staff will not be in direct

contact with the water, such as flushing toilets, the quality of the water does not

need to be of drinking/potable water quality, but it will need to meet national


standards. This water will either be sourced locally or tankered in, in agreement

with the communities and authorities. Assuming an average number of around

3,000 people (600 people per spread), the expected water demand for this

purpose is 300,000 L per day for the whole construction period (60,000 L per

spread); and

· Water for miscellaneous construction activities. The amount of water required for

construction activities will be calculated by the EPC Contractor during detailed

design. It is likely that for some of these activities, and especially for measures

such as dust suppression, grey water from the canteens and sanitary facilities

can be used. Again, this will need to be agreed with the authorities.

Table 2-6 provides a summary of the types and approximate quantities of water

needed during Phase I Construction.

Table 2-6: Phase I Construction Water Needs

Water Needs Rate / Day Volume / Day Quality Standard Likely Source

Drinking Water 3 L / person 9,000 L Drinking/potable

water

Brought on site by vendor

Water for

Canteens

20 L / person 60,000 L Drinking/potable

water


Water for

Sanitary

Facilities

100 L / person 300,000 L Non-potable water,

meeting national

requirements

Either sourced locally or

tankered in, in agreement with

communities and authorities

Water for

Miscellaneous

Construction

Activities

To be calculated by EPC

Contractor during detailed

design

Standards as defined

in ESIA and/or

agreed with national

authorities

Source to be agreed with

communities and authorities,

most likely tankered in or

partially recycled grey water

from the canteens and sanitary

facilities (if water quality

standards are met)

2.6.1.11.3 Power Consumption

For the execution of the works and transport logistics, several bulk equipment,

including generators, will be required (ILF, 2017).

The TAPI member countries will only be able to produce part of the materials needed.

For example, cement and diesel might be in short supply, as there is a high demand

for these items, while the production/availability is limited, especially in remote areas.

It is likely that fuel and other materials will need to be imported. Based on experience

with similar projects, the estimated fuel consumption during construction for diesel

equipment and vehicles is in the order of 10 million gallons (over 40 million L).

2.6.1.11.4 Hazardous Materials

Hazardous waste (sometimes referred to as special waste) is defined as wastes that

constitute a high degree of hazard to humans and the environment. These mainly

include wastes that are flammable, corrosive, reactive, toxic, radioactive, infectious,

carcinogenic, mutagenic, or teratogenic.


Based on experience with previous pipeline projects, typical groups of hazardous

waste and an indication of their volume are as follows:

· Absorbents, filters, rags, and contaminated protective clothing (10 tonnes);

· Pipeline coating (polyethylene coating) (≤1 tonne);

· Packaging containing hazardous substances or contaminated with hazardous

substances (≤1 tonne); and

· Batteries and accumulators (≤1 tonne).

As part of the Waste Management Plan, the EPC Contractor will prepare a detailed

inventory of hazardous waste arising, plus estimates of volumes.

All national requirements will be met in handling and disposing of hazardous wastes.

Aside from the overarching Waste Management Plan, the EPC Contractor shall

develop and implement a specific Hazardous Materials Management Plan that

incorporates all the requirements and recommendations in the approved ESIA report.

A Waste Management Framework and a Hazardous Materials Management

Framework have been development, as presented in Appendix F, to serve as

guidance for the EPC Contractor in development the detailed plans.

General wastes generated on-site shall be stored in enclosed bins and normal waste

streams separated from hazardous waste streams. Hazardous wastes will be stored

in a secured area (to prevent vandalism, theft, and accidents) and be within a covered

area to prevent the ingress of rain. Logistical provisions will be made with the

authorities and a local contractor to remove general refuse from the PAI on a daily

basis to minimize odor, the attraction of pests, and litter impact. These actions shall

be documented in the Waste Management Plan (Penspen, 2015b).

2.6.1.12 Waste Management

2.6.1.12.1 Overview

Construction wastes as well as waste and effluents generated by pigging and other

pipeline maintenance activities are expected to represent a potential threat to the local

environmental quality.

In general, waste management will be carried out in line with the legal framework and

under consideration of international good practice principles. All waste materials will

be collected, stored, and transported separately in appropriate and approved bins and

containers.

Companies certified by the relevant authorities will be used for the transportation,

recycling, and disposal of wastes. The overall objective is to minimize the impacts of

waste generated during the construction phase through the following:

· Minimize the amount of waste that is generated;

· Maximize the amount of waste that is recovered for recycling, including

segregation of recyclable wastes at source;

· Minimize the amount of waste that is deposited at landfill;


· Ensure any hazardous wastes (such as used oils and lead-acid batteries) are

securely stored and transferred to appropriate facilities;

· Avoid dust impacts from handling of construction wastes;

· Ensure all wastes are properly contained, labelled, and disposed of in accordance

with local regulations; and

· Ensure waste is disposed of in accordance with the waste management hierarchy

in order of preference as follows: reduce, reuse, and recycle.

A construction waste management strategy will incorporate the following good site

practices, which will aim to reduce the risk of impacts arising from waste management

activities. The construction waste management strategy will cover the following key

aspects:

· Development of inventory and schedule of likely waste generation;

· Assessment of local waste management facilities;

· Waste minimization principles;

· Maximization of reuse and recycle opportunities;

· Waste segregation (liquid and solid, reusable and recyclable);

· Waste collection, storage, and transfer;

· Specific disposal procedures for all waste steams identified, including waste

transfer notes if moved to a licensed offsite facility;

· Auditing and reporting procedures; and

· Closure process, including appropriate monitoring and recording.

Most of the excavated soil will be used to backfill the pipeline trench. Excess soil will

likely be spread out and contoured along the route in agreement with competent

authorities and according to further engineering studies. Wastewater and solid waste

from the construction camps will also be generated. Wastewater package treatment

units will be installed at the construction camps.

Waste generated during construction is likely to be classified into four categories for

disposal, as follows:

1. Inert - These will include wastes such as soil (not including excavated material,

which is destined to be backfilled when the area is restored), building rubble, and

unused construction material generated during preparation and restoration of

worksites. These wastes pose no risk of pollution but may be unsightly and need

to be disposed of at a controlled disposal site;

2. Domestic - The offices and administration buildings associated with the worksites

and the construction camps will generate domestic waste such as food scrap,

paper, and packaging. These will be transported to a controlled municipal waste

disposal site;

3. Oily and Hazardous - These will include oily wastes associated with vehicle

maintenance (such as waste oil and material collected from wastewater

interceptors), unused or waste chemicals, paints, and solvents, materials

excavated from contaminated sites (if any), and any other wastes, sludge, or


debris that are unsuitable for disposal in a municipal landfill. Such wastes will be

segregated for collection and disposal by specialist contractors at sites that are

equipped and approved for such wastes; and

4. Liquid - These will include hydrotest water from the pipeline sections, black and

grey water from construction camps, hazardous liquid wastes (such as oils and

solvents), and rainwater runoff from sealed surfaces and roofs.

2.6.1.12.2 Liquid and Solid Waste Types and Quantities

Typical waste types generated during the construction of the pipeline are presented

in Table 2-7. Generated waste types and estimated quantities are assumed based on

experience gained from similar projects and the current status of design.

Table 2-7: Typical Wastes Generated during Construction of the Pipeline

Construction Activity

Typical Waste Type Estimated Quantity Disposal Method

Working width

preparation

Hedges, timber,

vegetation, fence posts,

and wires

Unknown In accordance with applicable

legislation

Pipe string and

bending

Pipe bands and end

caps

Unknown Collect in skips and send to

licensed waste disposal or

recycling site

Welding, testing, and

coating

Spent welding rods,

grinding wheels, visors,

and shot-blast

5 to 10 tonnes per

week per construction

spread

Collect in covered skips or tipper

trucks and send to licensed

waste disposal site

Trenching, lowering,

and laying of pipeline

Soil and rock Approximately

2,400,000 m³ for the

whole pipeline route

Set aside to be used in

backfilling. Excess quantities

used to restore abandoned

quarries, in coordination with

authorities

Backfilling and

grading

Surplus spoil and rock Up to 3,000 tonnes per

day per construction

spread (based on

600 m backfilling per

day per construction

spread), dependent on

ground conditions

Subject to landowner or

occupier’s agreement. Reuse if

possible or take to licensed

waste disposal site.

Reinstatement Temporary stone roads Unknown Reuse elsewhere within

landholding

Miscellaneous Temporary fencing,

gates, and troughs

Unknown Reuse if possible

Thrust-boring Spoil and rock cutting. Up to 900 tonnes

(dependent on whether

used).

Dispose of using road truck

tankers to licensed waste

disposal site

Mess huts,

miscellaneous

Canteen refuse and

safety equipment

2.5 to 10 tonnes per

week per construction

spread

Collect in covered skips and

send to licensed waste disposal

site

Mobile site toilets Sewage Approximately 20

emptied per week per

construction spread

Disposal by appointed waste

management contractor


2.6.1.12.3 Wastewater Discharge

The following types of wastewater were taken into consideration in developing the

drainage philosophy:


· Uncontaminated storm water;

· Sanitary wastewater; and

· Oily water.

The drainage system will provide a safe and reliable method for the collection and

controlled disposal of flammable and non-flammable wastewater released during the

construction phase of the Project.

2.6.2 Phase I Commissioning/Start-up

Project activities and sequence of operations during the commissioning/start-up

phase typically include the following:

· Pre-commissioning:

- hydrostatic testing (or hydrotesting) of pipelines;

- flushing and cleaning of pipelines; and

- system dry-out;

· Commissioning:

- systematic conformity check of equipment;

- static, de-energized test of equipment;

- preliminary check;

- functional check;

- operational test; and

- pre-start-up activities.

2.6.2.1 Hydrotesting

Hydrotesting will be carried out to ensure that the installed pipeline complies with the

appropriate regulations and can be declared fit for its intended use.

If possible, water for hydrotesting will be from sourced along the route, otherwise

groundwater will be considered. Additional boreholes will be drilled to access

groundwater if needed, avoiding impacts on local water reserves. Management of

hydrotest water sourcing is addressed in the Hydrotest Environmental Management

Framework in Appendix F. In keeping with environmentally sound good practices and

industry standards, the EPC Contractor will ensure that, while protecting the pipeline

integrity and safety of personnel, no damage is done to the environment through

disposal or discharge of hydrotest water.

The quality of the source water used for the hydrotest will be analyzed by the

EPC Contractor at an accredited laboratory and the report will be delivered to TPCL

for approval, prior to hydrotesting activities. Depending on the water quality and

expected residence time in the pipeline, it may be necessary to chemically treat the

water to prevent biological growth and inhibit oxidation/corrosion of the internal pipe

surface. The addition of the chemicals to the hydrotest water will be subject to close

scrutiny and control and will always be done in a manner that minimizes the amount


of additions. An environmental permit will be obtained for all water abstraction and

discharge associated with the hydrotests.

In case of application of chemicals and oxidizers, TPCL shall be required to approve

any chemical additives (ILF, 2017u). The EPC Contractor shall identify in their

application procedure adequate water treatment processes and disposal methods of

such additives in a safe and environmentally responsible manner, according to

approved procedures and in line with permit guidelines and stipulations. This shall

also include how to protect the workers handling such additives. Management of

additives and discharges are addressed in Hydrotest Environmental Management

Framework in Appendix F.

The maximum length of a hydrotest will depend on the accuracy of the instruments

and the duration of the tightness test (at minimum 1.1x design pressure).

Nevertheless, the maximum hydrotest section length shall not exceed 12.5 km. Water

use for hydrotesting is estimated at 100,000 m3 and will be greatly dependent on the

successful reuse of hydrotest water between sections.

The pumping and discharge end for each hydrotest section will be located at least

500 m from local communities, wherever practical to do so.

2.6.2.2 Dewatering, Pigging/Swabbing, Geometric Measuring, and Drying

On completion and successful acceptance of the hydrotest, water will be removed

from the pipeline by swabs propelled by dry and oil free compressed air. Where

possible, hydrotesting water will either be reused in the next hydrotest section or

disposed of according to national environmental requirements. After the cleaning

process, an electronic caliper device will be employed to identify potential ovalities

and dents in the pipeline. If unacceptable ovalities or dents are detected, the

respective pipeline section will be excavated and repaired.

2.6.2.3 Reinstatement and Clean-up

Reinstatement will be performed in three distinct phases depending on the phase

objective, including slope stabilization and erosion protection, surface reinstatement,

and bio restoration. All temporary material, such as trench supports, will be

systematically removed from the construction easement area. Subsoil will be levelled

to its original contour or as determined by operational requirements. Any surplus pipes

will be delivered to the EPC Contractor’s storage yards. There will be a general

commitment to either leave the temporary access roads or remove them with a

provision for retaining sufficient access roads to ensure safe operation.


2.6.3 Phase I Operation

2.6.3.1 Operation Philosophy

The primary objective of the operating and control philosophy is to provide the basis

for safe, reliable, and efficient pipeline operation with an optimum of operations and

maintenance personnel, consistent with current practices in the pipeline industry.

The main target of the TAPI pipeline is to ensure the availability of the gas, with the

requested capacity and pressure and at the required time, from Turkmenistan to the

defined off-take points in Afghanistan and Pakistan and finally to the Pakistan-India

border (ILF, 2017x).

The land in the permanent ROW will be leased from the government and land use

restrictions will apply, including prohibition of all physical settlements of any kind. The

economic restrictions of land within the permanent ROW, in terms of agricultural uses,

have not yet been confirmed with the government. However, it is likely that certain

agricultural activities, including grazing and hay-making, may be able to continue

across the majority of the ROW, whereas ploughing and deep-rooted crops will not

be allowed.

To achieve the main target of the TAPI pipeline, the pipeline system will be

continuously monitored and controlled by the Main Control Center (MCC) / Back-up

Control Center (BCC) located within the Turkmenistan territory, or the Local Control

Center (LCC) located in Pakistan. AGIs along the pipeline will be provided with

Process Control Systems (PCS) and Fail-Safe Systems (FSS), which form an

integrated part of the Station Control System (SCS) with the following purpose:

· Guarantee a reliable control and safety system;

· Provide a consistent and homogenous interface to the operators that will allow

them to adequately and safely control and operate the facility; and

· Provide sufficient information from packaged equipment to operations to ensure

safe and adequate control of the facility.

The main responsibilities of the MCC or BCC will be, among others:

· Manage and plan the transport of the gas, on the basis of seasonal import pro-

grams, provision of consumptions, and fluctuations of the weekly or daily

demands (gas demand may be subject to sudden fluctuations due to unexpected

abnormal weather conditions, peak requests from industrial production, or

temporary unavailability of other gas import lines);

· Ensure the activation of safety measures, either acting by means of the control

systems or the direct intervention on field by specialized teams;

· Surveillance on the pipeline;

· Implement the maintenance plan for the facilities: plan and execute periodic

checks and maintenance programs on plants, equipment and pipeline to ensure


their integrity, safe operation, periodic updating to be compliant to new governing

codes;

· Plan and execute pigging programs for the cleaning purpose and for pipeline

integrity monitoring; and

· During maintenance or in case of communication breakdown, operation of the

pipeline can be controlled by the LCC located in Pakistan.

The starting point for the operation of the pipeline system is the preparation of the

Gas Transport or Dispatching Plan stating the gas throughputs during the established

operational periods. For each operational period (seasonal, weekly, daily), the Gas

Transport Plan will confirm the target gas throughput and will set the relevant

parameters governing the flow (pressures, number of stations in operations, number

of units in operation). The Gas Transport Plan will have adequate flexibility so as to

permit the pipeline operators to face unexpected situations, such as:

· Increased gas demand due to requirements of the end-users (such as unplanned

industrial production requests); and

· Interruption of the supplies or decreased transport capacities due to failures in

the system.

Therefore, the driving principles of the operation philosophy and the relevant control

philosophy will provide the Supervisory Control and Data Acquisition (SCADA) system

with the following features and capabilities:

· Measure gas flows at the entry point, delivery points, and off-take points;

· Remotely or locally control OSs, MSs, BSs, and SSs according to defined modes;

and

· Perform simulations and forecasts of gas consumption and transportation needs

to define and set the operating arrangement of the transport system.

Operational data gathering, archiving, and simulation capabilities are necessary

facilities prescribed by the operation philosophy.

The following principles will be set to guarantee the operation of the pipeline:

· Maximum automation and pre-configured options with maximum support of

automatic sequences, to minimize the intervention of humans to maximize

efficiency, performance, safety, and revenues, and to minimize operating costs

in accordance with the Project philosophy;

· Centralized remote control of the pipeline from the MCC by default or from the

BCC or LCC in exceptional cases, including the CS at Turkmenistan-Afghanistan

border, and of all BSs, OSs, and MSs, by skilled and experienced operators via

the pipeline SCADA system;

· The system operation will ensure the delivery of the target design flow rate; and

· The primary control parameter is station flow with maximum station discharge

pressure override at PAK-MS01 and all OSs.


Detailed operating procedures for the pipeline system will be developed. The

operating procedures will typically address the following:

· Report management;

· Online simulation / hydraulic modelling;

· Offline simulation;

· Predictive simulation;

· Inspection tool tracking;

· Leak detection and leak location;

· Metering and balancing tool;

· Dispatching; and

· Pipeline monitoring system (used to monitor and evaluate the operational

performance).

2.6.3.2 Emergency Response Procedures

TPCL will maintain a range of general emergency response procedures and

communication protocols that will apply across all locations.

Emergency response will be provided on two levels. The first level will apply to all

pipeline systems and will have the capability and resources immediately available at

all times to make the pipeline safe and minimize environmental damage or hazards

through spillage. The second level will provide the permanent or temporary repairs

required to put the pipeline back into operation. An Emergency Response Plan will be

developed by the EPC Contractor. An Emergency Management and Response

Framework has been developed, as presented in Appendix F, to serve as guidance

for the EPC Contractor in developing the detailed plan.

2.6.3.3 Operation Control Measures and Pipeline Safety

The overall pipeline operation, control, and monitoring will be carried out by default

from the MCC located on Turkmenistan territory, aimed at reducing manpower and

utilizing automated controls systems to the extent possible. An identical BCC will also

be established within Turkmenistan. The remote control of all pipeline facilities,

including CSs, MSs, BSs, and SSs, will be possible from the MCC, the BCC, or the

LCCs (corresponding local section only) (ILF, 2017c).

The pipeline will be monitored by a leak detection system that operates on the basis

of flow, pressure, and temperature monitoring, thereby detecting losses on an

automatic basis. Undetected leaks are a rare occurrence in modern gas pipelines as

leak detection systems allow immediate notification and action in an emergency.

2.6.3.4 Marking of the Pipeline and Ancillary Installations

The laid pipeline will be permanently marked by buried and aerial markers. In addition,

warning tape will be laid above the pipeline within the trench underground.


2.6.3.4.1 Pipeline Marker Tape / Mesh

Minimum width of the pipeline marker tape / mesh will be 300 mm, material

polyethylene, color yellow with a black imprint in English and local language stating

“WARNING - HIGH PRESSURE GAS PIPELINE” and an emergency telephone

number.

Pipeline marker tape / mesh shall be installed:

· Over the entire length of the buried pipeline;

· At a distance of 300 mm (+100 mm/-0 mm) above the top of the buried pipeline;

and

· Stretched out over its entire width.

2.6.3.4.2 Cable Marker Tape

The cable marker tape shall be installed when the cable is buried inside and outside

the pipeline trench.

Cable marker tape shall be installed:

· Over the entire length of the buried cable or cable conduit;

· At a distance of 300 mm (+100 mm/-0 mm) above the top of the buried cable or

cable conduit; and

· Stretched out over its entire width.

2.6.3.4.3 Pipeline Marker and Measuring Posts

The pipeline will be marked with markers along its entire route:

· On straight sections, marker and measuring posts shall be installed with an offset

of 1 m to the centerline and in flow direction on the right-hand side of the buried

pipeline; and

· Marker and measuring posts shall be installed prior or during the provisional

reinstatement of the ROW.

Marker posts shall be installed for the identification of the buried pipeline or

underground services and structures. The location of marker posts shall be identified

on the pipeline alignment sheets.

Marker posts shall be installed to allow the clear identification of the pipeline location

in the field, so as to reduce any potential interference or damage of the pipeline by

third-party activities.

The number of markers may be reduced wherever more facilities are running in

parallel, or in cases where Intelligent Pigging markers are closer than 50 m to another

marker. One marker shall respectively be set on each side of such a corridor.

2.6.3.4.4 Cable Marker Posts

Installation of marker posts for underground cables to anode ground beds shall only

be considered:


· Outside of pipeline stations; and

· If the cable is installed outside of the pipeline trench in a distance of more than

1 m from the pipeline and over a length of more than 10 m.

2.6.3.5 Monitoring and Maintenance

Monitoring and maintenance activities during the lifetime of the pipeline will include

clearing the 36 m permanent ROW (such as tree removal), exposing the pipeline if

required to ensure the coating and pipe are in good condition, performing necessary

repair work to ensure the safe operation of the pipeline, and placing pipeline markers

along the ROW to clearly identify that a pipeline is in the area. Furthermore,

monitoring and maintenance activities include aerial, vehicle, and foot patrols,

navigable waterway inspections, close interval and pipe-to-soil surveys, leak surveys,

mainline valve inspections, pipeline pigging, pipeline recoating if required, third-party

excavation monitoring, and routine maintenance on all pipelines and facilities.

Monitoring during the operation of the Project will include monitoring of flow, pressure,

and temperature along the pipeline route and in AGIs. Regular inline inspection will

be performed to identify areas where the wall has thinned or corroded.

Regular monitoring of pipeline coating and CP system is of paramount importance.

CP teams deployed at the MSs will regularly conduct surveys to have a true

assessment of coating condition and to carry out necessary rectification work. Other

corrosion related maintenance activities include: regular inspection and repair of

transformer rectifier units, ground beds / deep well anodes, and maintenance or

replacement of test posts.

Pipeline external coating system will be checked by means of Close Interval Potential

Survey / DC Voltage Gradient surveys. The frequency of check will be at most once

every three years. CP transformer output will be checked on a monthly basis. Potential

recording at test points will be checked every three months.

Routing monitoring via patrols will include checking of the following:

· Visible leaks;

· Third-party activities, especially excavations in the vicinity of the pipeline;

· Conditions of the ROW strip and windrow (berm);

· Permanent erosion and sedimentation control measures for the pipeline;

· Cover and position of the pipe at crossings;

· Condition of pipeline markers and barriers;

· Above grade lines are well supported and clear of sand; and

· External coating on exposed pipework, valves, and fittings is satisfactory.

Pipeline defects will be identified by regular patrolling, isolated defects by third-party

reporting or revealed by inspection tools. Aerial patrolling will also be considered at

least once every quarter.



Main services and utilities provided for the proper operation of the pipeline system at

CSs and OSs, which are likely to impact E&S components, are discussed as follows

(ILF, 2017c).

2.6.3.6.1 Power Supply

The electrical power for CSs and MSs will be generated from gas engine-driven

generator sets. Fuel gas for the generator sets will be supplied from the gas pipeline

through a fuel gas treatment package (ILF, 2017c).

Two identical rated gas engine driven generator sets will be provided, with one

generator set is in operation at all times while and the other is on standby. The load

on the operating generator set will be 90 to 100 % of its rated capacity. If the operating

generator set trips, the standby set will be started and takes over the load. Due to the

existence of uninterruptible power supply the short interrupt can be accepted.

For black start and emergency services, a diesel engine driven generator set will be

installed at each AGI, in addition to that provided from the gas pipeline.

2.6.3.6.2 Electrical System

The following electrical equipment will be used at each OS and MS (ILF, 2017c):

· Low voltage (LV) switchgear;

· Diesel engine driven generator set;

· LV distribution boards;

· Uninterruptible power supplies for AC and DC;

· Area lighting;

· Earthing and lightning protection; and

· Building and shelter Installations (small power and lighting).

2.6.3.6.3 Solar and Diesel Fuel System

It will be investigated if solar energy can be used to back up several systems in the

event of a power cut due to a failure of the fuel gas power generators (ILF, 2017m).

Otherwise, diesel fuel will be used. The emergency diesel generator set will consist of

a diesel engine/ generator unit, mounted on a common welded skid or base frame, a

dedicated control cabinet, and the associated secondary installations which will be

placed inside a container.

Diesel will be delivered by road tanker to site and stored within a buried steel tank.

Storage capacity of the diesel storage tank will be sufficient for 72-hour uninterrupted

operation at full load. Diesel transfer pumps will distribute the fuel to the consumers:

· Vehicle commercial filling point;

· Fire water pump day tank; and

· Emergency diesel generator set day tank.


2.6.3.6.4 Water Consumption

Phase I operation water consumption will be as follows:

· Drinking water. Based on experience from similar pipeline construction projects,

the amount of drinking water required is approximately 3 L per person per day.

Assuming that there will be an average number of around 300 people during

Phase I Operations, this will amount to a daily consumption of drinking water of

900 L. As the availability of clean drinking water in the Project area is likely to be

very limited, it is suggested that, as on other project sites, drinking water be

brought onsite by a vendor. Typically, large canisters of drinking water are

supplied. Empty canisters will be taken offsite by the vendor and replaced with

full ones;




Project area is likely to be very limited, it is likely to be tankered in / brought onsite

by a vendor. Assuming an average number of around 300 people, the expected

daily water demand for this purpose is 6,000 L; and





standards. This water will either be sourced locally or tankered in, in agreement


100 people, the expected daily water demand for this purpose is 10,000 L for the

whole operational period.


needed during Phase I operation.

Table 2-8: Phase I Operation Water Needs


Drinking Water 3 L / person 300 L Drinking/potable

water


Water for

Canteens


water


Water for

Sanitary

Facilities


meeting national

requirements

Either to be sourced locally or


the communities and

authorities

2.6.3.6.5 Fire Water System

The fire water system consists of a raw and fire water reservoir, two fire water pumps

(one electrical one diesel driven), jockey pumps, and fire water ring with hydrants.

The fire water system pressure is held at the present level by the jockey pumps during

normal non-fire condition. When the lower pressure limit of the main pump is reached,


the main pump starts up to supply fire water into the water distribution system at

required pressure and quantity.

The raw and fire water reservoir will be supplied from local water wells where possible.

In the event of insufficient capacity or water quality, the raw water tank can be filled

up with potable water delivered by road tankers. A loading pump can be used if the

road tanker is not sufficiently equipped.

2.6.3.6.6 Closed Drain System

The automatic discharge of liquids separated by the main gas filters will be conveyed

to a closed drain tank, which is a below ground double wall tank (ILF, 2017c). It will be

located close to the filter separators to reduce the risk of leaking pipes, to minimize

drained fluid travel and reduce unnecessary drain tank pit depth. The closed drain tank

is equipped with a connection for disposal of content via truck.

It is assumed that tank truck loading activities will be occasionally (once or twice a

year) inspected by certified contractors, under supervision of TPCL personnel. Due to

specified dry transport gas, the presence of minor condensate amounts is considered

in the inlet separators during normal operation. The condensate will be classified

taking into account the potential presence of liquid hydrocarbons.

Drainage of the inlet separator vessels is expected to be required only very

infrequently when liquids report to the flow station, such as during commissioning and

accidental discharge from the upstream station.

Monitoring of tank pressure is expected to protect the tank against overpressure. A

pressure switch will close the safety valve at the closed drain tank inlet piping. The

tank will be equipped with a flame arrestor and a vent pipe to lead gaseous

components to a safe area. The double wall closed drain tank will be equipped with a

leak detection system.

2.6.3.6.7 Contaminated Surface Water

Contaminated surface water is expected at the tanker loading / unloading facilities

(ILF, 2017c). Each loading / unloading area will be slopped and equipped with an oil

separator installed below ground at the low point of the concrete paving. During tanker

loading and unloading the outlet valve of the oil separator will be closed to avoid

contamination of the surrounding in case of spills. The latter will be sucked off with a

mobile pump if required. Normally the outlet valve of the oil separator is open and rain

water is dispersed to the surrounding.

Condensates and other waste products during plant operation are collected within the

condensate tank.

2.6.3.6.8 Open Drain System

The open drain system is designed to collect and dispose of contaminated water and

oil from all sources, due to temporary washing of process equipment (such as


maintenance) and continuous collected water from pre-filter package during back-

wash system.

Liquids from pre-filter package, maintenance activities, vessel draining, or machine

washing are drained through funnels to the open drain system, which collects all such

liquids and leads them to an oily water separator.

2.6.3.6.9 Sewage Water System

All buildings with sanitary installation, such as accommodation buildings, utility

building, and administration building, will be connected to the sanitary sewage water

system. It is assumed that sanitary wastewater will be discharged by underground,

gravity network to sewage treatment plant or septic tank(s) and then, depending on

the soil conditions, either directed to soak away area or used for the watering of

landscape plants within the site or evacuated by vacuum truck (ILF, 2017z).

In case of domestic sewage treatment plant, it will consist of a mechanical pre-

treatment unit (combined fine screening and sand removal unit), sludge storage, a

biological treatment unit, and a secondary settling unit. The effluent is discharged from

the secondary settling unit by gravity flow to the storm water channel. The stabilized

sludge will be removed from the sludge storage by truck withdrawal. Fully automated

operation is requested for all units

In case of septic tank(s), minimum two chamber precast concrete cylindrical

structures are expected lying side by side giving environmentally acceptable water

quality allowing free flow into a soak away area. It is expected to be emptied of

suspended solids on a yearly basis.

2.6.3.6.10 Storm Water Drainage System

The storm water drainage system will collect storm water from non-contaminated

areas. For that purpose, a system of open ditches will be provided (ILF, 2017c).

Underground pipes will be used around buildings and at some locations where open

ditches are not appropriate (for example, at road crossings or crossings with other

obstacles). Storm water sewer is a pipe system that should convey survey water

outside of the station or to evaporation pound.

The road levels will be raised by around 30 centimeters above the surrounding area

and the water will be drained to the surrounding area. Where needed, a special road

drainage system with road gullies and underground piping system will be provided.

The areas between the roads and buildings will be drained by open trapezoidal

ditches.

Rain water from the roofs of buildings and other structures will be collected in hot dip

galvanized rainwater downpipes with a minimum diameter of 150 mm. The water will

then be drained to the main trapezoidal ditch by small ditches or pipes. It is assumed

that storm water will be discharged with the use of open ditches outside the station or

directed to the evaporation ponds or seepage areas, depending on the soil conditions.


2.6.3.7 Workforce

The Project will employ only a small number of permanent employees at the MCC,

LCC, CSs, and MSs, and for inspection and maintenance work (ILF, 2017y).

The pipeline will be monitored by a control system, reducing the requirement for

operational workforce. Specialized teams are expected to repair faults (or sabotage),

and to maintain equipment and facilities. Regular ground and occasional aerial

inspections will be conducted, using vehicles and helicopter.

It is assumed that there will be approximately 100 permanent employees in Pakistan

during operation. Locals will be employed where possible, or foreigners will be

employed to live locally. Pakistan legislation does not require specific percentages of

local content, and such details have not been agreed between TPCL and the

government. The EPC Contractor is required to perform a skills assessment under a

detailed Local Content Plan. A Local Content Framework has been developed, as

presented in Appendix F, to serve as guidance for the EPC Contractor to develop the

detailed plan.

2.6.3.8 Waste Management

2.6.3.8.1 Overview

Waste management will generally be carried out closely in line with the legal framework

and under consideration of international good practice principles. All waste materials

will be collected, stored and transported separately in appropriate and approved bins

and containers. Companies certified by the relevant authorities will be used for

transportation, recycling, and disposal of waste.

Management of accommodation wastes, water treatment package wastes, and

closed drain contents will be performed according to dedicated procedure to be

developed in the EPC phase.

2.6.3.8.2 Liquid and Solid Wastes

Essentially, minimal quantities of wastes are expected to be generated during

operation of the pipeline. Vegetation waste resulting from periodic ROW maintenance

should be heaped and composted or managed under arrangement with input from

local community members as potential beneficiaries.

Expected waste streams have been identified based on the following activities:

· Maintenance activities:

- handling of waste from the pipeline found in the receiver, for example, mill

scale, debris, and wax deposits; and

- handling of the scraper(s) and associated materials, fluids, and inhibitor slugs

that may have been collected on the scraper during inspection runs;

· Presence of workforce on field.


During the operation of the pipeline, little waste will be generated compared to already

minimal quantities expected during construction. Waste oil from the servicing of

vehicles and miscellaneous solid wastes, including spent welding rods, packaging

waste, used drums, wood, scrap metal, and domestic rubbish could be generated.

Temporary waste disposal tanks can be used to collect debris from pipeline internal

inspection operations.

Hazardous wastes may potentially be generated in case of the need for disposal of

any non-significant residual arises, such as empty lubricants, residual oils canisters,

contaminated soils, or personal protective equipment (PPE).

Once the disposal solutions have been selected, shipment of waste from the

production and/or temporary storage sites to the disposal sites will have to be

organized in accordance with applicable legal requirements.

2.6.3.8.3 Wastewater Discharge

The drainage system will provide a safe and reliable method for the collection and

controlled disposal of flammable and non-flammable wastewater released during

normal operation or maintenance.

Major quantities of wastewater will arise from the sanitation facilities within the

buildings. The average maximum sanitary wastewater generation rate during

operation is estimated to be 0.16 m3 per hour.

2.6.4 Phase I Decommissioning

The expected service lifetime of the pipeline is 40 years. Decommissioning of the

pipeline will be undertaken in accordance with the legislation prevailing at that time,

in liaison with the relevant regulatory authorities.

A common decommissioning practice is to leave the pipeline capped in situ, unless

the pipe has a significant scrap value. The pipeline would be filled with an inert

substance, isolated, and recorded in an abandoned services register. This way, the

re-established vegetation within the corridor would not be disturbed again through

excavation and removal. Since the TAPI pipeline will only carry processed gas, it is

unlikely that the disposal of spent cleaning fluid will be of concern.

During the decommissioning phase, all AGIs will require dismantling, with all vessels

emptied of gases, liquids, and solids in advance. Any toxic or hazardous material will

be contained and disposed of in a safe manner, as agreed during consultation with

local authorities.

The assessment of the decommissioning methodology needs to take local

environmental considerations into account at the time of decommissioning. If parts of

the pipeline are to be decommissioned and removed, activities similar to that

undertaken during the construction phase will need to be executed, with a similar

environmental impact assessment required for the activities.


As part of environmental management of the Project, environmental performance

monitoring will be required as part of decommissioning works.

2.7 Phase II Project Components

In order to manage the pressure within the pipeline and to transport the natural gas

through the pipeline, two CSs (PAK-CS01 and PAK-CS02) will be constructed along

the pipeline route in Phase II of the Project. The two CSs will house a number of

compressor units, powered by low nitrogen oxides (NOx) gas turbines burning the in-

line gas. Standard modern packaged units will be used, which will comply with the

applicable environmental regulations. The compressor units will be housed in an

above ground enclosure.

Further to this, the CS facilities will include filter separators, aftercoolers, fuel gas

system, gas generators, vent, control and electrical building, administration building,

workshop / warehouse, fire brigade building, guard house, utilities as firefighting,

sewage treatment an all-weather bituminous concrete access road, a helipad, staff

accommodation, all-round fencing, and small auxiliary buildings.

A typical CS will include three (two operating and one standby) Turbo Compressor

Units (TUCO), four gas generators located in the power generation area, filter

separator units, two fired heaters (one operating and one in standby) in the off-take

area, gas coolers, an emergency diesel generator set, and a vent stack approximately

45 m high for emergency venting.

The footprint of each CS is 94 hectares (ha). The CS plots as identified on

Figure 2-1 are considered adequate to include the required construction camps and

laydown areas. Figure 2-9 illustrates a typical CS as provided by ILF.


Figure 2-9: Typical Compressor Station

2.8 Phase II Project Activities

2.8.1 Phase II Construction

The following steps are usually recognized in the construction of such facilities:

· Surveying;

· Preparation of temporary facilities such as storage areas, offices, and

accommodation facilities;

· Preparation of the construction site;

· Earthworks;

· Preparation of foundations;

· Erection of equipment and buildings (installation of underground structures may

require the use of sheet piling for stabilization of construction pits);

· Laying of cables and electrical works;

· Piping and mechanical works;

· Construction of internal roads and areas (if any);

· Installation of operational, control, and instrumentation systems; and

· Construction of new roads to facilitate permanent access for construction and

operation.

All key materials, such as the components of CSs, will be shipped to the Port of

Karachi or the Port of Bin Qasim then onwards by road. It is assumed that each CS


will take a maximum of six months to construct and multiple CSs can be constructed

at the same time.

It is anticipated that no access roads will be constructed in Phase II as the new and

upgraded access roads created during Phase I will be adequate for the Phase II

components. Permanent access to CSs will be required for construction works and

subsequently for operation and maintenance.


Where sites are established close enough and there is sufficient capacity, services

and utilities (such as water supply, wastewater and sanitation services, electricity

supply, potable water supply, and solid waste management) will be purchased from

local suppliers. Local utilities will be commissioned to extend transmission lines or

water pipes to worksites. Where local capacity is insufficient, contractors will establish

their own site facilities.

2.8.1.2 Workforce

During the construction of Phase II, there is estimated to be 500 construction workers

at each CS, in total 1,000 workers.

2.8.1.3 Water Consumption

Water needed during the Phase II construction includes the following:

· Drinking water. Based on experience from similar construction projects, the

amount of drinking water required is approximately 3 L per person per day.

Assuming an average number of around 1,000 people (500 people at each CS)

this will amount to a daily consumption of drinking water of 3,000 L (1,500 L at

each CS). As the availability of clean drinking water in the Project area is likely to

be very limited, it is suggested that, as on other construction sites, drinking water

be brought onsite by a vendor. Typically, large canisters of drinking water are

supplied. Empty canisters will be taken offsite by the vendor and replaced with

full ones;





by a vendor. Assuming an average number of around 1,000 people (500 people

at each CS), the expected daily water demand for this purpose is 20,000 L;





standards. This water will be either sourced locally or tankered in, in agreement



1,000 people (500 people at each CS), the expected daily water demand for this

purpose is 100,000 L for the whole construction period; and

· Water for miscellaneous construction activities. The amount of water required for

construction activities will be calculated by the EPC Contractor during detailed

design. It is likely that for some of these activities and especially for measures

such as dust suppression, grey water from the canteens and sanitary facilities

can be used. Again, this will need to be agreed with the authorities.


needed during Phase II Construction.

Table 2-9: Phase II Construction Water Needs



water


Water for

Canteens


water


Water for

Sanitary

Facilities


meeting national

requirements



the communities and

authorities.

Water for

Miscellaneous

Construction

Activities

To be calculated by EPC

Contractor during detailed

design

Standards as defined

in ESIA and/or

agreed with national

authorities

Source to be agreed with

communities and authorities,

most likely tankered in, or

partially recycled grey water

from the canteens and sanitary

facilities (if water quality

standards are met).

2.8.1.4 Use of Resources and Project Emissions

At this stage, no estimated quantities of resource use or Project emissions for Phase

II are available.

2.8.1.5 Construction Camps

At this stage, no information on construction camps for Phase II is available.

2.8.2 Phase II Commissioning/Start-up

There will be no commissioning/start-up activities for Phase II.

2.8.3 Phase II Operation

2.8.3.1 Monitoring and Maintenance

Each CS along the pipeline will be equipped with a SCS that provides control,

safeguarding, and monitoring of the station facilities and process units. The SCS will

incorporate both the PCS, which enables the plant to operate safely and efficiently

within its design constraints, and the FSS, which includes control and monitoring of


all process emergency shutdown (ESD) functions and control and monitoring of all

fire and gas process related facilities.

The PCS / FSS will control, monitor and shut down the plant and provide adequate

monitoring of the important process variables.

The following will be applied:

· The CS is designed and equipped for manned operation. Operators working in

shifts will be permanent on site and run the CS from the local control room. Data

transfer will be enabled via a fiber optic cable or satellite; and

· In case of a detected leak in the process piping or a fire at the CS, the operator

in charge can initiate an ESD that closes the inlet and outlet ESD valves of the

CS, and the CS will be isolated from the pipeline. A total CS blow-down through

the station vent can be triggered from the control room if required.

Maintenance centers and emergency response crews are foreseen at all CSs.

2.8.3.2 Power Supply

Electrical power for the CSs and MSs will be generated from gas engine driven

generator sets. Fuel gas for the gas engine driven generator sets will be supplied from

the gas pipeline through a fuel gas treatment package (ILF, 2017c).

The electrical power for each CS will be generated from four identical rated gas engine

driven generator sets, where three sets are operating at all times with one set on

standby. The load on each of the operating gas generator sets will be 65 to 70 % of

its rated capacity. In the event that any of the three operating generator sets trips, the

remaining two operating gas generator sets will meet the full load demand of the plant

until the standby generator set is brought online and starts sharing the plant load.

2.8.3.3 Workforce

The Project will employ a total of 500 staff onsite, spread across the two CSs in

Pakistan, which equates to approximately 250 staff at each CS.

CS operation will be managed in shifts with foreman, deputy foreman, and assistant.

The foremen and assistant will be responsible for operation and general upkeep of

the CS. Each CS will be headed by a station manager in charge, who is responsible

for technical and administrative matters relating to the CS.

Each CS will comprise office buildings, residential facilities, storage facilities,

workshops, and service facilities for the personnel posted there. It will be permanently-

manned and all the facilities necessary for making life of employees comfortable

should be arranged.

For routine maintenance of each CS, a team of maintenance personnel will be posted

to keep the station operational by conducting routine preventive and scheduled


maintenance as recommended by the equipment supplier. The maintenance team will

also look after emergencies and break downs of moderate level.

2.8.3.4 Water Consumption

Water needed during Phase II operation of the Project includes the following:

· Drinking water. Based on experience from similar pipeline projects, the amount

of drinking water required is approximately 3 L per person per day. Assuming an

average number of around 500 people (250 people at each CS), this will amount

to a daily consumption of drinking water of 1.500 L (750 L at each CS). As the

availability of clean drinking water in the Project area is likely to be very limited, it

is suggested that, as on other construction sites, drinking water be brought onsite

by a vendor. Typically, large canisters of drinking water are supplied. Empty

canisters will be taken offsite by the vendor and replaced with full ones;





by a vendor. Assuming an average number of around 500 people (250 people at

each CS), the expected daily water demand for this purpose is 10,000 L; and





standards. This water will be either sourced locally or tankered in, in agreement


500 people (250 at each CS), the expected daily water demand for this purpose

is 50,000 L for the whole construction period.


needed during Phase II operation.

Table 2-10: Phase II Operation Water Needs



water quality


Water for

Canteens

20 L / person 10, 000 L Drinking/potable

water


Water for

Sanitary

Facilities

100 L / person 50, 000 L Non-potable water,

meeting national

requirements


tankered-in, in agreement with

the communities and

authorities.


2.8.4 Phase II Decommissioning

The expected service lifetime of the Project is 40 years. Decommissioning of the CSs

will be undertaken in accordance with the legislation prevailing at that time, in liaison

with the relevant regulatory authorities.

A common decommissioning practice is to leave the pipeline capped in situ, unless

the pipe has a significant scrap value. The pipeline would be filled with an inert

substance, isolated, and recorded in an abandoned services register. This way, the

re-established vegetation within the corridor would not be disturbed again through

excavation and removal. Since the TAPI pipeline will only carry processed gas, it is

unlikely that the disposal of spent cleaning fluid will be of concern.

During the decommissioning phase, all CSs will require dismantling, with all vessels

emptied of gases, liquids, and solids in advance. Any toxic or hazardous material will

be contained and disposed of in a safe manner, as agreed during consultation with

local authorities.

The assessment of the decommissioning methodology needs to take local

environmental considerations into account at the time of decommissioning. If the CSs

are to be decommissioned and removed, activities similar to that undertaken during

the construction phase will need to be executed, with a similar environmental impact

assessment required for the activities.

As part of environmental management of the Project, environmental performance

monitoring will be required as part of decommissioning works.


3 LEGAL AND OTHER REQUIREMENTS

3.1 Overview

The ESIA Process detailed within this report has been undertaken in compliance with

the following:

· Pakistan legislation and international policies, guidelines, conventions, and

protocols to which Pakistan is party to; and

· International standards and guidelines on impact assessment, including the

IFC PS, World Bank/IFC General and Sector-specific EHS Guidelines, ADB

requirements, Asian Infrastructure Investment Bank (AIIB) requirements, and the

Equator Principles (EPs).

This chapter presents an overview of the abovementioned legal, regulatory, and

administrative framework within which the ESIA has been undertaken.

3.2 National Policy and Legal Framework

3.2.1 Constitutional Provision

According to the Constitution of Pakistan, the legislative powers lie with the federal

parliament and the legislative assemblies of the four provinces of Pakistan. The

Fourth Schedule of the constitution provides two lists of issues, as follows:

· The Federal Legislative List, which includes issues on which only the federal

government has legislative powers; and

· The Concurrent Legislative List, which includes issues on which both the federal

and the provincial governments have legislative powers.

If a particular legislation passed by a provincial assembly comes into conflict with a

law enacted by the national assembly, then according to the Constitution, the federal

legislation will prevail over the provincial legislation to the extent of the inconsistency.

Subsequent to the 18th Amendment of the Constitution of Pakistan in 2010, the

‘environmental pollution and ecology' subject was transferred from the Concurrent

Legislative List to the legislative domain of the provincial assemblies, resulting in a

significant increase in the extent of provincial autonomy actually handling all

environmental affairs. This has far-reaching implications for environmental

governance in the country, not only in terms of future law-making, but also for

implementation of existing environmental laws, rules, and regulations and Pakistan's

obligations under multinational agreements.

Responding to this need, some of the provinces have already enacted their provincial

environmental protection acts while others are in the process of doing so.


3.2.2 National Policy Framework

This section presents a summary of the national policies relevant to the Project and

considers national regulations and guidelines to assess Project compliance with local

requirements. Table 3-1 lists the national policies relevant to the Project.

Table 3-1: National Policy Framework

Policy Date

National Conservation Strategy 1992

Biodiversity Action Plan 2000

National Environmental Action Plan 2001

National Resettlement Policy (Draft) 2002

National Environmental Policy 2005

Labor Policy 2010

National Climate Change Policy 2012

National Forest Policy 2015


3.2.2.1 National Environmental Policy, National Conservation Strategy, and National

Environmental Action Plan

The National Environmental Policy (NEP) of 2005, developed by the Pakistan Ministry

of Environment, is the environmental policy of principal relevance. The NEP provides

an overarching framework for addressing the environmental issues that Pakistan is

facing, particularly as they relate to pollution of fresh water bodies and coastal waters,

air pollution, lack of proper waste management, deforestation, loss of biodiversity,

desertification, natural disasters, and climate change.

The NEP, while recognizing the goals and objectives of the National Conservative

Strategy (NCS), the National Environmental Action Plan (NEAP), and other existing

environment related national policies, strategies, and action plans, provides broad

guidelines to the federal and provincial level government. These guidelines address

environmental concerns and ensure effective management of environmental

resources to meet international obligations through sustainable development.

The objectives of the NEP include:

· Conservation, restoration, and efficient management of environmental resources;

· Integration of environmental considerations in policy-making and planning

processes;

· Capacity building of government agencies and other stockholders at all levels for

better environmental management;

· Meeting international obligations effectively in line with the national aspirations;

and

· Creation of a demand for environment through mass awareness and community

mobilization.

The NEP identifies the following set of sectoral and cross-sectoral guidelines to

achieve its goal of sustainable development:


· Sectoral guidelines, which address water and sanitation, air quality and noise,

waste management, forestry, biodiversity and protected areas, climate change

and ozone depletion, energy efficiency and renewables, agriculture and livestock,

and multilateral environmental agreements; and

· Cross-sectoral guidelines, which address poverty, population, gender, health,

trade and environment, environment and local governance, and natural disaster

management.

The NEP suggests the following policy instruments to overcome environmental

problems throughout the country:

· Integration of environment into development planning;

· Legislation and regulatory framework;

· Capacity development;

· Economic and market-based instrument;

· Public awareness and education; and

· Public private civil society partnership.

3.2.2.2 National Climate Change Policy and Biodiversity Action Plan

The National Climate Change Policy (NCCP), approved by the government in 2012,

has an overall goal ‘to ensure that climate change is mainstreamed in the

economically and socially vulnerable sectors of the economy and to steer Pakistan

towards climate resilient development’. One of the major objectives of the NCCP is

conservation of natural resources and long-term sustainability, which has been further

elaborated through specific measures under forestry, biodiversity, and other

vulnerable ecosystems.

The Biodiversity Action Plan (BAP), which was designed to complement the NCS and

the proposed provincial conservation strategies, identifies the causes of biodiversity

loss in Pakistan and suggests a series of proposals for action to conserve biodiversity

in the country. The BAP recognizes that an environmental assessment should be

used as a tool at a project level to identify environmental effects of a proposed project

and to plan for reducing adverse effects. The BAP further stipulates that an

environmental assessment needs to be initiated at an early stage of project

development and that public participation in the review of potential effects is important.

3.2.2.3 National Forest Policy

The National Forest Policy (NFP) deals with the renewable natural resources (RNR)

of Pakistan, such as forests, watersheds, rangelands, wildlife, biodiversity, and their

habitats. the NFP aims to eliminate the causes of depletion to RNR through the active

participation of various concerned stakeholders and government departments.

Some of the main elements of the NFP include reducing the impact of socio-economic

causes such as population planning, providing substitutes to firewood, poverty

alleviation, reducing political interference in the forest and wildlife departments,


renovating and invigorating institutions of RNR (local governments such as districts),

policies for fragile ecosystems (such as mountain forests and mangroves), developing

riverain forests, maintaining irrigated plantations, preserving unique forests (such as

the Juniper forest in Balochistan), and protecting wildlife, rangelands, and desert

ecosystems, planting trees and fodders on farmlands, and general monitoring and

evaluation.

3.2.2.4 National Resettlement Policy (Draft)

The Draft National Resettlement Policy (NRP) of 2002 has been formulated to ensure

an equitable and uniform treatment of resettlement issues throughout Pakistan. The

NRP applies to all development projects involving adverse social impacts, including

land acquisition, loss of assets, loss of income, loss of business, and other possible

losses. The NRP addresses areas that are not taken care of in the Land Acquisition

Act 1894 (further discussed in Section 4.2.3.9) and should be applicable wherever

any public sector or private development project affects people, families, or

communities, even when there is no displacement of population.

The PEPA 1997 will be responsible for both environment- and resettlement-related

matters. The following are of relevance to resettlement planning and management:

· The responsibilities for implementation at the federal level will be delegated to

the federal agency responsible for the implementation of a project, who is also

required to liaise closely with the government of the province where the project is

being implemented;

· The responsibilities for implementation at a provincial level are to be delegated

to the provincial EPA concerned with overall control under the planning and

development departments;

· A Resettlement Action Plan (RAP) will be required when the displaced population

exceeds 200;

· All categories of loss arising from development projects that entail resettlement

need to be addressed, including loss of land, built-up property, other

infrastructure, crops and trees, income, job opportunities, and access to natural

resources;

· Vulnerable groups whose issues need to be addressed in particular include

women, children, destitute persons, tribal communities, squatters, those with

usufruct rights, and landless groups; and

· There should be a particular emphasis on consultation with affected groups when

preparing a RAP.

3.2.2.5 Labor Policy

Five previous labor policies were announced by the national government since the

creation of Pakistan, between 1955 and 2002. The current version, which was

announced in 2010, was updated with the following objectives:


· Workers’ right to form unions, which should be protected, and an institutional

framework should be made available to foster close cooperation between

workers and employers at establishment level;

· Equitable adjustment of rights between workers and employers should be

ensured in an atmosphere of harmony, mutually beneficial to the workers and the

management;

· Consultations between workers and employers on matters of interest to the

establishment and welfare of workers should be made more effective;

· Adequate security of jobs should be available to the workers and there should be

expeditious redressal of their grievances;

· Conditions should be created that workers and employers are committed in

enhancing the labor productivity;

· Promotion to higher jobs should be ensured at all levels based on suitability and

merit and, for this purpose, arrangements should be made for in-service training

facilities;

· Facilities for proper matching of job opportunities and the job seekers should be

strengthened and standard procedures be streamlined;

· Social insurance schemes should be further strengthened;

· Just and humane conditions of work should be guaranteed to all workers;

· Forced labor in all its forms should be eliminated; and

· Provisions relating to the employment of children should be strictly adhered to

and enforced.

3.2.3 National Legal and Regulatory Framework

The ESIA must consider relevant national laws and regulations to assess Project

compliance. Table 3-2 lists the national laws and regulations relevant to the Project.

The main requirements of national E&S legislations are summarized in the

subsections below.

Table 3-2: National Legislative Framework

Title Date Enforcing

Agencies

Environment and Ecology

Canal and Drainage Act 1873 Pak-EPA

Cutting of Trees Act and Protection of Trees and Brushwood Act 1949 - 1975

Motor Vehicle Rules 1969

Wildlife Act 1975

The Pakistan Environmental Assessment

· PEPA 1997 (rules and regulations below developed under provisions of Sections 31 and 33)

· Environmental Tribunal Rules

· Pak-EPA Review of IEE/EIA Regulations

· Environmental Samples Rules

· National Environmental Quality Standards - Self-Monitoring and Reporting by Industries Rules

1997

1997

1999

2000

2001

2001


Title Date Enforcing

Agencies

· Pollution Charge for Industry Rules

· National Environmental Quality Standards for Motor Vehicle Exhaust and Noise

· National Environmental Quality Standards for Ambient Air, Drinking Water and Noise

2001

2009

2010

Forest Act 1927 – amended

in 2010

Pakistan Trade Control of Wild Fauna and Flora Act 2012

Pakistan Climate Change Act 2017

Archaeological and Cultural Heritage Resources

Antiquities Act 1975 National History and

Literary Heritage

Division

Waste and Hazardous Substances

Hazardous Substances Rules (Draft) 2003 PAK-EPA

Handling, Manufacture, Storage, Import of Hazardous Waste and

Hazardous Substances Rules

2016

Land Acquisition

Land Acquisition Act 1894 (with

subsequent

amendments

Evacuee Property and Displaced Persons Laws (Repeal) Act 1975

Resettlement Ordinance 2001

Local Government

Local Government Ordinance 2001

Labor

Labor Laws Amended 1972

Employment of Child Act 1991

Occupational Health and Safety

Mineral Gas Safety Rules 1960

Factories Act and Pakistan Factories Rules 1934 - 1962

Explosives Act and Explosive Rules 1884 - 2010

Mineral and Industrial Gases Safety Rules 2010

Mining Concession Areas along the ROW – Permit for Crossing

Regulation of Mines and Oilfields and Mineral Development

1[Government Control] Act

1948

Mining Concession (Acquisition) Act 1972

Mineral Rules 2002

Oil and Gas

Oil and Gas Regulatory Authority Ordinance 2002

3.2.3.1 Pakistan Environmental Protection Act 1997

The PEPA 1997 is the basic legislative tool empowering the government to frame

regulations for the protection of the environment. The PEPA 1997 is broadly

applicable to air, water, soil, marine, and noise pollution, and to the management of

hazardous waste. The PEPA 1997 provides for the establishment of the Pakistan

Environmental Protection Council (the Council), the Pak-EPA, Provincial Sustainable

Development Funds, and Environmental Tribunals. The Council coordinates and

supervises national environmental policy and ensures the implementation of a

national conservation strategy. It approves National Environmental Quality Standards


(NEQS) and provides guidelines for the protection and conservation of species,

habitat, and biodiversity. In particular, the PEPA 1997 empowers the Pak-EPA to:

· Delegate powers, including those of environmental assessment to the provincial

EPAs;

· Identify categories of the projects to which the IEE/EIA provisions will apply;

· Develop guidelines for conducting IEEs and EIAs and procedures for the

submission, review, and approval of the same;

· Develop environmental emission standards for parameters such as air, water,

and noise pollutants; and

· Enforce the provisions of the PEPA 1997 through environmental protection

orders and environmental tribunals headed by magistrates with wide-ranging

powers, including the right to fine violators of the PEPA 1997.

Environmental Tribunals are established by the federal government, who specifies

territorial jurisdiction of each Environmental Tribunal. Contravention of provisions of

the PEPA 1997 is submitted to the Environmental Tribunal for its decision by

authorities or aggrieved persons.

The PEPA 1997 defines for the first time the concepts of IEEs and EIAs, and provides

a stepwise process of conducting IEEs and EIAs.

Under the provisions of the Section 26 of the PEPA 1997, the Pak-EPA has

empowered four provincial EPAs to manage the environmental concerns of their

respective provinces. The provincial EPAs can frame environmental regulations

tailored to the requirements of their province, provided that these regulations meet or

exceed the minimum standards set out by the PEPA 1997. The PEPA 1997 has been

adopted by the provinces until they pass their respective environmental protection

laws and regulations. Provinces are also required to review and approve IEEs/EIAs

of all the development projects undertaken in their respective provinces, including

projects that are implemented by federal government agencies/departments.

In 2000, the Pak-EPA Review of IEE and EIA Regulations (the National Regulations

2000) were notified for providing detailed steps for the review process and project

inspection and monitoring of IEE and EIA as provided by the PEPA 1997.

With regard to hazardous substances, Section 14 of the PEPA 1997 (Handling of

Hazardous Substances) requires that, “subject to the provisions of this Act, no person

shall generate, collect, consign, transport, treat, dispose of, store, handle, or import

any hazardous substance except (a) under a license issued by the EPA and in such

manner as may be prescribed; or (b) in accordance with the provisions of any other

law for the time being in force, or of any international treaty, convention, protocol,

code, standard, agreement, or other Instrument to which Pakistan is a party.”

Enforcement of this clause requires the responsible EPA to issue regulations

regarding licensing procedures and to define hazardous substance.


3.2.3.2 National Environmental Quality Standards

The NEQS were first promulgated in 1993, revised in 2000, and amended in 2009

and 2010. The NEQS specify standards for industrial and municipal effluents,

gaseous emissions, vehicular emissions, and noise levels. The PEPA 1997 specifies

the imposition of a pollution charge in case of non-compliance with the NEQS.

Standards for disposal of solid waste have not been promulgated yet.

The NEQS specify the following standards:

· Maximum allowable concentration of pollutants (32 parameters) in municipal and

liquid industrial effluents discharged to inland waters, sewage treatment facilities,

and the sea (three separate sets of numbers);

· Maximum allowable concentration of pollutants (16 parameters) in gaseous

emissions from industrial sources;

· Maximum allowable concentration of pollutants (two parameters) in gaseous

emissions from vehicle exhaust;

· Maximum allowable noise levels from vehicles;

· Maximum allowable concentration of ambient gaseous and particulate matter (10

parameters); and

· Standards for drinking water quality covering bacterial, physical, chemical,

organic, and radioactive parameters.

These standards also apply to the gaseous emissions generated by generators. The

NEQS for vehicles will apply during the construction as well as operation phase of the

natural gas pipeline.

The NEQS also sets out the requirement for correct and timely submission of

Environmental Monitoring Reports by industrial units to the Pak-EPA. Industrial units

are classified on the basis of their pollution level into the category for gaseous

emissions or liquid effluents (Rule 4). Large industrial units with very high pollution

levels could be classified as a special industry (Rule 8). The required contents of the

Environmental Monitoring Reports are provided in Rule 9.

3.2.3.3 Local Government Ordinance 2001

The Local Government Ordinance (LGO) 2001 removed the urban-rural divide and

established local government at three levels, namely, Union Council, Tehsil/Taluka

Council, and District Council. The Union Council was defined as the basic unit and

the Union Nazims (Mayors) and Naib Nazims (Deputy Mayors), directly elected by the

voters, became members of the District and Tehsil/Taluka Councils, respectively.

The LGO 2001 devolved administrative, financial, and development powers to the

elected officials in the local councils and all the government departments became

accountable to the District Council. The Deputy Commissioners were re-designated

as District Coordination Officers and subordinated to the District Nazim for executive

approvals, performance evaluations, and transfers/postings.


Another important feature of the LGO 2001 was its allocation of reserved seats for

women (33%), minorities, professionals, and peasants. However, women's

participation was constrained in some parts of the country by the local jirgas, tribal

leaders, and biradaries.

Finally, the LGO 2001 provided for several forums, such as District Monitoring

Committees to oversee the work of government departments, Citizens Community

Boards to allow direct citizen participation in designing and overseeing development

schemes, Musalehat-e-Anjumans (consultative bodies) for alternate dispute

resolution, and Citizen Police Liaison Committees for promoting rule of law and

protection of rights (UNDP, 2013).

3.2.3.4 Hazardous Substance Rules (Draft)

In addition to requirements set out in Section 14 of the PEPA 1997 (as discussed in

Section 4.2.3.1), Pak-EPA has drafted the Hazardous Substance Rules to implement

the licensing requirement. These Rules are still in their draft form and are pending

notification.

There is a total of 22 Rules and 5 Schedules, making provisions for the granting of

licenses for the collection, treatment, storage, importation, and transportation of

hazardous substances. Substances prescribed as hazardous are listed in Schedule I.

An EIA of the project involving hazardous substances shall accompany the application

to obtain a license as stated in Rule 5. Rules 7 and 8 deal with the issuance of

licenses, and the conditions and requirements of licensees. Packaging and labelling

provisions are outlined in Rule 9. General safety precautions and precautions for

workers are covered in Rules 11 and 12. Provisions on the validity, renewal, and

cancellation of licenses are set out in Rules 13 to 15. Rule 16 states that authorized

staff of the federal or provincial EPA is entitled to enter and inspect the premises in

which hazardous substances are generated, collected, treated, disposed of, or stored.

Safety plans and waste management plans shall be submitted to the Pak-EPA, as

stated in Rules 17 to 19). Details to be provided for the application of licenses for the

importation and transportation of hazardous substances are provided in Rules 20 and

21.

3.2.3.5 Handling, Manufacture, Storage, Import of Hazardous Waste and Hazardous

Substances Rules 2016

These Rules lay the principle for dealing with hazardous waste and substances in

accordance with the provisions of the national and provincial environmental protection

acts. It includes a list of hazardous chemicals and substances in annexes, and gives

a threshold on the basis of toxicity levels. It also provides detail on physical and

chemical properties (Schedule I) and quantities that can be stored in a specific site

(Schedule III). It requires the institution dealing with hazardous wastes and

substances to obtain a license from the relevant EPA and gives the relevant EPA the

right to stop import of material. These Rules also make it mandatory for the licensee


to develop emergency plans for handling accidents and stipulate at least one

rehearsal in a calendar year.

3.2.3.6 Forest Act 1927 (and 1974 Amendment)

The Forest Act (Act Number XVI of 1927) is applicable to all regions of Pakistan. It

includes procedures for constituting and managing various types of forests, such as

reserved forests and protected forests. The Forest Act 1927 empowers the provincial

forest departments to declare any forest area as reserved or protected and to prohibit

the clearing of forests for cultivation, grazing, hunting, removing forest produce,

quarrying and felling, and lopping and topping of trees or branches in reserved and

protected forests. The Forest Act 1927 also defines the duties and roles of forest

related public servants, and penalties for any infringement of the rules.

Clause 30 of the Forest Act 1927 was amended through the Forest ‘Balochistan

Amendment’ Act1 1974, to declare Juniper trees as protected. The amended

Clause 30A of the Forest Act 1927 states that “it shall be unlawful (i) to fell or girdle a

Juniper tree; (ii) to lop, tap, burn, strip off the bark from, or in any other way damage,

a Juniper tree whether standing, fallen or felled; (iii) to remove any felled or fallen

Juniper tree, or its firewood, or any part thereof, for sale; (iv) to possess and stock

Juniper firewood or timber for the purpose of sale; provided that nothing shall be

deemed to be an offence under this section when done with the permission in writing

of the prescribed authority or in accordance with rules framed or in force under this

Act.”

The above legal requirements preventing cutting of Juniper trees are also contained

in the Balochistan Forest Regulation.

3.2.3.7 Cutting of Trees Act and Protection of Trees and Bush Wood Act 1949

The Cutting of Trees Act prohibits cutting or chopping of trees without prior permission

of the Forest Department. Section 3 of this Act states that “no person shall, without

the prior written approval of the local formation commander or an officer authorized

by him in this behalf, cut fell or damage or cause to cut, fell or damage any tree.”

Similarly, the Protection of Trees and Bush Wood Act, 1949 prohibits cutting of trees

and bush wood without permission of the Forest Department. This Act was enforced

to prevent unlawful removal /clearing of trees and green areas for any reason without

the consent of the Forest Department.

3.2.3.8 Canal and Drainage Act 1873

The National Canal and Drainage Act 1873 prohibits corruption or fouling of water in

canals (defined to include channels, tube wells, reservoirs, and watercourses) and

obstruction of drainage. The Act has relevance to the Project due to the potential

1 This Act, which amended the Forest Act, XVI of 1927, was passed by the Balochistan Assembly on 16 th July 1974; assented

to by the Governor of Balochistan; published in the Balochistan Gazette (extraordinary) No. 53, dated 2nd August, 1974.


presence of canals and irrigation networks in the Project area. All Project activities

near the irrigation network will have to be implemented in a way that no physical

damage to the canal or alteration in water quality occurs. Any discharge of waste into

the canal shall also be prohibited. Any abstraction of water from the canal shall be

subject to approval from the concerned irrigation department.

Canal Officers acting under the orders of the provincial government may enter any

land and use the water for the purpose of any existing or projected canal or drainage-

work (Part II). Canal Officers may clear land, inspect and regulate water-supply,

execute all works that may be necessary for the purpose of repairing or preventing

accidents, and perform all acts necessary for the proper prosecution of any enquiry

relating to any existing or projected canal. Any person desiring to use the water of any

canal may apply in writing to the Canal Officer.

Ordinances provide for the supply of water from a canal through an existing

watercourse or change of source of water supply of any land; applications for the

acquisition of land for construction works; application for the transfer of existing water

courses; expenses to be paid by applicants; rules and conditions to be followed by

the applicant. Part IV prescribes rules and conditions for the supply of canal water.

Any vessel entering or navigating any canal contrary to the rules of this Act, may be

removed or detained by the Divisional Canal Officer, and if any person causes the

obstruction of any river, stream or drainage-channel the Government may order the

removal or other modification of such obstruction (Part VI and VII).

3.2.3.9 Land Acquisition Act 1894 (and Amendments)

An important aspect of EIA is consideration of the displacement and relocation of the

project affected population. Article 24(1) of the Constitution of Pakistan states that “no

person shall be deprived of his property save in accordance with law”, whereas Article

24(2) states that “no property shall be compulsorily acquired or taken possession of

save for a public purpose and save by the authority of law, which provides for

compensation therefore and either fixes the amount of compensation or specifies the

principles on, and the manner in which, compensation is to be determined and given”.

Land acquisition is not covered by either the Federal Legislative List or the Concurrent

Legislative List. According to Article 142(c) of the Constitution, when a subject is not

covered by either list, the Provincial Assembly alone is authorized to pass laws on the

subject. However, the Land Acquisition Act (LAA) 1894 continues in full force and

effect as a federal legislation by virtue of Article 268(1) of the Constitution as an

existing law (Penspen, 2015).

The LAA 1894 and its amendments form the main legislation related to land

acquisition for projects of public interest in Pakistan. The LAA 1894 requires that,

following impact assessment and valuation of assets, the affected land and crops are

to be compensated in cash at the current market rate to titled landowners and

registered land tenants/users. The LAA 1894 is the de-facto legal instrument

governing resettlement and compensation to those affected by the Project. However,


it does not provide for the Project to give due consideration to social, cultural,

economic, and environmental conditions associated with and affected by

resettlement. Although the LAA 1894 lays down detailed procedures for acquisition of

private properties for public purposes and compensation, it does not extend to

resettlement and rehabilitation of people. The LAA 1894 has been variously

interpreted by provincial governments, and some provinces have augmented the

LAA 1894 by issuing provincial legislations.

The legal procedures for land acquisition have the objective of providing adequate

compensation for the loss of income to those who suffer loss of communal property,

including common assets, productive assets, structures, other fixed assets, income

and employment, loss of community networks and services, pastures, water rights,

public infrastructure such as mosques, shrines, schools, graveyards and any

consequential losses. However, the LAA 1894 is limited to a cash compensation

policy for the acquisition of land and built-up property, and damage to other assets,

such as crops, trees, and infrastructure. The LAA 1894 does not consider the

rehabilitation and resettlement of disrupted population and the restoration of their

livelihoods. It also states that the compensation package for land acquisition should

include compensation for structure and improvements made to land with damages

being accrued due to severing of acquired land from remaining land and diminution

of earnings and profits (if any). It should be noted that there have been frequent

revisions to the LAA 1894, and that the latest revisions will apply.

3.2.3.10 Resettlement Ordinance 2001

The national government has proclaimed an ordinance entitled Project

Implementation and Resettlement of the Affected Persons Ordinance 2001, later

referred to as the Resettlement Ordinance, which should be used to safeguard the

interests of persons/groups having to be involuntarily resettled due to land acquisition

caused by a proposed project. The Resettlement Ordinance 2001 establishes that the

resettlement of the involuntarily displaced persons is done as a matter of right and not

by way of charity or any such sentiment. In addition, the Affected Persons shall be

accepted as special groups who in the supreme interest of the country have

accepted/undergone involuntary displacement. The Resettlement Ordinance shall be

supplementary to the LAA 1894, other laws of Pakistan, and wherever items are

included in the NRP (as discussed in Section 4.2.2.4).

3.2.3.11 Antiquities Act 1975

The protection of cultural resources in Pakistan is ensured by the Antiquities Act,

1975. Antiquities have been defined in the Act as ancient products of human activity,

historical sites, or sites of anthropological or cultural interest, such as national

monuments. The Act is designed to protect antiquities from destruction, theft,

negligence, unlawful excavation, trade, and export. The Act prohibits new

construction in the proximity of a protected antiquity and empowers the federal


government to prohibit excavation in any area that may contain articles of

archaeological significance.

Under the Act, the Project Proponent is obligated to:

· Ensure that no activity is undertaken in the proximity of a protected antiquity or

within 200 m of protected sites, unless prior permission has been obtained from

the Federal Department of Archaeology and Museums; and

· If during the course of the Project an archaeological discovery is made, it shall be

reported to the Federal Department of Archaeology and Museums.

3.2.3.12 Motor Vehicle Rules 1969

The Ordinance establishes the motor vehicle examination and inspection system and

provides legal basis for motor vehicle fitness examination, fitness certification, and

the powers and responsibilities of the Motor Vehicle Examiners. The key

responsibilities of the Motor Vehicle Examiner include:

· Inspection and certification for granting / renewing fitness of vehicles;

· Monitoring traffic for violations of Motor Vehicle Ordinance 1965;

· Prosecuting motor vehicles emitting smoke; and

· Prosecuting motor vehicles being operated in unsafe conditions.

3.2.3.13 Occupational Health and Safety Regulations

National standards with respect to the occupational health and safety (H&S) of

workers have yet to be developed in Pakistan; however, the following laws and

regulations directly or indirectly govern the occupational H&S issues during

construction and operations of the Project.

3.2.3.13.1 Mineral Gas Safety Rules

These Rules provide for the compression of natural gas for the purpose of storage

and filling or distribution of compressed natural gas (CNG). Under these Rules, the

location, construction, and operation of a pipeline and all works connected with a CNG

refueling station must be in accordance with the license granted by the chief inspector

of explosives.

3.2.3.13.2 Mineral and Industrial Gases Safety Rules

These Rules provide specification, standards, import and manufacturing, and

manners of installation of all sorts of compressed/liquefied gas containers (cylinders

and vessels), petroleum storage tanks, compressors, dispensers, piping, fittings,

allied equipment, and all kinds of safety devices.

3.2.3.13.3 Factories Act 1934

The clauses of this Act relevant to natural gas pipelines are those that concern the

H&S and welfare of workers, disposal of solid waste and effluent, and damage to


private and public property. The Act also provides regulations for handling and

disposing of toxic and hazardous materials.

3.2.3.14 Oil and Gas Regulatory Authority Ordinance 2002

This Ordinance provides for the establishment of the OGRA and defines its internal

organization. Powers and functions of the OGRA include:

· Granting licenses for carrying out regulated activities, including the supply of

natural gas, construction or operation of pipelines for natural gas or oil, and

construction or operation of natural gas or oil installations; and

· Promoting and ensuring the observance of efficient practices in the transmission,

distribution, processing, refining, marketing, and storage of petroleum, and the

transportation of petroleum by pipelines.

The Ordinance further provides for the establishment of an OGRA Fund, powers of

the federal government to issue policy guidelines to the OGRA, offences, and rule-

and regulation-making powers of the OGRA.

3.2.3.15 Regulation of Mines and Oilfields and Mineral Development 1[Government

Control] Act 1948

An Act to provide for the regulation of oilfields and for the development of [mineral oil

resources].

3.2.4 Provincial Legal and Regulatory Framework

In addition to national requirements, the ESIA must also consider the relevant

provincial laws and regulations to assess Project compliance with local requirements.

Table 3-3 and Table 3-4 list the provincial laws and regulations relevant to the Project

in the Punjab Province and Balochistan Province, respectively. The main

requirements provincial E&S legislation are summarized in the subsections below.

Table 3-3: Punjab Province Legislative Framework

Title Date


Punjab Canal and Drainage (Amendment) Act 1873 – amended in 2016

Punjab Forest (Amendment) Act 1927 – amended in 2016

Punjab Environmental Protection Act 1997 – amended in 2012

Punjab Wildlife Protection, Preservation, Conservation and Management

(Amendment) Act

2007

Punjab Wetlands Policy 2012

Punjab EPA Review of IEE and EIA Regulations 2016

Environmental Guidelines

Environmental Quality Standards for Ambient Air 2016

Environmental Quality Standards for Drinking Water 2016

Environmental Quality Standards for Motor Vehicle Exhaust and Noise 2016

Environmental Quality Standards for Noise 2016

Local Government – Land Acquisition


Title Date

Punjab Acquisition of Lands (Housing) Act 1973 – repealed in 1985

Punjab Land Utilization Authority Ordinance 1981

Punjab Land Acquisition Rules 1983

Punjab Land Preservation Act 1990

Land Acquisition (Punjab Amendment) Ordinance 1894 – amended in 2001

Punjab Land Use (Classification, Reclassification and Redevelopment) Rules 2009

Punjab Private Housing Schemes and Land Sub-Division Rules 2010

Punjab Housing and Town Planning Agency (Amendment) Act 2002 – amended in 2012

Punjab Land Records Manual / The Punjab Land Administration Manual 2004

Punjab Local Government Act 2013 – amended in 2017

Punjab Land Records Authority Ordinance 2016

The Punjab Land Records Authority Act 2017

Punjab Local Governments (property) rules 2018

Resettlement

Evacuee Property and Displaced Persons Laws (Repeal) (Amendment) Act 1975 – amended in 2012


The Antiquities (Amendment) Act 1975 – amended in 2012

Human Environment

The Punjab Commission on The Status of Women Act 2014

The Punjab Social Protection Authority Act 2015

The Punjab Restriction on Employment of Children Act 2016

Population Policy 2017

Punjab Women Protection Authority Act 2017

Table 3-4: Balochistan Province Legislative Framework

Title Date


Balochistan Canal and Drainage Ordinance 1980 - amended in 2000 and

2006

Balochistan Forest Regulation (Amendment) Act 1974

Balochistan Integrated Water Resources Management Policy 2004

Balochistan Environment Protection Act 2012

Balochistan Wildlife Protection, Preservation, Conservation and Management Act 2014


Balochistan Culture Heritage Preservation Act 2010

Human Environment

The Balochistan Child Act 2016

Local Government

Balochistan Local Government Act 2010

3.2.4.1 Punjab and Balochistan Environmental Protection Acts

Before the passage of the 18th constitutional amendment by the parliament, the

Punjab government had enforced the Punjab Environmental Protection Act 1997 in

the province, which was originated and derived from the PEPA 1997. After the

passage of the 18th constitutional amendment, the Punjab provincial assembly passed

the Punjab Environmental Protection (Amendment) Act 2012, which include 22

amendments to the original Act.


Similarly, before the enforcement of the Balochistan Environmental Protection Act

2012, the PEPA 1997 was the basic legislative tool to empower the national

government to frame regulations for the protection of the environment in the province.

After the passage of the 18th constitutional amendment by the parliament, the

Balochistan Environmental Protection Act 2012 was enforced.

These Acts provide the overarching framework for the protection of the environment

in Punjab and Balochistan provinces, applicable to air, water, soil, marine, and noise

pollution, and social and economic conditions of communities, ecosystems, and the

handling of hazardous waste. These Acts include conventions on plant protection,

wetlands, desert locust, aquaculture, and the Convention on Biological Diversity of

1992. They build on the provisions of the PEPA 1997 and localize them to the

provincial context.

As far as public administration of environmental matters is concerned, the Acts make

provision for the establishment of the Provincial Environmental Protection Council,

Provincial EPA, Provincial Sustainable Development Funds, and Environmental

Tribunals.

Compared to the PEPA 1997 and the Punjab Environmental Protection Act, the

Balochistan Environmental Protection Act includes additional definitions relating to

alien species, coastal zones, endemic and indigenous species, integrated pollution

control, Strategic Environmental Assessment (SEA), sustainable management, and

water resources. With the provision regarding SEA, the Balochistan Environmental

Protection Act emphasizes the need to incorporate environmental considerations in

policies, plans, and strategies for projects in various sectors. The Balochistan

Environmental Protection Act also provides general definitions of waste management

practices and prohibits the import of hazardous waste within the Balochistan Province

and its jurisdiction limits.

With regard to the ESIA Process, according to the Section 12 of the Punjab

Environmental Protection Act and Section 15 of the Balochistan Environmental

Protection Act, no proponent of a project shall commence construction or operation

unless they have developed with the provincial EPA an IEE or, where the project is

likely to cause an adverse environmental effect, an EIA, and has obtained from the

provincial EPA approval in respect thereof. The provincial Acts provide an option to

submit reports to both provincial EPAs in case of cross provincial coverage.

3.2.4.2 Punjab and Balochistan Forest Acts

These Acts provide rules with respect to reserved forests, waste lands, village forests,

and protected forests, and regulate the use of forest resources and the handling of

timber. Forest reserves are the property of the government and are managed by

Forest Settlement Officers, who may stop public or private ways or watercourses in

reserved forests. The Acts lay down actions that are prohibited in reserved forests.


The Acts also provide for the assignment of forests to village communities. The

provincial government regulates the management of village forests, prescribing the

conditions under which the community may be provided with timber or other forest

resources or pasture, and their duties for the protection and improvement of such

forests.

The Acts designate any forest land or waste land that is not reserved to be a protected

forest over which the government has proprietary rights, and regulate the use of forest

produce. The provincial government has the power to control forest lands and waste

lands that are not under their property in order to protect slopes, banks, and beds of

rivers. The Acts, among other things, provide for duties on timber and other forest

produce, control of timber and other forest produce in transit, collection of drift and

stranded timber, cattle trespass, appointment of forest officers, and offences and

penalties.

3.2.4.3 Punjab and Balochistan Canal and Drainage Ordinances

The Ordinances regulate irrigation, drainage, and canal construction and

maintenance. The Ordinances entitle the provincial government to use and control,

for public purposes, water of all rivers and streams flowing in natural channels, lakes,

sub-soil, and other natural collection of still water as for provisions of the main national

regulation.

3.2.4.4 Punjab and Balochistan Wildlife Protection, Preservation, Conservation and

Management Acts

The Balochistan Act supersedes the Balochistan Wildlife Protection Act 1974 and

Balochistan Wildlife Protection Rules 1975 with inclusion of newly introduced

legislative requirements.

Both Acts provide for the preservation, protection, management, and conservation of

wildlife by the formation and management of protected areas and prohibition of

hunting of wildlife species declared protected under the Acts. Three broad

classifications of protected areas are specified, namely, national parks, wildlife

sanctuaries, and game reserves. Unless in possession of a special authorization,

activities stated in Sections 15 to 17 of the Acts shall be prohibited in the

aforementioned protected areas.

In recognizing various levels of protected areas, the Acts implement the provisions of

international conventions and treaties to which Pakistan is member. Activities such as

hunting and breaking of land for mining are prohibited in national parks, as are

removing vegetation or polluting water flowing through a national park. The Acts also

define the penalties and punishment for whoever contravenes or attempts to

contravene the provisions or the rules and regulations made thereunder.

The Acts further encourage the active participation of local communities in the

protection of wildlife resources in the provinces. Community participation is further


encouraged through economic incentives and benefit sharing, through the principle of

co-management of protected areas and the promotion of livelihood activities in

protected areas.

3.2.4.5 Punjab Land Preservation Act 1900

This Act recognizes the power of the provincial government to temporarily regulate,

restrict, or prohibit certain activities in any area subject to erosion and take up

reforestation and soil conservation programs. The provincial government may also

require owners or occupiers of land subject to erosion to execute works or take

measures as specified in the Act, including:

· Levelling, terracing, drainage, and embanking of fields;

· Construction of earth-works in fields and ravines;

· Provision of drains for storm water; and

· Protection of land against the action of wind or water.

The Act further prescribes measures to regulate the beds of any stream or torrent

flowing through, or from, any mountain range within the province, to regulate the flow

of water within and to prevent the widening or extension of such bed, or to reclaim or

protect any land situated within the limits of such bed.

3.2.4.6 Punjab and Balochistan Local Government Acts

In accordance with the 18th Amendment to the Constitution, the provincial assembly

of Balochistan passed the Local Government (LG) Act in 2010, whereas the provincial

assembly of Punjab passed its LG Act in 2013. Provisions of these Acts include for

Punjab and Balochistan to have Union Councils and District Councils in the rural

areas, and Union Councils/Committees and Municipal Committees in the urban areas.

Each LG Act provides for the establishment of a Local Government Commission

(LGC), headed by the provincial Minister for LG and including members from the

provincial assembly, bureaucracy, and technocrats. In Balochistan, the LGC is named

the Divisional Coordination Committee. The LGCs perform inspections, social audits,

and dispute resolution for councils and submit reports and recommendations to the

provincial government.

The provinces authorize the Union, Village, and Neighborhood Councils to constitute

panels of Councilors to facilitate out-of-court dispute resolution and address citizens'

grievances. Punjab allows a nine-member Panchayat in rural areas and Musalehat-

e-Anjuman in urban areas (assemblies chosen by the local community), including two

women members nominated by the provincial government. Balochistan allows for a

three-member Musalehat-e-Anjumans in both rural and urban areas.

However, neither provincial Act devolves sufficient function and power to the local

government, and the provincial government have retained the authority to suspend or

remove the heads of an elected local government. The LG Acts of the two provinces

still tend to subordinate the local governments to the provincial governments. The


LG Acts state that the District Councils function under the directives of the provincial

government, giving the provincial government leverage over the local governments.

While all the LG Acts devolve the key service delivery functions to local governments,

provinces have made exceptions to retain large entities such as solid waste

management.

3.2.4.7 Punjab Social Protection Authority Act 2015

This Act, consisting of 26 Sections, creates the Punjab Social Protection Authority

(PSPA) to provide a comprehensive, efficient, effective, and inclusive social protection

system to the poor and vulnerable people in the Punjab Province. It establishes

composition, duties, and responsibilities of the PSPA, which is entitled to perform the

following activities:

· Formulate social protection policy for the Punjab in synergy with the federal

government and national and international institutions;

· Coordinate all public social protection initiatives through policy framework for

each sector, including federal government initiatives;

· Formulate policies and propose legislation for the welfare and benefit of the poor

and vulnerable;

· Ensure equitable allocation of resources;

· Prepare, store, and disseminate data regarding eligible poor and vulnerable

people;

· Evaluate the performance of social sector programs;

· Formulate policies for effective and efficient mechanisms for relevant agencies

and to evaluate performance of such agencies;

· Formulate and execute policies for social protection, which may include food,

education, health, social assistance, social inclusion, and labor market

regulations; and

· Conduct research and formulate proposals for new interventions into the existing

social protection programs to meet the targets for social protection.

3.2.4.8 Punjab Women Protection Authority Act 2017

This Act creates the Punjab Women Protection Authority (PWPA). It establishes

necessary provisions for a comprehensive, efficient, effective, and gender-equitable

system for the protection, relief, and rehabilitation of women against all forms of

violence in the Punjab. The Act also controls, monitors, and oversees that system,

deals with all related matters.

The Act entitles the PWPA to:

· Establish, maintain, monitor, govern, operate, and construct Protection Centers

in the Punjab;

· Initiate and maintain a continuous process of comprehensive planning for the

protection system;


· Execute, implement, and administer the protection system, relief to, and

rehabilitation of, women against violence;

· Control, monitor, and oversee the administration and functioning of the

Committee and protection system;

· Execute the policies made by the government for the provision of protection,

relief, and rehabilitation of women against all forms of violence;

· Undertake appropriate projects for purposes of the Act;

· Issue necessary instructions, directions, or guidelines to the Committee and

District Women Protection Officer, or any other officer or official engaged in the

protection system, or to any other body for the implementation of the projects of

the PWPA and for effective implementation of the provisions of the Act;

· Formulate and ensure minimum standards, codes of conduct, and standard

operating procedures to be followed by persons engaged in the protection

system;

· Evaluate, assess, and coordinate the execution of its policies;

· Conduct survey of the aggrieved persons desirous of being rehabilitated; and

· Institute a mechanism for the periodic sensitization and awareness of the public

servants and employees of the PWPA on issues involving women and protection

and relief of the aggrieved persons.

3.2.4.9 Balochistan Child Protection Act

The Act provides for the protection of children in Balochistan from all forms of physical

or mental violence, injury, neglect or negligent treatment, maltreatment or exploitation,

including sexual abuse. The Act establishes a Child Protection Commission within the

Social Welfare, Special Education, Literacy, Non-formal Education and Human Rights

Department for providing vision, policy guidelines, and appropriate strategies for child

protection, analysis of trends, and adjusting policies and measures for the protection

of children.

3.2.4.10 Punjab Land Acquisition Rules 1983

For the purposes of acquisition of land, the Punjab government has established the

Punjab Land Acquisition Rules 1983 under Section 55 of the LAA 1894. The

LAA 1894 and the Punjab Land Acquisitions Rules 1983 should be read together.

3.2.4.11 Punjab Land Records Authority Act

This Act establishes the Punjab Land Records Authority (PLRA) to:

· Reform and modernize the system of land records;

· Improve the land records service delivery;

· Contribute to long-lasting tenure security; and

· Deal with ancillary matters.

The Act establishes the composition, duties, and responsibilities of the PLRA, entitling

it to:


· Acquire and hold property (both movable and immovable);

· Establish regional offices at such other place or places in the Punjab as it deems

appropriate;

· Manage, update, and maintain land records;

· Formulate strategies, policies, and plans for the management of land records;

and

· Provide efficient and prompt services to the public.

3.2.4.12 Provincially Administered Tribal Areas

The Provincially Administered Tribal Areas (PATA) are Pakistani administrative

subdivisions designated in the Article 246(b) of the Constitution of Pakistan. No act of

a provincial assembly can be applied to PATA, whereas the Governor of the

respective province has mandate parallel to the authority that the President of

Pakistan has over the Federally Administered Tribal Areas. That is to say that no act

of a provincial assembly shall apply to a PATA, or to any part thereof, unless the

Governor of the province in which the PATA is situated, with the approval of the

President of Pakistan, guides in this direction. And in giving such a direction with

respect to any law, the President of Pakistan or, as the case may be, the Governor of

a province, may direct that the law shall, in its application to a PATA, or to a specified

part thereof, have effect subject to such exceptions and modifications as may be

specified in the direction.

Article 247 of the Constitution of Pakistan states that “Subject to the Constitution, the

executive authority of the province shall extend to the Provincially Administered Tribal

Areas”. The Governor of the province can change or extend laws to PATA only with

the President of Pakistan’s approval. The original PATA Regulation of 1975 vested

judicial authority in districts’ deputy commissioners, and empowered jirgas

(assemblies) to decide civil and other disputes under the supervision of the revenue

officer, thus giving the district bureaucracy and allied local traditional elites’ significant

authority. However, the PATA are subject to the jurisdiction of Pakistan’s regular court

system.

According to the Constitution of Pakistan, the Loralai district is under PATA in

Balochistan Province. This should be taken into account for resettlement purposes.

3.2.5 National Environmental Assessment Regulations and Procedures

3.2.5.1 Project Requirements for an EIA

Under Section 12 of the PEPA 1997, no project involving construction activities or any

change in the physical environment can be taken unless an IEE, or an EIA as

required, is conducted and a report submitted to the federal or provincial EPA.

The 2000 National Regulations provide the necessary details on the preparation,

submission, and review of the IEE and the EIA. In 2016, the Punjab EPA Review of


IEE and EIA Regulations have been issued following the devolution of power to

provinces.

EIA requirements at provincial level reflect the Pakistan regulations, prescribed

specifically under Section 12 of the Punjab Environmental Protection Act and

Section 15 of the Balochistan Environmental Protection Act, and further developed

into the 2016 Punjab EPA Review of IEE and EIA Regulations. Although the definition

of project includes plans and schemes, one very serious problem with the law is the

timing of the carrying out an IEE or an EIA. Under Section 12 of the PEPA 1997,

Section 12 of the Punjab Environmental Protection Act, and Section 15 of the

Balochistan Environmental Protection Act, the proponent of a project is required to

submit the environmental assessment reports only very late in the scheme of things

(that is, prior to commencing construction or operation of a project and not at the

planning stage).

The federal and provincial regulations classify projects on the basis of expected

degrees of adverse environmental impacts, and list them in two separate schedules

as follows:

· Schedule I lists projects that may not have significant environmental impacts and

therefore require an IEE, such as oil and gas transmission systems; and

· Schedule II lists projects of potentially significant environmental impacts requiring

preparation of an EIA (all projects located in environmentally sensitive areas

require preparation of an EIA).

Although the TAPI Project falls under the list of projects requiring only an IEE

(Schedule I, oil and gas transmission systems), an EIA has been developed due to

following reasons:

· Cross-provincial coverage, which may require the involvement of provincial and

federal EPAs due to its national importance and environmental issues, in their

complexity and variety, which are often inter-sectoral and regional. However,

under devolution of powers, approval lies with the provincial EPAs;

· Magnitude, scale, and cost of the Project, including but not limited to its likely

resource requirements and impacts. It is important to note that the Punjab EPA

has listed oil and gas transmission systems having cost more than

PKR 100 million under Schedule II of its Draft EIA Regulations 2016; and

· ROW located within, or close to, environmentally sensitive areas and protected

forests, especially in Balochistan Province.

The Punjab and Balochistan EPAs are the main stakeholders for issuance of the NOC

for the Project against the EIA. According to the PEPA 1997 and the 2000 National

Regulations, the relevant EPA upon receiving the EIA from the proponent will confirm

within ten working days that their submitted report meets the review prerequisites.

During this time, should the concerned EPA require the proponent to submit any

additional information, it will return the EIA to the proponent for revision, clearly listing

those aspects that need further discussion. Subsequently, the relevant EPA will make


every effort to complete an EIA review within 90 days of filing, reviewed by an expert

EIA Review Committee constituted of officials mainly from the EPA. Public

consultation is a mandatory part of the EIA process. Provincial EPAs conduct the EIA

review and public hearing before granting an environmental approval.

The overview of the procedure for submitting an EIA report in Pakistan and its review

process is shown in Figure 3-1.

Figure 3-1: EIA Submission and Approval Process in Pakistan

Source: GOP, 2014

3.2.5.2 National Guidelines for EIA Development

The Pak-EPA prepared the Pakistan Environmental Assessment Procedures

package in 1997. The guidelines pertaining to the review process of IEEs and EIAs


were given regulatory status in the 2000 National Regulations. They are based on

much of the existing work done by international donor agencies and Non-

Governmental Organizations (NGOs). The package of regulations prepared by Pak-

EPA includes:

· Policies and procedures for filing, review, and approval of environmental

assessments;

· Guidelines for the preparation and review of environmental reports;

· Guidelines for public consultation;

· Guidelines for sensitive and critical areas; and

· Sectoral guidelines (no guidelines for natural gas pipeline projects have been

issued so far).

The guidelines on policies and procedures define the policy context and the

administrative procedures that will govern the environmental assessment process,

from the project pre-feasibility stage, to the approval of the environmental report.

According to the procedures laid out in the policy guidelines, IEEs or EIAs are to be

approved by the provincial EPA where the project is to be implemented. However, the

Pak-EPA has been given the right to review any environmental report at any time and

the power to revoke the decision of the provincial EPA, if it deems this to be

necessary.

The guidelines for the preparation and review of environmental reports cover:

· The initial environmental report (scoping, alternatives, site selection, format of

IEE);

· Assessing impacts (identification, analysis and prediction, baseline data,

significance);

· Mitigation and impact management (and preparing the Environmental

Management Plan [EMP]);

· Reporting;

· Review and decision-making;

· Monitoring and auditing; and

· Project management.

In the preparation of the environmental report, the project proponent shall:

· Consult with appropriate federal and / or provincial agencies;

· Obtain required information for the preparation of the report, including baseline

data collection;

· Assess potential impacts and suitable mitigation measures;

· Consult affected communities and relevant NGOs; and

· Take account of the comments and views received from agencies and the

community.


The guidelines require that all environmental assessment studies contain baseline

data on the area, a detailed assessment of the potential environmental impacts, and

the recommended mitigation measures.

The guidelines on public consultation deals with possible approaches to public

consultation and techniques for designing an effective program of consultation, which

reaches out to all major stakeholders and ensures the incorporation of their concerns

in any impact assessment study. Consultations with the communities that are most

likely to be affected and relevant NGOs are to be an integral part of the EIA process.

According to Regulation 10 of the 2000 National Regulations, public participation in

the EIA process does not begin until an EIA report is submitted to the provincial

agency. There is no public involvement at IEE level (screening), but public

involvement at the beginning of the EIA process is commonly known as a scoping

meeting. This is a key stage for informing the public about a proposed activity and

framing issues that will be discussed in the environmental report. This step is often

combined with the process for determining the terms of reference for the report.

The guidelines on sensitive areas are more specific in that they identify the officially

notified protected areas in Pakistan, including critical ecosystems and archaeological

sites. These guidelines identify protected areas in Pakistan and provides detailed

guidance on the approach to adopt. The protected areas include wildlife reserves,

forests, and cultural heritage sites. It presents the requirements for the consideration

of sensitive and critical areas during environmental assessment, as well as a list of

nationally protected natural and cultural heritage. All projects proposed in

environmentally sensitive areas (including game reserves and wildlife sanctuaries)

require an EIA.

The guidelines for the preparation and review of environmental reports provide

detailed required on the content of EIA reports, as well as the drafting style of the

report. The basis of determining the scope of the EIA derives from the sectoral

guidelines with the checklist of likely impacts and mitigation measures.

3.2.5.3 EIA Approval Process

According to the 2000 National Regulations, the Project Proponent is required to

submit the EIA report to respective provincial EPAs. Ten hard copies and two soft

copies of the EIA report will need to be separately submitted to the Punjab and

Balochistan EPAs. EPAs will grant their decision on the EIA as per the rules and

procedures set out in the 2000 National Regulations. The following rules apply:

· A fee is payable to the Punjab and Balochistan EPAs for review of the EIA;

· The EIA submittal is to be accompanied by an application in the format prescribed

in Schedule IV of the 2000 National Regulations;

· The Punjab and Balochistan EPAs are bound to conduct a preliminary scrutiny

and reply within ten days of the submittal of the report to:

- confirm completeness;


- ask for additional information, if needed; and

- return the report requiring additional studies, if necessary;

· The Punjab and Balochistan EPAs will publish a public notice in any English or

Urdu national newspaper, and in a local newspaper of general circulation in the

area affected by the Project, mentioning the following:

- type of Project;

- location of the Project;

- name and address of the Project Proponent;

- places at which the EIA can be accessed; and

- the date, time, and place for public hearing of any comments on the Project

or its EIA (the public hearing will not be earlier than 30 days from the date of

publication of the public notice, the EIA consultant and the Project Proponent

are required to present and defend the findings of the EIA during the public

hearing);

· In the review process, EPAs may consult a committee of experts;

· On completion of the review process and the public hearing, the decision of EPAs

will be communicated to the Project Proponent in the form prescribed in

Schedule VI of the 2000 National Regulations;

· Where an EIA is approved, EPAs can impose additional controls as part of the

conditions of approval;

· The Punjab and Balochistan EPAs are required to make every effort to complete

the EIA review process within 90 and 45 days, respectively, of the issue of

confirmation of completeness (however, EPAs can take up to four months to

communicate the final decision);

· EIA approval shall be valid for a period of three years from the date of its

issuance, or for the Project duration mentioned in the EIA but on the condition

that the Project commences within a period of three years from the date of

approval;

· If the Project is initiated after three years from the approval date, the Project

Proponent will have to apply for an extension in the validity period from respective

EPAs (EPAs on receiving such request may either grant the extension [not more

than three years at a time] or require the Project Proponent to submit a new EIA

if in the opinion of EPA changes in baseline conditions or the Project so warrants);

· After receiving approval from the EPAs, the proponent will acknowledge

acceptance of the conditions of approval by executing an undertaking in the form

prescribed in Schedule VII of the 2000 National Regulations;

· The 2000 National Regulations also require proponents to obtain from EPAs,

after the end of construction phase of the Project, a confirmation that the

requirements of the EIA and the conditions of approval have been duly complied

with (the Punjab and Balochistan EPAs are required to issue confirmation of

compliance within 15 days of the receipt of a request and complete

documentation, accompanied by an EMP);


· The EPAs in granting the confirmation of compliance may impose any additional

control regarding the environmental management of the Project or its operation,

as necessary; and

· It is required that a monitoring report be submitted to the Punjab and Balochistan

EPAs after completion of survey/operation, followed by annual monitoring reports

during Project operation (the required contents of the monitoring report are not

described in the regulations).

Based on ESIA approvals, both the Punjab and Balochistan EPAs have issued NOCs

for the TAPI Project in 2019, as presented in Figure 3-2 and Figure 3-3.

Figure 3-2: Punjab EPA Environmental Approval for the TAPI Project

Source: Punjab EPA, 2019


Figure 3-3: Balochistan EPA Environmental Approval for the TAPI Project

Source: Balochistan EPA, 2019

3.3 International Conventions, Treaties, and Agreements

Pakistan is a signatory to various international conventions, treaties, and agreements

associated with the protection of the environment and human rights, as summarized

in Table 3-5. These conventions, treaties, and agreements are considered as

evidence of emerging international principles and indicators of the likely trajectory of

national laws in Pakistan.

Table 3-5: International Conventions, Treaties, and Agreements to which Pakistan is Signatory

Title Description Date Status for Pakistan

Chemical and Hazardous Waste

Basel Convention on

the Control of

Transboundary

Movements of

Hazardous Wastes

Aimed at protecting human health and the environment against the

adverse effects of hazardous wastes. The provisions of the Convention

centers around the following principal aims:

· The reduction of hazardous waste generation and the promotion of environmentally sound management of hazardous wastes, wherever the place of disposal;

1989 Accessed

in 1994


Title Description Date Status for

Pakistan

· The restriction of transboundary movements of hazardous wastes, except where it is perceived to be in accordance with the principles of environmentally sound management; and

· A regulatory system applying to cases where transboundary movements are permissible.

Rotterdam

Convention on the

Prior Informed

Consent Procedure

for Certain Hazardous

Chemicals and

Pesticides in

International Trade

The Convention covers pesticides and industrial chemicals that have

been banned or severely restricted for health or environmental reasons.

The Convention aims to:

· Promote shared responsibility and cooperative efforts among Parties in the international trade of certain hazardous chemicals in order to protect human health and the environment from potential harm; and

· Contribute to the environmentally sound use of those hazardous chemicals, by facilitating information exchange about their characteristics, by providing for a national decision-making process on their import and export and by disseminating these decisions to Parties.

1998 Ratified in

2005

Stockholm

Convention on

Persistent Organic

Pollutants

This is a global treaty to protect human health and the environment from

chemicals that remain intact in the environment for long periods,

become widely distributed geographically, accumulate in the fatty tissue

of humans and wildlife, and have harmful impacts on human health or

on the environment.

2001 Ratified in

2008

Biodiversity

Convention on

Biological Diversity

The Convention is dedicated to promoting sustainable development and

was conceived as a practical tool for translating the principles of Agenda

21 into reality. The main goals of the Convention include:

· The conservation of biological diversity (or biodiversity);

· The sustainable use of its components; and

· The fair and equitable sharing of benefits arising from genetic resources.

1992 Ratified in

1994

Convention on

Wetlands of

International

Importance (Ramsar)

The obligations of signatories of the Ramsar Convention are:

· To designate wetlands for the List of Wetlands of International Importance;

· To formulate and implement planning so as to promote wise use of wetlands, to make EIA before transformations of wetlands, and to make national wetland inventories;

· To establish nature reserves on wetlands and provide adequately for their wardenship and through management to increase waterfowl populations on appropriate wetlands;

· To train personnel competent in wetland research, management, and wardenship;

· To promote conservation of wetlands by combining far-sighted national policies with coordinated international action, to consult with other contracting parties about implementing obligations arising from the Convention, especially about shared wetlands and water system;

· To promote wetland conservation concerns with development aid agencies; and

· To encourage research and exchange of data.

1971 Ratified in

1976

Convention on

International Trade in

Endangered Species

(CITES)

The CITES requires the signatories to impose strict regulation (including

penalization and confiscation of the specimen) on the trading of all

species threatened with extinction or that may become so, in order not

to endanger further their survival.

The CITES contains three appendices, as follows:

· Appendix I includes all species threatened with extinction, which are or may be affected by trade (the CITES requires that trade in these species should be subject to strict regulation);

· Appendix II includes species that are not necessarily threatened presently but may become so unless trade in specimens of these species is subject to strict regulation; and

1973 Accessed

in 1976



Pakistan

· Appendix III includes species that any contracting party identifies as subject to regulations in trade and requires other parties to cooperate in this matter.

Convention on the

Conservation of

Migratory Species of

Wild Animals (CMS) –

Also known as Bonn

Convention

The CMS requires countries to take action to avoid endangering

migratory species. The term migratory species refers to the species of

wild animals, a significant proportion of whose members cyclically and

predictably cross one or more national jurisdictional boundaries. The

Parties are also required to promote or cooperate with other countries in

matters of research on migratory species.

The CMS contains two appendices, as follows:

· Appendix I contains the list of migratory species that are endangered according to the best scientific evidence available, for which the CMS member states are required to:

- conserve and restore their habitats;

- prohibit their hunting, fishing, capturing, harassing, and deliberate killing;

- remove obstacles and minimize activities that seriously hinder their migration; and

- control other factors that might endanger them, including control of introduced exotic species;

· Appendix II lists the migratory species, or groups of species, that have an unfavorable conservation status and those that would benefit significantly from the international cooperation that could be achieved through intergovernmental agreements.

1979 Ratified in

1987

Cultural and Natural Heritage

Convention for the

Safeguarding of the

Intangible Cultural

Heritage

The purpose of this Convention is to:

· Safeguard the intangible cultural heritage;

· Ensure respect for the intangible cultural heritage of the communities, groups, and individuals concerned;

· Raise awareness at the local, national, and international levels of the importance of the intangible cultural heritage, and of ensuring mutual appreciation thereof; and

· Provide for international cooperation and assistance.

2003 Ratified in

2005

Convention

concerning the

Protection of the

World Cultural and

Natural Heritage

This Convention notes the cultural heritage and the natural heritage that

are increasingly threatened with destruction not only by the traditional

causes of decay, but also by changing social and economic conditions

that aggravate the situation with even more formidable phenomena of

damage or destruction.

1972 Ratified in

1976

Climate Change/Atmosphere

Paris Agreement The Paris Agreement seeks to accelerate and intensify the actions and

investment needed for a sustainable, low carbon future. Its central aim

is to strengthen the global response to the threat of climate change by

keeping a global temperature rise this century well be-low 2 degrees

Celsius (°C) above pre-industrial levels and to pursue efforts to limit the

temperature increase even further to 1.5 °C.

The Paris Agreement also aims to strengthen the ability of countries to

deal with the impacts of climate change.

2016 Ratified in

2016

United Nations

Framework

Convention on

Climate Change (UN

FCCC)

The objective of the UN FCCC is to stabilize greenhouse gas (GHG)

concentrations in the atmosphere at a level that would prevent

dangerous anthropogenic interference with the climate system.

It provides a framework for international cooperation to combat climate

change by limiting average global temperature increases and the

resulting climate change and coping with impacts.

1992 Ratified in

1997

Kyoto Protocol to

UN FCCC

The Kyoto Protocol is linked to the UN FCCC and commits its Parties by

setting internationally binding emission reduction targets.

1997 Accessed

in 2005

Vienna Convention

for the Protection of

the Ozone Layer

The Convention acts as a framework for the international efforts to

protect the ozone layer.

1985 Ratified in

1992



Pakistan

Montreal Protocol on

Substances that

Deplete the Ozone

Layer and its

Amendments

The Montreal Protocol is designed to protect the ozone layer by phasing

out the production of numerous substances that are responsible for

ozone depletion.

Members of the Protocol commit to gradually eliminating the production

and consumption of ozone depleting substances to limit their damage to

the earth's ozone layer.

1987 Accessed

in 1992

Land/Environmental Cooperation

United Nations

Convention to

Combat

Desertification in

those Countries

Experiencing Serious

Drought and/or

Desertification

The Convention is the sole legally binding international agreement

linking the environment and development to sustainable land

management.

It is aimed at working together and encouraging the participation of local

people in combating desertification and land degradation to:

· Improve the living conditions for people in drylands;

· Maintain and restore land and soil productivity; and

· Mitigate the effects of drought.

1994 Ratified in

1997

Rio Declaration on

Environment and

Development

The Rio Declaration on Environment and Development is a set of

principles that recognize the importance of preserving the environment

and set forth international guidelines for doing so.

1992 Ratified in

1992

Labor/Human Rights International Labor

Organization (ILO)

Convention 81: Labor

Inspection

ILO members must maintain a system of labor inspection in industrial

workplaces in order to secure the enforcement of legal provisions

relating to working conditions, advise employers and workers on how to

comply with provisions, and bring to the notice of the competent

authority defects or abuses not specifically covered by existing legal

provisions.

1947 Ratified in

1953

ILO Convention 95:

Protection of Wages

Wages payable in money shall be paid only in legal tender, and

payment in the form of promissory notes, vouchers or coupons, or in

any other form alleged to represent legal tender, shall be prohibited.

1949

ILO Convention 105:

Abolition of Forced

Labor

Convention undertakes to suppress and not to make use of any form of

forced or compulsory labor:

· As a means of political coercion or education or as a punishment for holding or ex-pressing political views or views ideologically opposed to the established political, social or economic system;

· As a method of mobilizing and using labor for purposes of economic development;

· As a means of labor discipline;

· As a punishment for having participated in strikes; or

· As a means of racial, social, national or religious discrimination.

1957 Ratified in

1960

ILO Convention 107:

Indigenous and Tribal

Populations

Governments are responsible for protecting and enabling the integration

of indigenous and other tribal or semi-tribal populations into the life of

their respective countries.

1957 Ratified in

1960

ILO Convention 111:

Discrimination,

Employment and

Occupation

No distinction, exclusion, or preference made on the basis of race,

color, sex, religion, political opinion, national extraction, or social origin

will have the effect of nullifying or impairing equality of opportunity or

treatment in employment or occupation.

1958 Ratified in

1961

ILO Convention 138:

Minimum Age

Members of this Convention will pursue a national policy designed to

ensure the effective abolition of child labor and to progressively raise

the minimum age for admission to employment or work to a level

consistent with the fullest physical and mental development of young

persons.

1973 Ratified in

2006

ILO Convention 182:

Worst Form of Child

Labor

Members of this Convention shall take immediate and effective

measures to secure the prohibition and elimination of the worst forms of

child labor as a matter of urgency.

1999 Ratified in

2001

Source: United Nations Treaty Collection, 2017


3.4 International Policies, Guidelines, and Standards

This ESIA report complies with the international policies, guidelines, and standards

discussed in this section. Where multiple references exist for a single topic, the most

stringent will be applied on the Project.

3.4.1 IFC Performance Standards and EHS Guidelines

3.4.1.1 IFC Performance Standards

The IFC, a member of the World Bank Group, is the largest global development

institution serving the private sector in developing countries. The IFC and most of the

international credit granting institutions adopt, in their credit granting policy, eight PSs

that provide guidance on the way to identify and associate measures to avoid,

minimize, and manage socio-environmental risks and impacts, to increase the

opportunities for sustainable development. The IFC PSs have been adopted by the

World Bank Group and are generally considered as international good practice for

development projects.

The IFC PSs are considered as being equivalent to, or more stringent than, other

sources of guidance discussed in this section. Therefore, TPCL has adopted the

IFC PSs as the international reference standard for their E&S strategies and will

comply with these requirements throughout all stages of the Project.

The eight IFC PSs are:

· PS 1: Assessment and Management of Environmental and Social Risks and

Impacts;

· PS 2: Labor and Working Conditions;

· PS 3: Resource Efficiency and Pollution Prevention;

· PS 4: Community Health, Safety and Security;

· PS 5: Land Acquisition and Involuntary Resettlement;

· PS 6: Biodiversity Conservation and Sustainable Management of Living Natural

Resources;

· PS 7: Indigenous Peoples; and

· PS 8: Cultural Heritage.

Table 3-6 presents an overview of the main requirements of each of the IFC PSs

relevant to this Project. This is further supported by Figure 3-4, which presents a flow

chart of the IFC requirements for an ESIA process.

Table 3-6: Overview of IFC Performance Standards

IFC PS Management Planning Requirements

PS 1: Assessment

and Management

of Environmental

and Social Risks

and Impacts

PS 1 establishes the importance of:

· Integrated assessment to identify the E&S impacts, risks, and opportunities of projects;

· Effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them; and

· The client’s management of E&S performance throughout the life of the project.



The objectives of PS1 are to:

· Identify and evaluate E&S risks and impacts of the project;

· Adopt a mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimize, and, where residual impacts remain, compensate/offset for risks and impacts to workers, Affected Communities, and the environment;

· Promote improved E&S performance of clients through the effective use of management systems;

· Ensure that grievances from Affected Communities and external communications from other stakeholders are responded to and managed appropriately; and

· Promote and provide means for adequate engagement with Affected Communities throughout the project cycle on issues that could potentially affect them and to ensure that relevant E&S information is disclosed and disseminated.

The client, in coordination with other responsible government agencies and third parties as

appropriate, will conduct a process of E&S assessment, and establish and maintain an ESMS

appropriate to the nature and scale of the project and commensurate with the level of its E&S

risks and impacts

Conduct stakeholder engagement, which is an ongoing process that may involve the following

elements: stakeholder analysis and planning, disclosure and dissemination of information,

consultation and participation grievance mechanism, and ongoing reporting to affected

communities.

PS 2: Labor and

Working

Conditions

PS 2 aims to

· Promote the fair treatment, non-discrimination, and equal opportunity of workers;

· Establish, maintain, and improve the worker-management relationship;

· Promote compliance with national employment and labor laws;

· Protect workers, including vulnerable categories of workers such as children, migrant workers, workers engaged by third parties, and workers in the client’s supply chain;

· Promote safe and healthy working conditions, and the health of workers; and

· Avoid the use of forced labor.

PS2 applies to direct workers, contract workers and supply chain workers.

Other key requirements of PS 2 include:

· Workers must be provided with documented information that is clear and understandable, regarding their rights under national labor and employment law and any applicable collective agreements;

· Respect the collective bargaining agreement with a workers’ organization;

· Comply with the national law;

· Provide a grievance mechanism for workers (and their organizations, where they exist) to raise workplace concerns;

· Do not employ children in any manner that is economically exploitative, or is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s heath or physical, mental, spiritual, moral, or social development;

· Do not employ forced labor; and

· Provide a safe and healthy work environment, considering inherent risks in its particular sector and specific classes of hazards in the client’s work areas, including physical, chemical, biological, and radiological hazardous, and specific threats to women.

PS 3: Resource

Efficiency and

Pollution

Prevention

The aim of PS 3 is to:

· Avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from project activities;

· Promote more sustainable use of resources, including energy and water; and

· Reduce project-related GHG emissions.

Other key elements of PS 3 include:

· World Bank/IFC EHS Guidelines, or other internationally recognized sources, will be used when selecting pollution prevention techniques for the Project;

· When host country regulations differ from the levels and standards presented in the EHS Guidelines, the more stringent will apply;

· Technically feasible and cost-effective measures for improving resource efficiency shall be implemented;

· Projects with significant waste consumption shall adopt measures to avoid or reduce water usage;

· Consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions;



· Quantify GHG emissions annually in accordance with internationally recognized methodologies and good practice;

· Consider ambient conditions and avoid / minimize the release of pollutants to air;

· Consider routine, non-routine, and accidental circumstances with the potential for local, regional, and transboundary impacts;

· Consider additional strategies for pollution control in an already degraded area; and

· Avoid the generation of hazardous and non-hazardous wastes materials.

PS 4: Community

Health, Safety and

Security


· Anticipate and avoid adverse impacts on the health and safety of the Affected Community during the project life from both routine and non-routine circumstances; and

· Ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.

Other key requirements of PS 2 include:

· Evaluate the risks and impacts to the health and safety of the Affected Communities during the project life-cycle and establish preventive and control measures consistent with good international industry practice (GIIP), such as EHS Guidelines or other internationally recognized sources;

· Identify risks and impacts and propose mitigation measures that are commensurate with their nature and magnitude;

· Avoid or minimize the potential for community exposure to hazardous materials and substances, water-borne, water-related, and vector-borne diseases, and communicable diseases that could result from project activities;

· Avoid or minimize transmission of communicable diseases that may be associated with the influx of temporary or permanent project labor;

· Risks and impacts potentially posed by security arrangements to those within and outside the project site, shall be assessed;

· Hiring, rules of conducts, training, equipping, and monitoring of security personnel shall follow GIIP and applicable law; and

· A grievance mechanism will be provided for Affected Communities to express concerns about the security personnel.



PS 5: Land

Acquisition and

Involuntary

Resettlement


· Avoid, and when avoidance is not possible, minimize displacement by exploring alternative project designs;

· Avoid forced eviction;

· Anticipate and avoid, or where avoidance is not possible, minimize adverse social and economic impacts from land acquisition or restrictions on land use by:

- providing compensation for loss of assets at replacement cost; and

- ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected;

· Improve, or restore, the livelihoods and standards of living of displaced persons; and

· Improve living conditions among physically displaced persons through the provision of adequate housing with security of tenure at resettlement sites.

Key requirements of PS 5 include:

· Consider feasible alternative project designs to avoid or minimize physical and/or economic displacement;

· When displacement cannot be avoided, offer displaced communities and persons compensation for loss of assets at full replacement cost and other assistance to help them improve or restore their standards of living;

· Engage with Affected Communities through the process of stakeholder engagement and establish a grievance mechanism;

· In the case of physical displacement, develop a Resettlement Action Plan (RAP);

· Persons who have formal legal rights to the land or assets they occupy or use, or persons who do not have formal legal rights to land or assets but have a claim to land that is recognized or recognizable under national law, offer them the choice of replacement property of equal or higher value, security of tenure, equivalent or better characteristics, and advantages of location or cash compensation, where appropriate, however compensation in kind should be considered in lieu of cash;

· Persons who have no recognizable legal right or claim to the land or assets they occupy or use, offer them a choice of options for adequate housing with security of tenure so that they can resettle legally without having to face the risk of forced eviction;

· In the case of economic displacement only, develop a Livelihood Restoration Plan (LRP) to compensate Affected Persons and/or Communities; and

· Economically displaced persons will be compensated for loss of assets or access to assets at full replacement cost; in addition, economically displaced persons will also be provided opportunities to improve, or at least restore, their means of income-earning capacity, production levels, and standards of living.

PS 6: Biodiversity

Conservation and

Sustainable

Management of

Living Natural

Resources

The objective of PS 6 is to:

· Protect and conserve biodiversity;

· Maintain the benefits from ecosystem services;

· Promote the sustainable management of living natural resources through the adoption of practices that integrate conservation needs and development priorities;


· Avoid impacts on biodiversity and ecosystem services, or implement measures to minimize impacts and restore biodiversity and ecosystem services;

· Consider modified, natural, and critical habitats;

· Consider biodiversity offsets, but only after appropriate avoidance, minimization, and restoration measures have been applied;

· Do not intentionally introduce any new alien species unless this is carried out in accordance with the existing regulatory framework for such introduction;

· Conduct a systematic review to identify priority ecosystem services, and minimize adverse impacts to them; and

· When a project is purchasing primary production produced in regions where there is a risk of significant conversions of natural and / or critical habitats, primary suppliers will be evaluated as part of the Environmental and Social Management System (ESMS) of the project.



PS 7: Indigenous

Peoples

The objective of PS 7 is to:

· Ensure that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples;

· Anticipate and avoid adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimize and/or compensate for such impacts;

· Promote sustainable development benefits and opportunities for Indigenous Peoples in a culturally appropriate manner;

· Establish and maintain an ongoing relationship based on Informed Consultation and Participation (ICP) with the Indigenous Peoples affected by a project throughout the project’s life-cycle;

· Ensure the Free, Prior, and Informed Consent (FPIC) of the Affected Communities of Indigenous Peoples when the circumstances described in this Performance Standard are present; and

· Respect and preserve the culture, knowledge, and practices of Indigenous Peoples.


· Identify all communities of Indigenous Peoples within the PAI who may be affected by the project, as well as the nature and degree of the expected direct and indirect economic, social, cultural (including cultural heritage) and environmental impacts on them;

· Adverse impacts on affected communities of Indigenous Peoples should be avoided where possible, and if unavoidable, the impacts will be minimized, restored and/or compensated for;

· Any actions will be developed with the ICP of Indigenous Peoples and contained in an Indigenous Peoples Plan;

· Undertake an engagement process with the Affected Communities of Indigenous Peoples as required in PS 1;

· FPIC will be exercised if:

- impacts on lands and natural resources subject to traditional ownership or under customary use are expected;

- relocation of Indigenous Peoples from lands and natural resources subject to traditional ownership or under customary use take place; and

- critical cultural heritage is affected;

· Where government is responsible for managing Indigenous Peoples issues, collaborate with them, to the extent feasible, to achieve outcomes consistent with PS 7; and

· Where government capacity is limited, play an active role during planning, implementation, and monitoring of activities, and prepare a plan to document such information.

PS 8: Cultural

Heritage


· Protect cultural heritage from the adverse impacts of project activities and support its preservation; and

· Promote the equitable sharing of benefits from the use of cultural heritage.


· In addition to complying with the national law, implementing the host country’s obligations under the World Heritage Convention, identify and protect cultural heritage by ensuring that internationally recognized practices for the protection, field-based study, and documentation of cultural heritage are implemented;

· Where the risk and identification process determine that there is a chance of impacts to cultural heritage, retain competent professionals to assist the identification and protection of cultural heritage;

· Site and design the project to avoid significant adverse impacts to cultural heritage;

· Determine whether the proposed location of a project is in areas where cultural heritage is expected to be found, either during construction or operations;

· As part of the ESMS, develop provisions for managing chance finds through a chance finds procedure, which will be applied if cultural heritage is subsequently discovered; and

· Do not remove, significantly alter, or damage critical cultural heritage.

Source: IFC, 2012


Figure 3-4: ESIA Process as Presented in IFC Performance Standards



Early on in the ESIA Process, a gap analysis was performed comparing national

legislative requirements with the IFC PSs. Areas of divergence were highlighted with

information presented on the measures that will be undertaken by the Project to

ensure compliance with both national legislation and alignment with IFC

requirements. The gap analysis is presented in Appendix B1.

3.4.1.2 World Bank/IFC EHS Guidelines

Since IFC PSs are primarily general and qualitative guidelines, they often do not

provide quantitatively targetable goals. Therefore, to further support the IFC PSs, the

World Bank Group has published a set of EHS Guidelines jointly developed with the

IFC, which are defined in the IFC PSs as technical reference documents with general

and industry-specific examples of GIIP. In essence, the IFC PSs reference the

World Bank Group EHS Guidelines and other industry-specific EHS guidelines as

standards to be incorporated into ESIAs and facility compliance assurance programs.

The World Bank Group has also published sector-specific EHS Guidelines, which are

designed to be used together with the General EHS Guidelines and provide guidance

to users on common EHS issues potentially applicable to all industry sectors.

For the TAPI Project, the following are applicable, in whole or in part:

· General EHS Guidelines; and

· EHS Guidelines for Onshore Oil and Gas Development.

3.4.2 ADB Environmental and Social Assessment Guidelines

The following standards, manuals, and policy documents published by the ADB are

relevant to the Project:

· Safeguard Policy Statement (SPS) (2009);

· Safeguard Requirements 1: Environment (SR 1) (2009);

· Safeguard Requirements 2: Involuntary Resettlement (SR 2) (2009);

· Safeguard Requirements 3: Indigenous Peoples (SR 3) (2009);

· Policy on Gender and Development (2003);

· Operations Manual: Section C2, Gender and Development in ADB Operations

(2010); and

· Operations Manual: Section F1, Safeguard Policy Statement (2013).

ADB’s SPS sets out the objectives, principles, and delivery process of ADB’s

safeguard policy. The objectives of ADB’s safeguards are to:

· Avoid adverse impacts of projects on the environment and affected people, where

possible;

· Minimize, mitigate, and/or compensate for adverse project impacts on the

environment and affected people when avoidance is not possible; and

· Help borrowers/clients to strengthen their safeguard systems and develop the

capacity to manage E&S risks.


Borrowers and clients of ADB are expected to comply with SR 1, SR 2 and SR 3

during both project preparation and project implementation. All three SRs include

requirements for impact assessment, planning, and mitigation to be undertaken

throughout the project cycle to address adverse E&S effects.

The Policy on Gender and Development requires gender concerns to be treated as a

cross-cutting theme across all social and economic processes. It aims to promote

gender equity by mainstreaming gender issues into all ADB activities. Projects will

need to consider gender issues at all appropriate stages of the project cycle.

The Operations Manual is a collection of operational policies (known as Bank Policies)

that specify ADB’s internal review process for due diligence and supervision of

borrowers and clients. Section C2 sets out how ADB will ensure compliance with the

Policy on Gender and Development, whereas Section F1 outlines the procedural

requirements for ADB to ensure E&S sustainability of projects, in line with the SPS

and SRs.

3.4.3 AIIB Environmental and Social Safeguards

The AIIB is a multilateral development bank with a mission to improve social and

economic outcomes in Asia. The AIIB Environmental and Social Framework (ESF)

(2018) is a system that supports the AIIB and its clients in achieving environmentally

and socially sustainable development outcomes. There are three Environmental and

Social Standards (ESS), as summarized in Table 3-7, which are also relevant to the

Project.

Table 3-7: Overview of AIIB Environmental and Social Standards

AIIB ESS Description

ESS 1:

Environmental

and Social

Assessment and

Management

· Aims to ensure the E&S soundness and sustainability of Projects and to support the integration of E&S considerations into the Project decision-making process and implementation;

· Applies if the Project is likely to have adverse environmental risks and impacts or social risks and impacts (or both);

· Requires an E&S assessment to identify direct, indirect, cumulative and induced risks and impacts to physical, biological, socioeconomic and cultural resources in the Project’s area of influence;

· The assessment must apply a mitigation hierarchy by:

- anticipating and avoiding risks and impacts;

- where avoidance is not possible, minimizing or reducing risks and impacts to acceptable levels;

- once risks and impacts have been minimized or reduced, mitigating; and

- where residual risks or impacts remain, compensating for or offsetting them, where technically and financially feasible;

· Once the Project’s impacts are identified and the mitigation hierarchy applied, establish the measures to mitigate, monitor and manage the impacts and reflect them in an Environmental and Social Management Plan approved by the Bank, including the proposed:

- mitigation measures;

- E&S monitoring and reporting requirements;

- related institutional or organizational arrangements;

- provisions for disclosure and consultation;

- capacity development and training measures;

- implementation schedule;

- cost estimates; and


AIIB ESS Description

- performance indicators;

· Carry out meaningful consultation with Project-affected people and facilitate their informed participation in the consultations; and

· Establish a suitable grievance redress mechanism to receive and facilitate resolution of the concerns of people who believe they have been adversely affected by the Project’s E&S impacts and inform Project-affected people of its availability.

ESS 2:

Involuntary

Resettlement

· Aims to avoid Involuntary Resettlement wherever possible; where avoidance of Involuntary Resettlement is not feasible, to enhance, or at least restore, the livelihoods of all displaced persons in real terms relative to pre-Project levels; to improve the overall socioeconomic status of the displaced poor and other vulnerable groups; and to conceive and implement resettlement activities as sustainable development programs, providing sufficient resources to enable the persons displaced by the Project to share in Project benefits;

· Involuntary Resettlement covers physical displacement (relocation, loss of residential land or loss of shelter) and economic displacement (loss of land or access to land and natural resources; loss of assets or access to assets, income sources or means of livelihood) as a result of:

- involuntary acquisition of land; or

- involuntary restrictions on land use or on access to legally designated parks and protected areas. It covers such displacement whether such losses and involuntary restrictions are full or partial, permanent or temporary;

· Prepare a resettlement plan elaborating on displaced persons’ entitlements, income and livelihood restoration strategy, institutional arrangements, monitoring and reporting framework, budget and time-bound implementation schedule;

· Involve affected persons in consultation on the resettlement plan and disclose the draft resettlement documentation; and

· Establish a suitable grievance redress mechanism to receive and facilitate resolution of the concerns of persons displaced by the Project and inform them of its availability.

ESS 3:

Indigenous

People

· Aims to design and implement Projects in a way that fosters full respect for Indigenous Peoples’ identity, dignity, human rights, economies and cultures, as defined by the Indigenous Peoples themselves, so that they:

- receive culturally appropriate social and economic benefits;

- do not suffer adverse impacts as a result of Projects; and

- can participate actively in Projects that affect them;

· Applies if Indigenous Peoples are present in, or have a collective attachment to, the proposed area of the Project, and are likely to be affected by the Project;

· The term Indigenous Peoples is used in a generic sense to refer to a distinct, vulnerable, social and cultural group possessing the following characteristics in varying degrees:

- self- identification as members of a distinct indigenous cultural group and recognition of this identity by others;

- collective attachment to geographically distinct habitats or ancestral territories in the Project area and to the natural resources in these habitats and territories;

- customary cultural, economic, social or political institutions that are separate from those of the dominant society and culture; and

- a distinct language, often different from the official language of the country or region;

· Undertake a culturally appropriate and gender-sensitive social assessment or use similar methods to assess Project impacts, both positive and adverse, on Indigenous Peoples;

· Prepare an Indigenous Peoples plan that is based on the social impact assessment prepared with the assistance of suitably qualified and experienced experts and that draws on indigenous knowledge and participation by the affected Indigenous Peoples communities;

· Carry out a process of meaningful consultation on the Project with affected Indigenous Peoples communities and concerned Indigenous Peoples organizations, in a culturally appropriate, accessible and inclusive manner, and facilitate their informed participation:

- in designing, implementing and monitoring measures to avoid adverse impacts or, when avoidance is not possible, to minimize, mitigate, offset or compensate for such impacts; and

- in tailoring Project benefits to affected Indigenous Peoples communities in a culturally appropriate manner.

Source: AIIB, 2016


3.4.4 Equator Principles

In addition to the above requirements, the EPs are an approach by financial

institutions to determine, assess and manage E&S risk in project financing. The EPs

emphasize that lenders will seek to ensure that the Project is developed in a manner

that is socially responsible and reflects sound environmental management practices.

The EPs have been adopted by a wide range of banks and lenders all over the world

in order to manage the social and environmental risks associated with their potential

investments.

There are ten EPs, as follows (EP, 2020)

· EP 1: Review and Categorization;

· EP 2: Environmental and Social Assessment;

· EP 3: Applicable Environmental and Social Standards;

· EP 4: ESMS and EP Action Plan;

· EP 5: Stakeholder Engagement;

· EP 6: Grievance Mechanism;

· EP 7: Independent Review;

· EP 8: Covenants;

· EP 9: Independent Monitoring and Reporting; and

· EP 10: Reporting and Transparency.

The EPs, among other things, require that the borrower conduct an ESIA of the

proposed project, develop an ESMS including plans and performance standards, and

carry out adequate consultation and public disclosure during project implementation.


4 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

4.1 Overview

This pre-liminary TAPI Environmental and Social Management Plan (ESMP) outlines

mitigation measures to address the significant environmental and socio-economic

issues associated with each phase of the Project, as identified through the ESIA

process.

Impacts and their associated mitigation measures are organized as follows:

· Environmental or social aspect – an element of Project's activities, products or

services that can interact with the environment – can be direct or indirect;

· Impact – the effect of a Project’s aspect on an environmental or social receptor;

· Mitigation – the proposed activity to reduce or minimize a project impact; and

· Relevant Plan/s – the link to the proposed mitigation and proposed mitigation

specification to topic-specific management plans to be developed by TAPI and

contractors to address key areas of potential environmental and social impacts

and risks associated with the Project.

ENVIRONMENTAL & SOCIAL IMPACT ASSESSMENT STUDY C-PAK-TAPI-ESMP-REP-0001-03 ESMP - PAKISTAN 28/09/2018


4.2 Environmental & Social Management Plan - Phase I

Table 4-1 – Phase 1 General Management Measures

Environmental or Social Aspect

Environment and Social Impact

Mitigation Measures Relevant

Management Plan/s

Implementation Timeline

The ESMP is not properly implemented.

Unmitigated environmental & social impacts

· TPCL will establish an Environmental and Social Management System (ESMS) to monitor all E&S activities and implementation of the Construction Environmental and Social Management Plan (CESMP).

· CESMP

and other more specific plans, as shown below.

· All Project Phases

· TPCL will install a dedicated Project Management Team in charge of supervising the Construction Environmental and Social Management System (CESMS) and implementation of the CESMP. This will include a management team at the head office, along with in-country and local staff.

Specific Management Plans:

Environment

• Air Quality Management Plan (AQMP)

• Water Management Plan (WMP)

• Waste Management Plan (WAMP)

• Noise and Vibration Management Plan (NVMP)

• Watercourse Crossing Management Plan (WCMP)

• HDD Environmental Management Plan (HDD EMP)

• Sediment & Erosion Control Management Plan (SECP)

• Hydrotest Environmental Management Plan (HEMP)






Management Plan/s


• Spill Prevention & Response Plan (SPRP)

• Hazardous Materials Management Plan (HMMP)

• Emergency Management & Response Management Plan (EMRP)

• Biodiversity Management Plan (BMP); and Biodiversity Action Plan (BAP)

• Climate Change Management Plan (CCMP)

• Flooding Management Plan (FMP)

Socio-Economic

• Human Resources / Workers Management Plan (HRWMP)

• Traffic Management Plan (TMP)

• Community Health and Safety Management Plan (CHSMP)

• Socio-Cultural Management Plan (SCMP)

• Gender Management Plan (GMP)

• Human Rights Management Plan (HRMP)

• Tribal People Management Plan (TPMP)

• Nomadic People Seasonal Migration Management Plan (NPSMMP)

• Cultural Heritage Management Plan (CHMP)

• Chance Finds Procedure (CFP)

• Influx Management Plan (IMP)

• Landscape Visual Impact Management Plan (LVIMP)

• Cumulative Impacts Management Plan (CIMP)

• Local Content Plan (LCP)






Management Plan/s


• Stakeholder Engagement Plan (SEP)

• Community Development Plan (CDP)

• Land Acquisition and Livelihood Restoration Plan (LALRP)

• Occupational Health and Safety Plan (OHSP)

• Construction Camp Management Plan (CCMP)

This list is not exhaustive and additional plans may be introduced as the Project progresses depending on the identification of new receptors.

Table 4-2 – Phase 1 Pre-Construction/Construction Phase Impacts and Mitigation Measures




Management Plan/s


Ambient Air Quality

Plant and equipment required to execute construction works;

RoW preparation works;

Pipeline construction and AGIs (PAK-OS01, PAK-OSO2, PAK-OS03 and PAK-MS01) (excluding Phase 2).

Increased levels of NO2 and SO2 emissions

· Maintenance and inspection of diesel generators and machinery according to manufacturer’s instructions;

· Ensure all machinery is properly maintained in accordance to equipment maintenance requirements; and

· No plant should be left running unnecessarily – no idling vehicles.

· CESMP

· AQMP

· BAP

· BMP

· CCMP

· SEP

· TMP

· Contractual arrangements of obligations before construction.

· Implementation throughout construction

· Reinstatement phase

Increased levels of PM10

and PM2.5 emissions associated with the generation of dust

· Pre-notification of critical dust producing activities and implementation of Community Liaison procedures;

· Weather conditions should be monitored and dust generating activities limited in extreme wind conditions;






Management Plan/s


· Dust generation will be monitored and controlled on an as-needed basis through water spraying techniques and suppression methods. Dust suppression will be undertaken near populated areas and where required, on unpaved construction roads;

· Dust suppression using watering can be achieved using camps’ grey water. Alternatives include wood chips and calcium chloride, or other environmentally safe products developed for this specific use. Dust suppression material should not scar the area and prevent vegetation growth (salt for example is not acceptable);

· Wind fences should be considered where appropriate;

· Road stabilization by use of soil-crete (soil mixed with cement or soil mixed with lime);

· Surface improvement, by measures such as paving or adding gravel/slag to dirt roads;

· Minimize drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays (reusing water such as grey water from camps where possible, subject to meeting WHO grey water guidance WHO-EM/CEH/125/E2006) on such equipment wherever appropriate;

· Ensure slopes on stockpiles are no steeper than the natural angle of repose of the material and maintain a smooth profile;

· Stockpiles should be located away from sensitive receptors;

· Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent






Management Plan/s


escape of material and overfilling during delivery; and

· Dust suppression techniques should be implemented, such as applying water (for example, grey water from camps, subject to meeting WHO grey water guidance WHO-EM/CEH/125/E2006) or non-toxic chemicals to minimize dust from vehicle movements.

For AGIs and temporary facilities, the following additional mitigation measures may be applied on an as-needed basis:

· Seeding of topsoil stockpiles with local grasses, if left in stockpiles for months, can also reduce dust when vegetation is established; and

· Imported construction material stockpiles should be located away from sensitive receptors

Noise and Vibration

Plant and equipment required to execute construction works.

ROW Preparation Works (along the pipeline route)

Pipeline construction

AGI construction (Offtake Station, OS and/or Metering Station, MS)

Increased road traffic movements

Increased noise levels · The EPC Contractor to implement targeted mitigation as needed along the ROW (such as consultation with locals, noise monitoring, siting of equipment, barriers, etc.) once the corridor has been defined;

· It is recommended that the contractors undertaking construction activities follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at the minimum level practicable. These measures include:

· The noisiest machines to be located on the far side of the pipeline to the works. Thus, when the works are at the closest distance to a sensitive receptor, there will be less noise sources contributing to the noise level at a single location.

· CESMP

· NVMP

· TMP

· SEP

· CHSMP

· SCMP



Noise disturbance during construction

Transboundary noise impacts






Management Plan/s


· Selecting equipment with low noise emission levels, wherever possible;

· Ensure machinery is properly maintained in accordance with equipment maintenance requirements captured in the contractor’s management system;

· Use machinery and equipment in accordance with the manufacturers’ instructions;

· No plant should be left running unnecessarily; and

· Noise impacts from generators will be minimized by regular maintenance and, if practicable and safe, taking into account the local temperature, keep generators within acoustic enclosures.

· Some activities can be controlled to some extent by the provision of temporary noise barriers or enclosures, but this may not be practicable in all instances.

· It is also recommended that clear and early communication with local residents be provided to make them aware of the activities to be undertaken and to give provide advice based on the health and safety risks involved.

· In addition, construction works should avoid certain sensitive time periods such as night-time hours, Fridays, and holiday periods.

· In the event the contractor must undertake works at night, this will need to be approved by the relevant authority in the area in advance.

· In the instance that the duration of the construction works at a single location is 10 days or more of working in any 15 consecutive






Management Plan/s


day period or more than 40 days in any 6 consecutive months, it is recommended that temporary rehousing be considered (BSI, 2014a). The application of British Standards for the provisioning of temporary housing in rural Pakistan socially and culturally has potentially significant negative impacts. TPCL is focused on being culturally sensitive and will approach grievances and mitigation measures on a case-by-case basis.

· Community grievances in relation to noise will be address on a case-by-case basis with potential mitigation measures discussed with the affected party, including the provision of temporary housing for ongoing grievances.

· Any individual receptors in close proximity of access roads connecting the AGIs with the local road network need to be identified (preliminary routes are provided Although vibration construction works are not expected to result in significant impact, any receptors located within 10 m may experience vibration levels (of 2.6 mm/s) which are likely to be noticeable and cause a complaint but can be tolerated if prior warning and explanation has been given to residents.

· The noise from vehicles and moving plant can be minimized by regular maintenance, selection of traffic routes, and timings of traffic movement.

· In relation to rock blasting activities, it is recommended that a specific assessment is undertaken prior to the works commencing to establish the potential impacts specially from vibration on nearby structures. Engagement






Management Plan/s


with local residents to inform them prior to such activities taking place is the most suitable mitigation measure. The contractor in charge of rock blasting must also minimize, as far as practicable, noise and vibration from this activity by minimizing the number of events and the period of the activity.

Physical Environment

Earth works, site preparation activities;

Access Roads construction;

ROW clearance;

trenching

Impact on Soil Characteristics, Subsurface Structures, Stability, and Productivity due to Construction Activities

In addition to those outlined in detail in the ESIA Section 7.4 Physical Environment Impact Assessment, mitigation measures are defined below:

· Mitigation measures outlined in the ESIA Section 7.5.2.8 should be implemented for the river crossings to minimize impact and enable restoration and compensation for permanent impacts;

· At major river crossings, pre-construction levels of turbidity should be established so that the Project can compare to them during and after the river crossing;

· Use of measures to limit sediment dispersion, such as curtains, should be considered during extended trenching activity and / or where there are sensitive receptors;

· While crossing waterways and adjacent riparian habitat, methods should be utilized that will minimize the impact footprint, as well as sediment suspension and related downgradient transport;

· CESMP

· BAP

· BMP

· EMRP

· FMP

· HMMP

· HDD EMP

· SECP

· SPRP

· WMP

· WCMP



Impact on Drainage Characteristics and Natural Water Flow / Impact on Surface Water Resource Quality due to Trenching Outside Watercourse Areas

Impact on Drainage Characteristics and Natural Water Flow / Impact on Surface Water Resource Quality at Watercourse Crossings






Management Plan/s


Impact on Surface Water Resources Quality due to Frac-out during HDD

· When possible, trench during the low-flow season and complete the construction (including burial) as quickly as possible;

· Where possible, avoid machinery contacting surface waters;

· Check waterways for barriers created construction activities and remove any materials to ensure waterway flow allows free movement of aquatic fauna through the area of the crossing;

· Inspect all machinery for leaks prior to mobilization to the watercourse crossing;

· Intercept and treat run-off from the construction working area, for example, by using sandbags;

· Ensure fuelling is done at a distance greater than 50 m from watercourses;

· The natural surface substrate within the watercourse should be separated and replaced as closely as practical to the original stratification when the open-cut method is used;

· Planting / seeding of native vegetation should occur in riparian zone as soon as possible after habitat impact to minimize erosion; and

· Consider the sensitive points in the life cycle of ecological receptors (such as migratory aquatic birds and spawning fish) in defining construction schedule. To the extent practicable, avoid construction during these periods. Additional details will be provided in the BMP.

· Implement the ambient air quality mitigation measures described in Section 7.2. Ambient Air Quality Impact Assessment;

· Minimize additional light at night; and

Impact on Flood Risk

Impact on Soil, Groundwater, and Surface Water due to Accidental Spills / Leakages

Impact on Water Resource Use and Quality due to Dewatering

Impact on Water Availability due to Consumption of Freshwater Resources






Management Plan/s


· Implement the noise and vibration mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment.

· The mitigation measures listed throughout Section 7.5.2 of the ESIA should be undertaken. Based on the information gathered to date, a Project Net Positive Biodiversity Benefit in relation to the habitat for Desert Wolf, Hog Deer, and Indus River Dolphin will be required. For the Indian Narrow-Headed Softshell Turtle and Balochistan Forest Dormouse, options are to conduct additional surveys or, likely simpler and more cost-effective, to assume presence and ensure a Project Net Positive Biodiversity Benefit as part of the mitigation process.

· The BMP should include potentially relevant habitat and consider the habitat preferences of the species in biodiversity offsetting design.

Ecology and Biodiversity

Clearing land for temporary and permanent project infrastructure and crossing perennial and intermittent waterways.

Direct Loss of Habitat and Degradation

· Avoid construction of temporary access tracks in critical habitats and potential critical habitats as reasonably practicable;

· Minimize habitat impacts beyond infrastructure footprints;

· To the extent practicable, minimize impacts to native habitat when constructing temporary or permanent roadways;

· Restore soils and plant native vegetation (or comparable crops where applicable) in areas subject to temporary impact comprising 1,346 ha of natural habitat and 1,260 ha of modified habitat;

· Clean equipment of soil and vegetation prior to transport to new areas;

· CESMP

· BAP

· BMP

· CDP

· HMMP

· HRWMP

· LALRP

· LCP

· SECP

· TMP

· WCMP

· WAMP

· During construction







Management Plan/s


· Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP). The BMP will include an assignment of relative biodiversity quality to the remote sensing and a refinement of the characterization of the balance between natural and modified habitats for the purpose of defining biodiversity restoration and offset needs. If additional field data cannot be collected, an assumption regarding the average level of degradation will need to be adopted to account for the uncertainty associated with the natural category.

· Prior to commencement of the construction activities, qualified ecologists are to further document areas within the construction corridor defined in Section 6.5. Ecology and Biodiversity Baseline as natural habitat. The purpose is to support the development of restoration, compensation, and offsetting approaches and ground truth the classification done using remote sensing and transects, confirming: 1) if the areas are natural habitat or should be revised to modified habitat where evidence can be provided of extensive degradation; and 2) confirming if areas classified as potential critical habitat are critical habitat or natural habitat or remain potential critical habitat with supporting evidence. The pre-construction survey should include the following:

- identification of plant species, ecosystem, and / or IBA, and assess according to the presence of biodiversity features and / or ecosystem processes that are representative of the ecoregion and / or IBA and measure as:

- highly representative (3 points);

· WMP






Management Plan/s


- moderately representative (2 points);

- poorly representative / not representative (1 point); Biological Q-rating for each survey location is assigned based on the sum of the evaluation points across these three criteria, as high [9 points], medium-high [8 points], medium [3-7 points], low-medium [2 points], or low [1 point])

- delimitation of high biodiversity areas;

- characterize and map the juniper trees that would be cut and evaluate opportunities to alter alignment or apply reduced width ROW to avoid, in particular, mature trees. If cutting is approved by the involved government agencies, negotiate compensation for the impacts with the prescribed authorities;

- identification of the presence of other protected species;

- identification of the most viable and cost-effective post-construction restoration approach;

- identification of viable areas within the PAI where opportunities to create greater long-term ecological value than currently exists for consideration in TPCL’s offset program;

- proposed revisions to classification of habitat type;

· Offsets for permanent impacts to natural habitat estimated as 444 ha. Compensation for permanent impacts of 450 ha modified habitat will be addressed through the Land Acquisition Plan and Livelihood Restoration Plan;

· For the loss of natural habitat (this includes potential critical habitat and modified habitat with






Management Plan/s


significant biodiversity values), mitigation must be provided that is equivalent in value. For critical habitats, mitigation must be provided that is greater in value. Tree planting requirements under the Pak-EPA’s environmental approvals must incorporate GIIP for offsetting (IFC, 2015). Two types of offset are acceptable, namely, averted loss and restoration;

· Offset design shall apply the following design principles:

- stakeholder participation fortifies offset design;

- out-of-kind (trading up) vs like-for-like offsets, where such opportunities are identified are to be developed in consultation with stakeholders and only out-of-kind offsets where stakeholders view the offset has greater value should be progressed;

- offsets should support landscape-level conservation;

- offsets must provide additionality;

- achieving net gain requires adequate scale;

- offsets shall endure at a minimum as long as the Project impacts;

· For the design of in-place habitat restoration and biodiversity offsets, consider the habitat preferences of the species for which critical habitat and potential critical habitat have been identified by province (Table 7.5-9), and any additional CR, EN, or endemic species identified during the ongoing construction surveys;

· Select viable opportunities to create greater long-term ecological value than currently exists to help offset permanent losses. For example, converting temporarily impacted, poor quality habitat within






Management Plan/s


the ROW to a higher quality level or converting developed or agricultural area into native habitat could create greater value;

· Ensure TPCL’s objective of achieving a Project Net Positive Biodiversity Benefit is achieved through the mitigation measure listed above, increasing biodiversity along the restored section of the ROW and targeted offsetting in areas of critical habitat. The timeframe for when the Project will achieve Net Positive Biodiversity Benefit is constrained by the length of time offset planted areas take to establish. This target date is before the end of the Project’s operation phase; and

· Project Net Positive Biodiversity Benefit will be included as potential objective as a topic to be investigated in the Community Development Plan (CDP), Local Content Plan (LCP) and Human Resources and Workers Management Plan (HRWMP). This would likely include increasing biodiversity along the restored section of the ROW and targeted offsetting in areas of critical habitat.

Clearing of land and construction in and near waterways

Direct Loss of Fauna Species

· Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP), which will be made up of the flora and fauna management and monitoring as per Chapter 10. Preliminary Environmental and Social Management Framework (ESMF);

· Include measures in the training and code of conduct of the construction and security teams to ensure that hunting of game does not take place. This must be monitored regularly by construction site managers with strict regulation of any observed hunting activities;

· CESMP

· BAP

· CDP

· BMP

· HMMP

· HRWMP

· LALRP

· LCP

· SECP

· TMP








Management Plan/s


· Pre-construction surveys of vegetation prior to clearing. Particular care for reptiles and amphibians should be taken during April / May during peak breeding when movements are high;

· Conduct daily surveys for organisms in and around open trenches and release them. Record the types and counts of dead organisms;

· To the extent possible, minimize the time trenches are open in areas where the bottom could flood quickly due to rainfall;

· In areas where the density of animals may be high, construct trench plugs every several hundred meters (that is, ramped earth which enables entrapped animals to escape);

· Before blasting, survey for important natural resources that may be impacted. Scare off or move animals in the immediate vicinity. Use blast mats to minimize impacts to vegetation and important environmental features. Do not use ammonium nitrate-based explosives in or near water due to the production of toxic by-products; and

· Adhere to the Traffic Management Plan and Water Management Plan that will be developed for the Project.

· WCMP

· WMP

Use of Horizontal Directional Drilling (HDD)

Impact to Rivers from River Crossings

Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP), which will be made up of the flora and fauna management and monitoring as per Chapter 10. Preliminary Environmental and Social Management Framework (ESMF);

· CESMP

· BAP

· BMP

· HDD EMP

· HMMP

· WMP

· WAMP

· During Construction






Management Plan/s


It should be noted that the use of HDD is a river crossing mitigation measure in its own right, as it is an alternative to open-cut, which would have a higher impact if used on the Indus River. Many of the mitigation measures for open-cut river crossings, as discussed in Section 7.5.2.11, also apply to HDD;

In addition to those outlined in detail in Section 7.4 Physical Environment Impact Assessment, the following mitigation measures should be included in an HDD EMP prior to construction:

· Mitigation measures specific to the Indus River dolphin include the use of pingers during drilling activities to encourage dolphins to avoid the area. Concurrently Marine Mammal Observation (MMO) during the works, restricting the speed and movement of any project-associated watercraft. These measures should be included in the HDD EMP, together with timeframes for HDD and reporting / communication protocols between MMO and HDD crew;

· During HDD, storage of cuttings and bentonite fluids is required to have secondary containment;

· HDD cuttings and waste drilling fluids should be tested prior to disposal and the final disposal method should be approved by regulatory agencies as specified in the Waste Management Plan;

· Contingency measures should be in place prior to drilling for a frac-out event during HDD activities. This should include monitoring of equipment and the water crossing, provision of silt curtain materials and fasteners at the HDD site, and machinery to remove bulk bentonite in the event of a major frac-out;






Management Plan/s


· Work areas for drilling and pipe pull should avoid the riparian zone if possible, taking into account the constraints of working at the upper limits of the technology. In the event that the riparian zone cannot be avoided, planting / seeding of native vegetation should occur in riparian zone as soon as possible after habitat impact to minimize erosion;

· Consider the sensitive points in the life cycle of ecological receptors (such as migratory aquatic birds and spawning fish) in defining construction schedule. To the extent practicable, avoid construction during these periods. Definable sensitive life cycle points will be detailed within the BMP;

· The HDD EMP should be read and implemented in conjunction with the WCMP; and

· TPCL will provide a copy of the draft HDD EMP to WWF India and Punjab EPA for review comment. TPCL will provide regular progress updates and MMO summaries of HDD activities to WWF India and Punjab EPA.

Use of Open-cut and Pipe Bridge Methods

Impact to Rivers from River Crossings

Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP), which will be made up of the flora and fauna management and monitoring as per Chapter 10. Preliminary Environmental and Social Management Framework (ESMF);


· CESMP

· BAP

· BMP

· HMMP

· SECP

· SPRP

· WCMP

· WMP







Management Plan/s

















Management Plan/s




· Consider the sensitive points in the life cycle of ecological receptors (such as migratory aquatic birds and spawning fish) in defining construction schedule. To the extent practicable, avoid construction during these periods. Additional details will be provided in the BMP and BAP.

Dust, light, and noise associated with construction

Indirect Impacts to Flora and Fauna





· CESMP

· BAP

· BMP

· AQMP

· NVMP


Construction activities Impact to Critical Habitat · Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP), which will be made up of the flora and fauna management and monitoring as per Chapter

· CESMP

· BAP

· BMP

· AQMP







Management Plan/s


10. Preliminary Environmental and Social Management Framework (ESMF);


· The BMP and BAP should include potentially relevant habitat and consider the habitat preferences of the species in biodiversity offsetting design.

· NVMP

Socio-Economic

Land Acquisition and Physical Displacement/Resettlement

Physical Displacement. Resettlement of Households

· The Project will actively consider adjustments of the pipeline within the 500 m corridor to avoid physical displacement and to reduce economic displacement as far as possible.

· A Land Acquisition and Resettlement Policy Framework (LARF) has been developed for the Project, which sets out the national and international standards and laws to be followed during the land acquisition process. A Preliminary Land Acquisition and Resettlement Plan (LARP), which has also been prepared, will be replaced by a Land Acquisition Plan (LAP) and Livelihood Restoration Plan (LRP) prior to Project construction. The aim of these documents is to

· CESMP

· LARP / LALRP

· CDP

· GMP

· HRMP

· NPSMMP

· TPMP

· LCP

· SEP

Prior and throughout construction






Management Plan/s


ensure that national legal requirements and international standards for land acquisition and resettlement are met. As part of this process, the GOP and TPCL will be required to organize resettlement for all occupants or users of affected land and residences (if applicable), irrespective of their tenure or legal status. The aim of this process is to ensure that affected parties are able to restore, and ideally improve their living conditions and livelihoods.

· Mitigation measures for physical displacement will be developed in consultation with affected parties, providing alternative housing and / or cash compensation and livelihood restoration measures where appropriate. Special consideration will be taken for those viewed as being severely affected and/or vulnerable prior to the commencement of any Project construction.

Under the Preliminary LARP, the following provisions are made in terms of promoting restoration of land and livelihoods:

· A comparison between LAA 1894 and IFC PS 5 will be prepared to inform discussions with Pakistan authorities responsible for land acquisition and compensation;

· TPCL will work closely with the Pakistan authorities responsible for land acquisition and compensation to ensure the process meets both national regulatory requirements and GIIP, such as stakeholder engagement, fair compensation, replacement land where possible, and support to vulnerable people;

· Affected Persons who will by physically displaced (i.e., will lose their place of residence, if applicable)






Management Plan/s


will be offered a package of compensation measures that will include in-kind replacement (the provision of a replacement property and replacement structures) or cash compensation based on replacement value. TPCL, the competent authorities, and Affected Persons will negotiate on the package of options consistent with the land acquisition procedures established in the country;

· TPCL will promote fair and informed consultation and participation of key stakeholders and Affected Persons during the resettlement planning and implementation phases. This will include direct engagement with Affected Persons in terms of the package of compensation options, the determination of their preferences and suitable training if cash compensation is chosen. All forms of engagement and negotiations will be recorded consistent with national regulatory requirements and to GIIP;

· Affected Persons that are deemed eligible for resettlement assistance and compensation are not limited to landowners or structure-owners but also include persons with customary rights to land and assets or persons with no recognizable legal right or claim to land and assets under national law. This will include persons who derive benefits from the land under a fixed-term or annualize tenancy agreement, or persons who have a long-term occupation or use of land with expanded rights under the principle of adverse possession (or when a person, who does not have legal title to a property, may make a legal claim based on a history of possession or occupation);

· TPCL acknowledges the responsibility not just to pay compensation for losses, but also to assist






Management Plan/s


potentially affected households (and vulnerable households in particular) to restore their livelihoods and improve their standard of living. The LRP will be developed to meet these responsibilities, in compliance with both international good practice and guidelines. Livelihoods are multi-faceted, and a combination of approaches is therefore required to support restoration of income and the reestablishment of community support networks. Measures should include:

- meet both GIIP and the requirements of the GOP;

- livelihood and income restoration should be achieved by providing suitable compensation packages that prioritize replacement assets over pure cash compensation, as defined in the Preliminary LARP;

- as most livelihoods are land and agriculture based, the provision of replacement land is deemed a priority with respect to livelihoods restoration. Where possible, the GOP will allocate unclaimed or unutilized state or village land and transfer the land to private title under the Affected Person’s name. Where such cannot be secured, TPCL and the GOP will explore the acquisition of private land on the open market and transfer the acquired land to the Affected Persons. Where this second option fails, and replacement land cannot be guaranteed, cash compensation for the land will be provided at replacement value to allow Affected Persons to secure their own alterative land, or for individual livelihood investment;

- consider livelihood restoration strategies within the framework of existing livelihoods practices,






Management Plan/s


skills and providing access to assets and resources and the vulnerability of Affected Persons in the PAI;

- offer a package of livelihood restoration opportunities from which affected households can choose including options that suit or enhance their interests and capacity and that will allow them to restore their livelihoods to at least pre-Project levels;

- complete appropriate disclosure of information, consultation, and the informed participation of those affected;

- support households to restore their livelihoods to at least pre-Project levels;

- provide capacity building as part of livelihood restoration activities to develop household skills, including financial management. Capacity building acknowledges the different needs of women, men, youth, and vulnerable groups with respect to skills development;

- provide mechanisms for those receiving cash compensation to optimize opportunities such as financial management training;

- engender self-reliance and foster socio-economic empowerment in the affected community;

- TPCL in collaboration with the GOP may, at their discretion, promote a range of alternative livelihood development programs, where replacement land and other assets cannot be secured. The range of programs will be defined in a separate LRP to be developed alongside the finalization of the Preliminary LARP. The development of alternative livelihoods is prone






Management Plan/s


to failure and requires significant investment therefore it should not be treated as a preferred option, but rather should be defined as developmental programs in addition to the provision of replacement assets and compensation;

- active participation of intended beneficiaries in planning and decision making is required to ensure proposed support reflects local realities / priorities and have active buy-in;

- Affected Persons should be provided with choices so that they can self-determine how their household will best benefit from the livelihood restoration options;

- vulnerable households are less able to adapt to changes and therefore require targeted support through the planning and implementation of livelihood restoration; and

- financial management training or advisory support including basic numeracy, money management and budgeting, and basic literacy.

A set of principles is recommended to guide the land acquisition and compensation effort, including:

· A transparent compensation procedure with multiple information and consultation steps so that all village residents can see that no other resident is gaining an advantage;

· Sensitivity to cultural practices and local legal requirements;

· Recording all compensation transactions; and

· Avoiding resettlement of households through Project redesign where possible.






Management Plan/s


Construction Activities Economic Displacement and Impacts to Livelihoods

· International best practice stipulates that livelihoods should be considered to encompass the full range of means that individuals, families, and communities utilize to make a living, such as wage-based income, agriculture, fishing, foraging, other natural resource-based livelihoods, trade, and bartering. A livelihood is sustainable when it enables people to cope with and recover from shocks and stresses (such as natural disasters and economic or social upheavals) and enhance their well-being and that of future generations without undermining the natural environment or resource base. Since the Project cannot avoid economic displacement impacts, an LRP will be developed in close liaison with authorities and Affected Persons including the following:

- A comparison between the LAA 1894 and IFC PS5 will be prepared to inform discussions with Pakistan authorities responsible for land acquisition and compensation;

- TPCL will work closely with the Pakistan authorities responsible for land acquisition and compensation to ensure the process meets both national regulatory requirements and GIIP, such as stakeholder engagement, fair compensation, replacement land where possible, and support to vulnerable people;

- Affected Persons eligible for livelihood restoration assistance and compensation are not limited to landowners or structure-owners but also include persons with customary rights to land and assets or persons with no recognizable legal right or claim to land and

· CESMP

· CDP

· GMP

· HRMP

· LALRP

· LCP

· NPSMMP

· SEP

· TPMP

Prior to and throughout construction






Management Plan/s


assets under national law. This will include persons who derive benefits from the land under a fixed-term or annualize tenancy agreement, or persons who have a long-term occupation or use of land with expanded rights under the principle of adverse possession (or when a person, who does not have legal title to a property, may make a legal claim based on a history of possession or occupation);

- TPCL acknowledges the responsibility not just to pay compensation for losses, but also to assist potentially affected households (and vulnerable households in particular) to restore their livelihoods and improve their standard of living. The LRP will be developed in compliance with international best practice and guidelines including:








Management Plan/s


- consider livelihood restoration strategies within the framework of existing livelihoods practices, skills and providing access to assets and resources and the vulnerability of Affected Persons in the PAI;





- provide mechanisms for those receiving cash compensation to optimize opportunities such as financial management training; and

- engender self-reliance and foster socio-economic empowerment in the affected community.

Where damages are sustained to crops or economic trees, fair compensation will be determined by a number of differing methods as established in the LAA 1894 including:

· Crops: The prices of crops including additional inputs costs (such as the price of seeds sowed,






Management Plan/s


chemical fertilizers, and costs of farming) will be determined. The price of crops will be determined based on local market value in neighbouring areas for the three months prior to the valuation;

· Non-Productive Trees: The value of non-productive trees will be determined on the basis of the price of firewood, according to the local tradition. The Law does not establish how firewood is equated to the number or size of non-productive trees;

· Non-Productive Ornamental Trees: The value of non-productive ornamental trees will be determined on the basis of five times that of the price of firewood, according to the local tradition. The LAA 1894 does not establish how firewood is equated to the number or size of non-productive ornamental trees; and

· Productive Trees: The value of productive trees will be determined on the basis of the price of firewood as well as the price of products of the trees over the period of 5 years. Where fruit produce is directly lost, the price of the fruits will also be included in the compensation.

As a means of comparison and to allow for alignment with GIIP requirements, the value of crops and trees will be determined using the Income Method where the crops and economic trees are valued based on the estimated income/profits generated from the produce over a pre-determined transition period. The Income Method also factors in costs for the re-establishment of annual crops, perennial crops and trees, including costs of seedlings/saplings, input costs, and the loss of productivity over the period which perennial crops and trees need to become productive.






Management Plan/s


The LALRP will identify households that will no longer be able to continue with their existing livelihood activities. These households will be provided with access to a livelihood restoration process. The aim of this is to help affected households access alternative livelihoods and replace those lost by the Project. This will include training on improved agricultural techniques such post-harvest handling or accessing low-cost inputs, diversification of employment, assistance in accessing savings and credit opportunities, and providing local business and enterprise training. Particular attention will be paid to vulnerable groups and individuals who may require additional support, in particular during the transitional period between loss of existing livelihoods and reestablishment of improved/alternative livelihoods.

A Project SEP has been developed as a living document that shall be updated as the Project evolves, in accordance with key milestones, to ensure full stakeholder participation in Project decision-making, guided by GIIP including the following:

· Involve stakeholders to facilitate inclusive communication and capture a wide range of issues and concerns;

· Ensure that stakeholders, particularly those directly affected by the proposed development, have information at their disposal with which to make informed comments and enable them to plan for the future to reduce levels of uncertainty and anxiety. Information should allow affected parties to develop an understanding of potential impacts, risks and benefits and an open and transparent approach is central to achieving this aim; and

· Implement a Grievance Mechanism to monitor and manage stakeholder grievances. The Grievance






Management Plan/s


Mechanism is to be closely monitored for any potential issues related to conflicts or creating any new clashes between ethnic groups, workers and/or villages. Urgent action will be likely be required in the event of complaints being made in relation to conflict between groups.

Regular review and continued implementation of the Project SEP will be undertaken, ensuring that consultation with affected communities continues and that the needs of vulnerable community members are considered.

Economic displacement Impact to Persons Reliant on Ecosystem Services, Specifically Land-based Resources

At this stage it is not clearly understood how many affected parties will be impacted by changes to access to ecosystem services. As part of the ongoing land acquisition process and during the finalization of the LAP and LRP, it is the responsibility of TPCL to conduct the following:

· Identify areas along the pipeline route that are used communally for natural resource collection;

· Determine the land tenure status of this land, how the land is used and by whom;

· Identify whether the ecosystem services accessed in the PAI are unique or ubiquitous; and

· Determine if there is an impact that requires mitigation measures.

All mitigation measures must be developed in consultation with relevant stakeholders, including affected communities and relevant government officials.

· CESMP

· BAP

· BMP

· CDP

· LALRP

· NPSMMP

· SEP

· TPMP







Management Plan/s


Water Use Impact on Persons Reliant on Ecosystem Services, Specifically Water Supplies for Local Communities

· The CESMP shall include a Water Management Plan (as per guidelines provided in the Water Management Framework in Appendix F). Mitigation measures for groundwater, surface water, and irrigation channels are to be included in the Water Management Plan.

· Pre-construction planning must identify water sources for human consumption and Project use, along with conducting an evaluation of the impacts of groundwater draws by the Project to private and community wells and boreholes. If analyses indicate that reduction in water levels will occur, TPCL must purchase water and transport to the site for use. Measures must be taken to prevent damage to irrigation systems which could result in orphaned farmland. Irrigation systems are to be reinstated or diverted as necessary to prevent degradation of farmland.

· TPCL will ensure that any abstractions of water including groundwater for Project use, will not impact this resource availability to nearby communities. All abstractions must be permitted by the appropriate agencies.

· Measures to protect river water quality to minimize the release of sediment related to construction methods used for river crossings or other wastes either directly or diverted into water bodies should be implemented. In Punjab, in particular, canals and rivers are a key irrigation source for surrounding agriculture. Minimizing sediment content and transport is essential to maintaining agricultural output.

Should river water be abstracted, the following mitigation measures should be followed:

· CESMP

· BAP

· BMP

· CDP

· LALRP

· NPSMMP

· SEP

· TPMP

· WMP







Management Plan/s


· Screens should be used at water abstraction points in order to prevent the removal of juvenile fish and other organisms from the water body;

· Monitoring of water levels and flow of the abstraction points should be conducted as appropriate to ensure that abstraction is not causing a net decline in the amount of water;

· No more than 10% of the river flow should be abstracted at any point in time, so that downstream flows are maintained for natural systems; and

· A Grievance Mechanism shall be implemented to monitor and manage stakeholder grievances related to water availability and quality.

· In the event HDD is applied to river crossings, risks will be mitigated by the measures described in the HDD EMP.

· Stakeholder engagement will keep communities informed of the construction schedule.

Disruption to migratory pathways

Impact to Permanent (Non-nomadic) Populations due to Construction Noise

· Proactive outreach with potentially affected settlements is essential to reducing the disruption to local settlements.

· It is recommended that clear and early communication with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken.

· Monitoring of the Grievance Mechanism must be conducted during construction to identify any complaints made in relation to noise impacts.

· CESMP

· NVMP

· SEP







Management Plan/s


Services and Infrastructure Impact Associated with Increased Demand for Services and Infrastructure

Prior to construction, the CESMP shall be developed to include the following specific management plans: Community H&S Plan, Community Development Plan, and Influx Management Plan.

· The Community H&S Plan

- establish preventive and control measures consistent with GIIP, such as in the World Bank/IFC EHS Guidelines or other internationally recognized source;

- anticipate and avoid adverse impacts on the H&S of the affected community during the Project life from both routine and non-routine circumstances;

- promote the safeguarding of personnel and property carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the affected communities;

- design, construct, operate, and decommission the structural elements or components of the Project in accordance with GIIP, taking into consideration safety risks to third parties or affected communities;

- avoid or minimize the potential for community exposure to hazardous materials and substances that may be released by the Project;

- identify those risks and potential impacts on priority ecosystem services that may be exacerbated by climate change - adverse impacts should be avoided;

- avoid or minimizes the potential for community exposure to water-borne, water-based, water-related, and vector-borne diseases, and

· CESMP

· CHSP

· CDP

· IMP

· SEP







Management Plan/s


communicable diseases that could result from Project activities, taking into consideration differentiated exposure to and higher sensitivity of vulnerable groups;

- avoid or minimizes transmission of communicable diseases that may be associated with the influx of temporary or permanent Project labour; and

- in addition to the emergency preparedness and response requirements (as per IFC PS1) assist and collaborate with the affected communities, local government agencies, and other relevant parties, in their preparations to respond effectively to emergency situations, especially when their participation and collaboration are necessary to respond to such emergency situations.

Influx of workers, Accidents, Disease, Construction

Impacts Related to Community Health and Safety

· Community Development Plan

- TPCL shall consider developing a Community Development Framework (and subsequently a Community Development Plan) that shall include needs assessments and priority ranking to identify needs of local communities. The plan shall include local institutional capacity building to ensure that communities manage and maintain their projects, striving towards sustainability;

- as part of a community development program and to provide for local institutional capacity building, TPCL should consider providing emergency medicine training to local medical staff who work at facilities along the PAI and

· CESMP

· CDP

· CHSMP

· EMRP

· HRWMP

· IMP

· SEP

· TMP

· TPMM







Management Plan/s


donations of equipment and supplies to these institutions; and

- the Grievance Mechanism shall be used to manage and monitor community complaints. Grievances shall be analysed to understand if complaints are made in relation to local access to services and infrastructure with any issues dealt with as a matter of urgency.

· Influx Management Plan

- prior to construction, ensure that the CESMP includes a specific Influx Management Plan to manage this process and minimize service and infrastructure demand impacts where possible;

- TPCL will ensure that the contractor provides for additional medical staff onsite trained in providing emergency services during peak construction periods to provide critical support in the field, avoiding overwhelming local healthcare resources;

- the Project will monitor non-Project related influx into the area to understand if this has the potential to impact upon local services and infrastructure. In the even that this occurs, the Project will work with local authorities to manage this process and minimize impacts where possible; and

- prior consultation must be undertaken with any potentially impacted communities to discuss upcoming works in order to reduce potential conflict.

Road Traffic Increase

Communicable Diseases

Impact Associated with Increased Risk of H&S

· Develop and implement a Community Health and Safety Plan

· CESMP

· CHSP







Management Plan/s


UXO Clearance

Vehicle Movements

Incidents and Communicable Diseases

· In addition to complying with the World Bank/IFC EHS Guidelines for Onshore Oil and Gas Development, which address occupational and community H&S, a complete H&S Program that includes emergency response plans will be developed and implemented by the EPC Contractor.

· This program will be cascaded down through the supply chain, requiring stringent adherence for all participating organizations.

· This program will include first aid and safety training for project leaders and workers, regular testing of emergency response plans in coordination with public service agencies (such as law enforcement, healthcare organizations, and others), and community stakeholders, construction camp regulations to be developed to minimize local nuisance (for example, limiting or preventing workers from socializing in the PAI), onsite healthcare at each construction camp and in the pipeline construction area, PPE, and limiting exposure/providing hydration when working in high temperature environments

· An Occupational H&S Plan (OHSP) will be developed prior to construction. The program will cascade down through the supply chain requiring adherence for all participating organizations.

· The program will include, but not be limited to the following list of H&S plans, standards and procedures which are to be developed as a function of Project H&S execution. As such these will be undertaken separately to core ESMS documents.

· NVMP

· OHSP

· SEP

· SCMP

· TMP

· WMP






Management Plan/s


· H&S Regulatory Permits will be managed under Projects Permits and Compliance System.

· An Occupational H&S Plan will be prepared by the Contractor, which will include the following items:

- Initial Safety Induction Course. All workers will be required to attend a safety induction course before they are allowed access to the work area;

- Periodic Safety Training Courses. Safety courses will be conducted not less than once every six months. All EPC Contractor (and subcontractor) employees will be required to participate in relevant training courses appropriate to the nature, scale and duration of the works. Training courses will be provided for all workers and at all levels of supervision and management. A list of training participants’ names and time-stamped photographic evidence of the training will be provided by the EPC Contractor to TPCL;

- Safety Meetings. Regular safety meetings will be conducted on a monthly basis. TPCL will be notified of all safety meetings in advance. TPCL may attend in person or by representative at their discretion. Minutes of all safety meetings will be taken and sent to TPCL within seven days of the meeting and will include a list of participants names and time-stamped photographic evidence of the training;

- Safety Inspections. The EPC Contractor will regularly inspect, test and maintain all safety equipment (including firefighting equipment), scaffolds, guardrails, working platforms, hoists, ladders and other means of access, lifting, lighting, signing and guarding equipment. Lights and signs will be kept clear of obstructions and






Management Plan/s


legible to read. Equipment, which is damaged, dirty, incorrectly positioned or not in working order, will be repaired or replaced immediately by the EPC Contractor;

- PPE. Workers will be provided (before they commence works) with appropriate PPE suitable for construction work such as safety boots, helmets, gloves, protective clothes, goggles, and ear protection at no cost to the workers. Life vests will be provided for all staff working around, or above water channels or rivers;

- Workers H&S Training Plan including communicable disease prevention;

- Workers Fit for Work Plan including communicable disease checks;

- Injury Management and Rehabilitation Plan; - Heat Stress Management Plan; - Mobile Equipment Use and Inspection Plan; - Site Vehicle Inspection; - Project HSE Standards and Procedures; - H&S Management System documents

including:

H&S Induction documents including H&S handbook;

Risk Assessments. Task specific – Method statements can have risk assessment appended to the document;

Permits to Work; Weekly and Monthly Safety Report

Template; Mandatory Incident Report Template; Project Emergency Contact List; Project Map; and Activity Planner.






Management Plan/s


· The EPC Contractor shall keep a log of both training records and safety incidents including near misses;

· All construction plant and equipment used on or around the work area will be fitted with appropriate safety devices. These will include, but not be limited to effective safety catches for crane hooks and other lifting devices, and functioning automatic warning devices and, where applicable, an up to-date test certificate, for cranes and hoists;

· Zones with noise levels above 80 dBA shall be marked with safety signs and appropriate PPE must be worn by workers;

· Portable toilet facilities for workers at work sites shall be provided;

· Barricading of all areas of excavation greater than 2 m deep along with warning signs;

· Ensure sufficient fresh air supply to confined workspaces;

· Keep air inlet filters clean and free of dust and microorganisms;

· Ensure reversing signals are installed on all construction vehicles;

· Implement fall prevention and protection measures whenever a worker is exposed to the hazard of falling more than two meters or falling into operating machinery or through an opening in a work surface. (Note: fall prevention / protection measures shall include installation of guardrails with mid-rails and toe boards at the edge of any fall hazard area, proper use of ladders and scaffolds by trained employees, use of fall prevention devices, including safety belt and lanyard travel






Management Plan/s


limiting devices to prevent access to fall hazard, fall protection devices such as full body harnesses);

· Mark the areas where risk of injuries from falling objects exist with rope or flagging to minimize risks and injuries;

· Provide spotters. Employ flag persons to control traffic when construction equipment is entering or leaving the work area;

· All Project subcontractors shall be supplied with copies of the H&S Plan. Provisions shall be incorporated into all subcontracts to ensure compliance with the H&S Plan at all tiers of subcontracting. All subcontractors will be required to appoint a safety representative who will be available on the site throughout the operational period of the respective subcontract unless TPCL approval to the contrary is given in writing. In the event of TPCL approval being given, the EPC Contractor shall ensure, as far as is practically possible, that employees of subcontractors of all tiers are conversant with appropriate parts of the H&S Plan. To implement the above items, the EPC Contractor shall designate qualified environmental, H&S personnel.

· Water supply. If groundwater or surface water is to be used as potable water, it shall be tested prior to use and weekly thereafter to ensure that the water quality meets drinking water standards.

· Socio-Cultural Management Plan

- A Workers’ Code of Conduct that include communication and behaviour protocol related to socio-cultural values and promote cultural awareness to reduce cultural clashes and misunderstandings in the workplace as well as






Management Plan/s


with neighbouring communities and community members. This is particularly important in today’s multicultural environment. It can help prevent cultural conflicts and allow workers to better deal with each other;

- Policies limiting interactions between foreign workers and the communities, particularly after hours;

- Contract bilingual staff to help ensure the participation of ethnic, linguistic, and cultural minorities in the workplace;

- Local socio-cultural knowledge and skills as job requirements for Project staff, in addition to Project induction and awareness creation;

- Time provision to have discussion on socio-cultural values and differences and how to manage it;

- Training in conflict prevention, resolution, and other negotiation mechanisms that can avoid socio-cultural clashes;

- Training of key Project officials in cultural sensitivity to better enable them to manage procurement, service delivery, communications, and conflict-resolution mechanisms; and

- Recruitment of Project team members that are able to speak the language of Affected Persons to ensure efficient and effective community consultation and participation.

· Communicable Diseases: To mitigate the potential for communicable disease transmission, the following key measures targeting workers and community members shall be taken:






Management Plan/s


- As part of the H&S Program, there shall be awareness creation and training modules HIV/AIDS and STD risks and a recreational activity plan to provide for activities outside of working hours. HIV/AIDS awareness and prevention programs shall also be undertaken in communities to reduce the transmission HIV/AIDS and other STD;

- Construction workers shall be instructed and required to comply with a Worker’s Code of Conduct which addresses issues such as anti-social behaviour, drug and alcohol consumption, HIV/AIDS, weapons, and respect for women;

- Construction workers shall be required to complete health screening to minimize the spread of communicable diseases. Health screening for all workers shall include active tuberculosis (TB). Where workers are handling food or water production and distribution the workers shall have received typhoid and Hepatitis A (full series) vaccinations, in addition to TB vaccination. At least the first inoculation in the Hepatitis A series must be given prior to the start of employment, with continuation and completion of the inoculation series. Once the complete Hepatitis A vaccination series is completed, it does not have to be repeated. Typhoid inoculation shall be completed within two years prior to the date of employment in the food and water service capacity. Typhoid vaccination shall also include periodic booster immunization as required. Proof that employees and contractor employees have received vaccinations shall be provided to






Management Plan/s


TPCL. The contractor shall maintain their employees’ vaccination records for examination and make these available for inspection as required;

- Vector borne diseases such as malaria should also be controlled by awareness creation and not allowing standing water in trenches or in camps; and

- Awareness creation on prevention practices to ensure safe drinking water, health and hygiene, sanitation, and solid waste management needs to be promoted

This could readily be extended to cover advice on pre-natal and post-natal care to benefit women in the local communities.

Delivery of materials, equipment and transportation of staff

Impact Associated with Increased Risk of Road Traffic Incidents and Injuries

· The EPC Contractor should develop and implement a Traffic Management Plan to address construction traffic and reduce the potential for accidents. This will include information related to vehicle maintenance, equipment transport by phase, schedule, signage and control, hours and volume of equipment and worker transport, lighting conditions, driver safe driving training requirements, material movement, areas of restricted carriageway width, haul routes, speed limits and separation distances, geotagging to track road speed, reversing alarms, limiting working hours, limiting driving after dark, accommodating the needs of local residents, record keeping, driver training, and inspections;

· Community Emergency Response Plans addressing traffic incidents and potential releases of chemicals and other hazardous materials will be

· CESMP

· CHSMP

· OHSP

· SEP

· TMP







Management Plan/s


developed, tested, and implemented throughout construction. Plan testing will involve workers, public sector agencies, and residents in the vicinity of Project-related traffic. Response plans will address traffic accidents, the potential releases of chemicals, and other hazardous materials and fires. The contractor shall involve external stakeholders (such as the police and local authorities) in any on or off-site security incidents and ensure that appropriate incident response procedures are implemented; and

· Major road and railway crossings will be undertaken using trenchless methods to minimize disruption and damage to major roads and railway lines.

Security Impact on Facilities, Workers, and Neighbouring Community Members due to Inter-ethnic and Sectarian Tension/Conflict

Measures implemented to mitigate this impact will help to avoid additional conflict, but will not alter the firmly established social systems. The following documents will be key to managing this issue:

· The Community Emergency Response Plan (CERP) as part of the CHSMP should be developed and tested to determine effectiveness of protocols related to each of the three potential conflict groups described above. The contractor shall involve external stakeholders (such as the police and local authorities) in any on or off-site security testing or actual incidents and ensure that appropriate incident response procedures are implemented;

· The Human Resources and Workers Management Plan (HRWMP) as well as the Local Content Plan (LCP) should clearly articulate and communicate how hiring will occur. Transparency in

· CESMP

· CHSMP

· GMP

· HRMP

· HRWMP

· LCP

· OHSP

· SCMP

· SEP







Management Plan/s


implementing hiring to engender equal opportunities is essential;

· The Worker’s Code of Conduct should mandate appropriate behaviour requirements for all staff within the Project area and external to it during the Project construction period;

· Grievance Mechanism implementation and monitoring is essential to understanding if the Project is exacerbating any existing conflicts or creating any new clashes between ethnic groups, workers and/or villages. Urgent action will be required in the event of complaints being made in relation to conflict between groups; and

· Unskilled labour should preferably be selected via a ballot system to ensure that the selection process is fair and equitable. It is also advisable that unskilled labour workers stay in one Lot and are not moved to other parts of the country as it may create tension with locals who are in need of employment.

Workforce and Services Impact Associated with Employment and Economic Development

Enhancement measures:

The positive impacts associated with employment and economic development should be monitored throughout construction to ensure that sourcing is occurring locally (as expected) and to identify/maximize opportunities for additional local development. There are several key measures that should be conducted simultaneously in support of this impact.

· Local Consultation

- Consultation with local residents along the pipeline route will be conducted post the ESIA

· CESMP

· CDP

· GMP

· HRMP

· HRWMP

· LALRP

· LCP

· SEP







Management Plan/s


process, prior to commencement of the construction hiring process.

- The Project plans to engage CLOs in all districts to assist in the direct communication and engagement of local residents. This will enable sharing of information on available positions and the Project’s policy on fair and equitable employment and recruitment practices.

- The CLOs will also allow for the sharing of grievances, should they occur, in relation to employment and recruitment. The aim of this is to ensure that all villages affected by the Project are able to share concerns, along with being provided with feedback on how the Project is approaching employment and equitable benefit sharing with those directly impacted.

· Outreach to Potential Employers: To ensure local participation, contractors and subcontractors shall be required to:

- Comply with requirements of the Project’s Human Resources and Workers Management Plan and LCP;

- Hire local staff as far as possible to support construction and as part of supply chain provisions and;

- Regularly report on the local hiring compliance.

- This requirement shall be included as part of the Project’s procurement commitment. Contractors shall also be required to identify the number of positions and skills necessary as well as the steps to be taken to ensure compliance with this provision. Contractors






Management Plan/s


shall designate a person to lead this local hiring initiative, with responsibilities including the collection of employment information and leading the outreach program. In addition to the Project’s Human Resources and Workers Management Plan and LCP, the contractor shall provide training and support to the workforce and ensure that vulnerable people benefit equitably with other people from the general population.

· Engagement with Potential Workers and Vendors

- The Project’s SEP, Human Resources and Workers Management Plan, and LCP shall be used to engage with and inform relevant stakeholders (such as local leaders) of employment opportunities.

- It shall also be done through awareness creation within Project affected communities including verbal announcements (such as through focus group and other meetings) and by providing culturally (language and literacy) appropriate materials.

- There should be a unique focus and emphasis on conducting outreach to high unemployment level groups (such as youth) and vulnerable people.

· Local Workforce and Development Monitoring and Evaluation: Prior to construction, an LCP shall be developed that shall address the following as a minimum:

- Responds to government regulations or investment agreements stipulating local content levels and percentages;






Management Plan/s


- Includes requirements of any agreement reached between the Project and the host country on local content (such as percentages related to skilled, semi-skilled and unskilled workers);

- Includes the requirements for engagement and the context in which the various tribes / communities need to be engaged in employment and procurement;

- Include the activities of:

workforce development (employment of local workforce, skills development and training of the local workforce);

investment in supplier development (developing supplies and services locally);

procurement of supplies and services locally (creating business opportunities with local enterprises for economic development);

training to local businesses to produce goods and services that meet the standards and requirements of multinational operators;

developing a retrenchment plan;

develop and implement a mobilization plan

develop and implement a demobilisation plan (as skills and training already starts during construction)

create opportunities to consistently renew the Project’s license to operate;






Management Plan/s


- Enhance engagement with stakeholders; and

- Manage and monitor implementation of LCP.


· Local Labour Targets

- It is advisable that the target to employ local people is raised.

- For unskilled labour it should be very high (80% or higher).

- There should also be a gender element, if possible and subject to the security and safety of women, for camps.

- For unskilled workers, a ballot system could be used to ensure the employment system is fair and equitable.

· CESMP

· CCMP

· GMP

· HRWMP

· HRMP

· IMP

· LCP

· OHSP


Interruption of Passageways

Impact Associated with Access Restrictions on IP/Nomadic Communities

· A Nomadic Peoples Seasonal Migration Management Plan should be developed prior to construction to include the following mitigation measures as a minimum:

- Construction works should be timed where possible to avoid seasonal migration routes, or steps should be taken to identify alternative migration routes or ensure safe passage across the ROW;

- Alternate routes could be in public or community spaces when current routes are under construction; and

- In addition to coordinating with nomadic groups, the coordinator should collaborate with community councils, religious networks, or civil service organizations serving indigenous communities to help communicate impacts.

· CESMP

· NPSMMP

· HRMP

· SEP

· TPMP







Management Plan/s


· Mitigation measures for this impact are aimed at avoiding or reducing negative impacts on communities and on planning and implementing a robust community engagement program. The ADB (2013) recommends 1) integrating social interventions at a community level in Pakistan versus focusing measures at an indigenous group or subgroup level, and 2) recognizing that the tribal context and expectations mandate heightened consultation and participation. This will prevent conflict that may be caused by focusing on ethnic or indigenous distinctions.

· As part of the TPMP, a robust construction and nomadic migratory schedule should be developed.

· An onsite nomadic crossing coordinator should conduct a census of nomadic groups crossing the two provinces to determine whether construction timing coincides with winter and summer migratory seasons. Following this determination, the coordinator should undertake engagement and/or outreach sessions one season in advance of construction into provinces through which construction will occur and migrants will be crossing.

· The coordinator shall engage with local elders within construction Lots to identify possible passageways and negotiate passage during construction.

Effects of a large-scale infrastructure construction project

Impact on Vulnerable Groups including Women, People with Disabilities, and Human Rights Issues

As part of the Gender Management Plan, Human Resources and Workers Management Plan, and LCP developed for this Project, the EPC Contractor shall integrate opportunities for disadvantaged persons and persons with disabilities. These plans should provide

· CESMP

· CCMP

· GMP

· HRMP







Management Plan/s


opportunities for women and women’s groups to participate in the work force to the extent safe and practical, and assist them in having good quality work standards so that they can train others and are able to work with other companies or government agencies in the future.

· The Gender Management Plan shall be developed to include the following mitigation measures as a minimum:

- Ensure that women and girls are provided a safe space where they can fully participate in Project engagement and consultation;

- Establish appropriate hours and locations of meetings that allow women to participate (taking onto account that it should be culturally appropriate);

- As far as possible, given security and socio-cultural constraints, influence/inform authorities responsible for the LAP, to explicitly consider and compensate for loss of land experienced by women and girls who do not have control over their income;

- As far as possible, develop employment opportunities that prioritize equal opportunities for women’s training schemes to ensure women have the basic skills necessary for employment;

- Establish codes and training for staff prohibiting the provision of transportation or rides to community members to minimize perceptions of inappropriate behaviour or additional risk to women and children;

- As far as possible, given security and socio-cultural constraints, ensure requirements for

· HRWMP

· LALRP

· LCP

· OHSP

· SEP






Management Plan/s


contractors explicitly state recruitment of women, as well as equal amount and form of pay, occupational H&S support, and anti-discrimination/ abuse contracts;

- As far as possible, given security and socio-cultural constraints, provide support for female contractors to obtain any certification or formal registration needed;

- As far as possible, given security and socio-cultural constraints, alter schedules or timelines allowing women entrepreneurs to provide services at convenient times (deliveries during the day etc.); and

- As far as possible, given security and socio-cultural constraints, provide transportation support if female subcontractors do not have their own access and negotiate rates to counter cost of fuel etc. at cost.

· As part of the Human Resources and Workers Management Plan developed for this Project, the EPC Contractor should:

- Integrate opportunities for women and persons with disabilities where wherever it is safe and culturally acceptable to do so.

- All gender focused initiatives will, as the first priority, take into account women’s security. Security for women is TPCL’s primary concern and all opportunities for including women in the workforce must first be screened against TPCL’s Security Plan.

- Where such opportunities are approved safe for women, good quality work standards are to be provided.






Management Plan/s


· As part of the Community Development Plan, TPCL shall:

- Consider developing training programs for women and persons with disabilities, with the aim of increasing their future employment opportunities.

- Training should as far as possible include food and health safety standards courses and other technology training programs. These shall be offered as an in-kind compensation measure that will help them to establish new and/or improved livelihoods.

- Short-term vocational training will be offered to eligible households for an agreed amount and period of time.

· The Project’s SEP shall be reviewed regularly, ensuring that consultation with affected communities continues and that the needs of vulnerable community members, are considered.

· Additional livelihood restoration support for vulnerable parties, including women, which are economically displaced by the Project, shall be provided.

· Within the PAI, female-headed households were reported to be 0.34%, which is much lower than the national average. Given the need to safeguard female-headed households and women in general, the recommendation is that a gender specialist to be retained as part of the LAP and LRP.

· TPCL should also consider health intervention to increase the immunization coverage in the TAPI pipeline districts with lowest indicators of immunization. This could readily be extended to






Management Plan/s


cover advice on pre-natal and post-natal care to benefit women in the local communities.

· Overall, vulnerable groups may require additional measures to obtain compensation and Project benefits. Targets should be set for the EPC Contractor to employ people from disadvantaged groups.

Archaeology and Cultural Heritage

Pre-construction/Construction activities

Impact of Pre-construction Activities on Archaeology and Cultural Heritage.

· Although the survey team identified only one karez system (the Inzargai Karez System) during the field survey, there is potential for a number of other karez systems to be present along the pipeline route. A pre-construction survey dedicated to investigating the Khojak Tunnel, the Inzargai Karez System, along with any as-yet unidentified karez systems will be required. This will inform the need for any relevant rerouting or engineering solutions required as part of the detailed design process;

· In the case of the Khojak Tunnel, the Inzargai Karez System, and any as-yet unidentified karez systems, care will be taken during the pre-construction activities to ensure that the pipeline does not cross the path of the tunnel or karez system;

· In relation to the Tomb of Hazrat Shah Yousaf and the Naqiba Abad Archaeological Mound, these sites should be avoided by the pipeline route. There is ample flexibility within the 500 m corridor to strategize accordingly. It is recommended that caution be taken to avoid any damage to these sites and structures, including any indirect damage from vibration;

· CESMP

· CFP

· CHMP

· WCMP

· WMP

· SEP







Management Plan/s


· If the identified sites cannot be avoided, the Project and their contractors must work with the relevant national authorities to understand whether affected sites can be reinstated following construction and the impact that this will have on the overall value of the site;

· If anything gets unearthed during the excavations of the pipeline, either known or unknown, the incident must be recorded fully, authorities contacted, and the discovery and its location must be documented;

· The results of the baseline survey (NAFTEC/MAB’s subcontractor, 2018) should be considered for the pre-construction planning and management process;

· TPCL will undertake GIS-based predictive modelling prior to construction, and provide the EPC Contractor with GIS mapping layer showing relative likelihood zones of archaeologic area, features, or artefact being present prior to construction; and

· The EPC Contractor shall develop a Cultural Heritage Management Plan (CHMP) and a CFP to define management measures for archaeological and cultural heritage impacts. The CHMP will include the GIS-based predictive modelling mapping undertaken by TPCL. The CHMP and CFP shall be developed in accordance with the frameworks provided in Appendix F.

· A Chance Finds Procedure (CFP) is a Project-specific procedure that outlines the actions to be taken if previously unknown cultural heritage is encountered. The implementation of the CFP is a crucial mitigation measure and considered good






Management Plan/s


management practice for potential impacts of the Project on known and unknown cultural heritage resources.

· In addition to being required to meet international good practice, the CFP also follows the 1975 Antiquities Act, under which the Project Proponent is obligated to:

- Ensure that no activity is undertaken in the proximity of a protected antiquity, within 200 m of protected sites unless prior permission has been obtained from the Federal Department of Archaeology and Museums; and

- If during the course of the Project an archaeological discovery is made, it shall be reported to the Federal Department of Archaeology and Museums.

· The CFP will be communicated to all construction and site staff and be included in all training.

Climate Change

Construction Activities Greenhouse Gas Emissions Contributing to Climate Change

· Climate change mitigation measures to be included in a Project-specific Climate Change Management Plan (CCMP) shall include, but are not limited to, the following:

· Detail design is to include allowance for climate change risk for the 40-year operational life of the Project;

· Detailed design is to include the development of a Climate Change Risk Design Review Procedure for Operations, specifying the engineering design review to be undertaken every five years of operational life to check that the Project design is operating with design parameters following update

· CESMP

· BMP

· BAP

· CCMP

· SEP

· TMP







Management Plan/s


of the climate risk assessment (refer to operation phase mitigation measures outlined in the ESIA Section 7.9.3.7);

· Use fuel-efficient vehicles and machinery where practicable and optimize transport logistics (of people and equipment) to reduce fuel consumption;

· Assess the use of alternative fuels (such as CNG, LNG, LPG, and biodiesel) versus diesel and petrol;

· Source low embedded emissions construction materials where appropriate; and

· Source energy efficient lighting (such as LED) that must also meet security and ecological requirements.

In addition, environmental mitigation measures included in other Project-specific management plans that also address climate change impacts include:

· Encourage the regrowth and revegetation of the pipeline ROW, with measures such as seeding with local grass species or returning to agricultural use, re-spreading topsoil and cleared vegetation to encourage growth from the natural seedbank, and replanting in high-risk areas where stability needs to be rapidly achieved;

· Back-load trucks, and source materials and services from local suppliers where possible;

· Operate vehicles and machinery in a fuel-efficient manner (for example, operate onsite vehicles at an optimal speed and no idling for extended periods);

· Assess construction techniques to determine the most fuel-efficient and least GHG-intensive methods (onsite versus modular construction);






Management Plan/s


· Clear the minimum amount of vegetation for ROW clearance;

· Progressively rehabilitate land cleared for construction, especially exposed soils;

· Maximize the amount of land revegetated;

· Minimize the volume of natural gas released during venting; and

· Consider good quality biodiversity offsets for land cleared.

All management plans shall be developed in accordance with the frameworks provided in Appendix F.

Landscape

Impact of Pre-Construction Activities on the Landscape of Chaman

Measure that will be carried out to minimize impacts will be included in the Landscape and Visual Impacts Management Plan (LVIMP) and are detailed below:

· high standards of construction site practice and good housekeeping should include the tidy storage of materials and unused machinery in laydown areas, and the appropriate handling of waste, to limit degradation in views towards the works;

· construction camps should be organized to keep elements that would cause an impact over long distance (such as scattered materials and machinery, and reflections off vehicles) within compounds and screened from the outside. Topsoil heaps could be used as effective ground-level screens to this end;

· appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen), taking into account that the security requirements for lighting take

· CESMP

· BAP

· BMP

· LCP

· LVIMP

· SECP

· SEP


Pre-Construction Activities on the Landscape of the Sulaiman Mountains

Pre-Construction Activities on the Landscape of the Sulaiman Piedmont

Pre-Construction Activities on the Landscape of the Indus Plain

Construction Activities on the Landscape of Chaman






Management Plan/s


Construction Activities on the Landscape of the Sulaiman Mountains

precedence over landscape and visual impact mitigation. While glare will notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;

· buildings introduced into the landscape due to the non-CS AGIs in Phase I shall, as far as practical, be coloured appropriately to minimize their visual prominence within the surrounding landscape, taking into account safety engineering requirements, cultural context, and community consultation;

· local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of modern materials (through reduction), and to screen ground-level views of industrial elements; and

· audits will be conducted to verify the continued implementation of the LVIMP, to ensure mitigation measures are being carried out as required;

· Additional measures for impacts on the Sulaiman Mountains include:

- tracks and roads create distinct scars across the Sulaiman Mountain landscape, whose floor-plain has a consistent naturalized texture formed by rocky slopes, gravel, and alluvial soil. Therefore, all temporary tracks and roads within the Sulaiman Mountains should be reinstated following completion of their use, whether this be the reinstatement of alluvial topsoil, or the rocky crust of the slopes;

Construction Activities on the Landscape of the Sulaiman Piedmont

Construction Activities on the Landscape of the Indus Plain






Management Plan/s


- topsoil (or the equivalent rocky layer) should be returned as close to its original source as possible, and in all cases, should match the appearance of the adjacent ground;

- these areas should be left to naturally vegetate to ensure a consistency of native plant communities and to avoid likely long-term failures in planting;

- reinstatement should occur for any laydown areas, construction camps, and pipe yards that are no longer in use; and

- In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state;

· Additional measures for impacts on the landscape of the Indus Plain include:

- tracks and roads (including temporary roads), construction camps, and pipe yards should be arranged to sit within the north/south-east/west grid of the Indus Plain, rather than breaking the strong land pattern. This will increase the success and speed of reinstatement works and minimize impact while the elements are still present.

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s Environmental and Social Management Action Plan [ESAP] for discussion with Pakistan authorities) to define erosion control mitigation measures. These management plans, when combined with the reinstatement measures






Management Plan/s


developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized. The management plans shall be developed in accordance with the frameworks provided. Dust control measures as detailed in the ESIA Section 7.2. Ambient Air Quality Impact Assessment should be implemented to reduce the visual prominence of the works across long views.

Table 4-3 – Phase 1 Commissioning/Start-up Phase Impacts and Mitigation Measures


Environment and Social impact

Key Mitigation Measure Relevant

Management Plan Implementation

Timeline

Noise and Vibration



Plant and equipment;

Reinstatement and clean-up activities

Noise associated with pipeline commissioning and start-up activities.

· Construction mitigation measures also apply here. These would need to be implemented by the contractors on-site in order to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at the minimum level practicable.

· Prior to hydrotesting, the contractor should:

- Define the exclusion zone for hydrotesting;

- Identify these locations and sensitive receptors in the proximity and inform residents about the works;

- Hydrotesting activities should be address in the Noise and Vibration Management Plan and a dedicated Hydrotest Environmental Management Plan. The Noise and Vibration Management Plan must consider hydrotesting activities and locate these away from sensitive receptors as far as practically possible (> 500 m). Where hydrotest locations cannot be located away from sensitive receptors, less noisy equipment and methods such as condensers, water injection or discharging into water, and fitting of silencers must be used;

- Place the generators, which are one of the main noise sources from this activity, within acoustic enclosures and away from the sensitive locations, as much as practicable; and

- Do not exceed the scheduled period for hydrotesting and this should be minimized as far as practicable.

CESMP

HEMP

HMMP

NVMP

SEP

SPRP

WMP

During commissioning and start-up activities


Hydrotesting Impact on Water Availability due to Hydrotesting

HEMP During commissioning



Impact on Water Quality due to Hydrotesting

The following mitigation measures should be applied for Medium significance impacts during Phase I commissioning/start-up:

· Develop a Project-specific Hydrotest Environmental Management Plan (HEMP) to capture all activities involved in the abstraction, potential additives, testing, treatment, discharge, and performance monitoring of hydrotesting water, including relevant health and safety considerations (such as exclusion zones to be implemented);

· Ensure there is an adequate SPRP, Water Management Plan, Waste Management Plan, and HMMP prior to commencement of commissioning works;

· Schedule in advance the proposed hydrotest date and ensure the area where it is to be conducted is assessed and surveyed for environmentally sensitive receptors;

· Notify in advance the scheduled activities to secure any permits or approvals that may be necessary for activities such as water withdrawal, disposal or transport between watersheds. Land owners and relevant government agencies should also be notified prior to conducting large-scale hydrotests;

· Ensure than land needed for hydrotesting activities is included in the Land Acquisition Plan for proper management before the use;

· Landowners and relevant government agencies should also be notified prior to conducting large-scale hydrotests;

· The following additive design mitigation measures shall be implemented:

- for any hydrotest additives, ensure the use of low environmental impact and or biodegradable substances;

- minimize the usage of any additives which will affect water quality;

- water used for hydrotesting can typically be returned to its source or released to land with the

HMMP

LALRP

NVMP

SEP

SPRP

WAMP

WMP

and start-up activities

Impact on Soil Quality due to Hydrotesting



landowner’s permission. Regulatory approval conditions may require laboratory analyses to verify that the water has not become contaminated during handling. In such situations, it is advised that samples of the source water be collected and analysed prior to hydrotesting to ensure that background concentrations of certain parameters are acceptable;

- water containing additives or water used to hydrotest an existing section of pipeline is likely to require treatment prior to discharge;

- conduct aquatic toxicity tests on sample water prior to discharge, if additives are used (for example, biocides, oxygen scavengers, corrosion inhibitors, detergents, antifreeze, or leak detection tracers) and treat if toxicity is higher than reference water from the waterbody;

- in the event that hydrotesting water does not meet toxicity test discharge criteria, treatment and disposal options at the test location (including transporting the water through the pipeline for storage and eventual treatment) are to be evaluated;

- should discharge criteria not be available in the legislation and guidelines referred to in this section of the ESIA report, the EPC Contractor is referred to the UK Environment Agency Refining Sector Guidance Note EPR 1.02 (2009);

- if water is to be discharged from one river to another, analyse the presence of living alien species prior to discharge;

· The following water abstraction and discharge physical mitigation measures shall be implemented:

- pump intakes during withdrawal from surface water bodies must be located at least 0.3 m above the bed, whenever possible;

- ensure that pump intakes point downstream;



- ensure the use of screen pump intakes with a maximum mesh size of 2.5 mm to prevent the removal of juvenile fish and other organisms from the water body;

- ensure that a 0.038 m/s velocity of flow at the screen is not exceeded;

- if the water is particularly turbid, additional filtering or sufficient settling time in a holding tank may be required to reduce suspended solids prior to use;

- ensure the use of best practices to minimize the quantity of water supplied for testing purpose by requiring recycling and reuse;

- the withdrawal rate shall not exceed 10% of the stream flow; however, the regulatory agency may identify specific requirements through permit or approval conditions. There may also be restrictions pertaining to the time of year that water withdrawal is allowed to take place;

- this may limit abstraction to specific times of the year. Gauging of the rivers upstream of the point of abstraction should be undertaken to confirm that the abstraction is not adversely reducing the river flow and exceeding the agreed criterion;

- abstraction from, and discharges to, all rivers should meet the requirements of the national and local agencies;

- monitor discharged waters from hydrotesting activities to be sent to an evaporation pond / lagoon or river depending on water quality and chemical composition;

- for discharge to land, water must be released in a manner that will not cause soil erosion;

- release water at a rate that will not increase the temperature or decrease the dissolved oxygen levels within a short distance from the discharge point;



· The following hazardous material storage, management, and spill response mitigation measures shall be implemented:

- whenever possible, the pumps used to pressurize a section of pipeline for a hydrotest should be located a minimum of 50 m away from any surface water bodies or ditches that may lead directly into one. As an added precaution, all pumps, tanks and associated piping should be situated within a bermed area to contain the inadvertent release of any deleterious liquids;

- storage for fuel, lubricants, and other hazardous materials must be situated as far away from water courses as possible within an impermeably lined, bermed area; and

- spill kits and emergency response equipment will be stationed nearby during a hydrotest to deal with the release of any deleterious materials. An exclusion boom may be pre-deployed to protect sensitive areas identified during the pre-test site survey.


Extraction and discharge of water and elevated noise levels

Disturbance to ecological receptors (i.e., aquatic environments and fauna)


· For noise, implement the noise mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment and consider the sensitive points in the life cycle of ecological receptors (such as breeding) in defining construction schedule, to the extent practicable. Examples could include not hydrotesting during bird nesting season and avoiding fish spawning

· CESMP

· BAP

· BMP

· NVMP

· HEMP

· WMP

· SEP

During commissioning and start-up activities i.e., hydrotesting



events for water withdrawals and discharges. This will be detailed within the BMP.

· Develop a Project-specific HEMP to capture all activities involved in the abstraction, potential additives, testing, treatment, discharge, and performance monitoring of hydrotesting water, including relevant H&S considerations (such as exclusion zones to be implemented). Refer to Section 7.4.4.4 for a detailed list of mitigation measures to be included in the HEMP.

· Specific mitigation measures relating to hydrotesting water intake and discharge include the following:

· Ensure the use of screen pump intakes with a maximum mesh size of 2.5 mm;

· Do not exceed a 0.038 m/s velocity of flow at the screen;

· Locate the intake at least 0.3 m above the river bed;

· Point the intake downstream;

· Limit the withdrawal rate to no more than 10% of the flow;

· Conduct aquatic toxicity tests on sample water prior to discharge if additives are used (such as biocides, oxygen scavengers, corrosion inhibitors, detergents, antifreeze, or leak detection tracers) and treat if toxicity is higher than reference water from the water body;

· Release water at a rate that will not cause scour;

· Release water at a rate that will not increase the temperature or decrease the dissolved oxygen levels within a short distance from the discharge point; and

· If water is to be discharged from one river to another, analysis of the presence of living alien species should be conducted prior to discharge.


Commissioning/Start-up Activities

Impact of Commissioning/Start-up

· The implementation of a CFP as a mitigation measure and good management practice for potential impacts of

· CESP

· CHMP



Activities on Archaeology and Cultural Heritage

the Project on known and unknown cultural heritage resources should continue to be followed into the commissioning/start-up phase.

· Tangible assets that have been avoided during the construction phase may be impacted by commission/start-up activities. Therefore, the direct and indirect avoidance of such resources should be planned and implemented into all Project phases.

· CFP

· SEP



Table 4-4 - Phase 1 Operational Phase Impacts and Mitigation Measures





Timeline

Ambient Air Quality

Two Fired Oil Heaters and one diesel generator installed at each Off-take Unit, PAK-OS01, PAK-OS02 and PAK-OS03; and

Three Fired Oil Heaters and two gas generators installed at the Metering Station Unit, PAK-MS01.

Impact from NO2, SO2, PM10, and PM2.5

· The FEED emission studies (TPCL, 2017a, 2017b, 2017c) have reported NOx emissions of 320 milligrams per normal cubic meter (mg/Nm3) for a fired heater and 200 mg/Nm3 for a power generation unit. It is therefore proposed to remove the fired heaters form the design to reduce the NOx emissions significantly. However, it must be noted that this is representative of a worst-case maximum capacity emission scenario defined at a preliminary design stage, and actual emissions from Project units are likely to be lower.

· Detailed engineering design should perform a BAT analysis to select the best technologies that could be included in the design of the AGIs, to minimize the NOx emissions from power generation units.

· OESMP

· AQMP

· CCMP

· SEP

Throughout operation

Noise and Vibration

Process units and equipment during normal operation within the AGIs (excluding compressor stations).

Noise associated with AGIs. The following engineering controls are recommended as a form of GIIP measures:

· Utilize the best available technology by selecting equipment with the lowest noise emission levels, wherever possible;

· Fit silencers, acoustic insulation, and noise enclosures, where practicable;

· Ensure new plant equipment is properly maintained in accordance with equipment maintenance requirements to avoid any potential increase in the noise levels caused due to poor maintenance;

· Use machinery and equipment in accordance with the manufacturers’ instructions; and

· No plant should be left running unnecessarily.

OESMP

HEMP

HMMP

NVMP

SEP

SPRP

WMP








Timeline


Use of equipment during operations


· Temporary waste disposal tanks can be used to collect debris from pipeline internal inspection operations.

· Vegetation waste resulting from periodic ROW maintenance should be heaped and composted or managed under arrangement with input from local community members as potential beneficiaries.

· OESMP

· BAP

· BMP

· SEP

· TMP

· WAMP


Presence of the pipeline

Impact on Karez Systems / Irrigation Pattern due to Permanent ROW

· In line with mitigation set out Section 7.7. Cultural Heritage Impact Assessment, avoidance of karez systems is recommended. Suitable stakeholder consultation will need to take place to ensure the owners and users of any karezes that may be impacted by the Project are consulted with prior to construction works commencing, this will be detailed with the Stakeholder Engagement Plan.

· Location of karezes will be checked against the FEED database and, where different, the Project will be informed;

· Staff involved in construction will be well trained on karez management prior to construction;

· Location of karezes in the vicinity of the pipeline ROW will be marked on the ground;

· A geotechnical engineering evaluation of the risk of collapse of a karez at location of pipeline crossing will be done prior to constructing the pipeline across the karez;

· Works over an area marked as the karez will progress as quickly as possible to minimize time that higher loads are placed above the structure;

· All heavy vehicles will avoid parking in a 50 m exclusion zone on either side of marked karez;

· OESMP

· CHMP

· SEP

· WCMP

· WMP

Prior to Operation







Timeline

· For each karez crossing, the mitigation methods employed will be documented;

· Contingency water supply shall be immediately available in the event of a karez collapse;

· Remedial action shall be taken where construction activities result in karez collapse;

· The location of existing irrigation systems in the vicinity of the pipeline ROW will be recorded prior to construction works commencing;

· Any drainage systems used as a water source will be mapped prior to works commencing and impacts will be avoided and mitigated;

· Avoidance of channels used as a water source, including those for agricultural land, will be a priority; if they cannot be avoided then the impacts will be mitigated fully by temporarily redirecting water flow during construction to ensure the existing flow is maintained for the duration of the Project;

· Any cut-off of existing drainage systems shall be communicated in advance to the interested parties and any action shall be authorized by specific agreement; and

· In general, the irrigation drainage shall be maintained during trenching by adopting specific measures such as: maintain existing flow by using piping/small diversions or keep the watercourses open through culverts.


Operational noise/light/activity

Disturbance to ecological receptors


· OESMP

· BAP

· BMP

· NVMP

· TMP








Timeline

· Minimize the time lights are on, particularly at night, during migration periods of birds (spring and fall), and within or near high biodiversity value features;

· Use PC Amber or filtered yellow / green LED lights (Longcore et al., 2018) and shielding to direct light to only where it is needed (such as to eliminate spillage). Shielding can be provided by the fixtures or screening;

· Utilize designated roads only, at speeds within defined limits, and adhere to the Traffic Management Plan. This will confine the area of impact and minimize noise, dust and vehicle-induced animal mortality. The survey team observed numerous reptiles, a group of organisms that are susceptible to being killed by vehicles;

· Implement noise mitigation measures to keep consistent noise levels to less than 45 dBA within a short distance into native habitat;

· Develop a set of mitigation measures specific to the Indus River Dolphin, including monitoring an exclusion zone for any activities that could produce noise or light that could potentially disturb marine mammals. These measures should be included in a Marine Mammal Mitigation section of the BMP; and

· Employ strict control measures for any spills from vessels required for the pipe bridge maintenance.

· WCMP

· SEP

· SPRP

Socio-Economic and Community Health

Water Withdrawal Impact Associated with Abstraction of Hydrotesting Water on Communities

· Abstraction from the Sutlej River, in particular, needs to be timed when flows exceed 5.0 m3/s, so that no more than 10% of the river flow is removed. The 10% criterion is for guidance only and should be discussed and agreed with the appropriate agencies. The river needs to support other abstractions and support fisheries and the abstraction should not result in a deterioration in the ecological health of the surface waters or groundwater.

· OESMP

· BAP

· BMP

· HDD EMP

· CHSP

· SEP

· WMP








Timeline

Abstraction should also meet the criteria specified in Impact SEPAK04.

· This may limit abstraction and hence hydrotesting based on river water use to specific times of the year. Gauging of the rivers upstream of the point of abstraction should be undertaken to confirm that the abstraction is not adversely reducing the river flow and exceeding the agreed criteria. Abstraction from and discharges to all rivers should meet the requirements of the national and local agencies.

· The following measures specific to hydrotesting should be included in the Project’s Occupational H&S Plan:

- Hydrotesting can be hazardous in nature due to the high pressures and flows of water involved. A hazard assessment must be undertaken for this activity and any other hazardous activity identified. This would likely include designation of a safe zone and appropriate signs and barriers, never tightening fittings under pressure and wearing hearing protection;

- Hydrotests will predominately be located at a minimum distance of 500 m from local communities. Noise impacts for hydrotesting will be mitigated by measures outlined in the Noise and Vibration Management Plan and to a lesser extent through the Hydrotest EMP.

- The Grievance Mechanism will be monitored to understand if complaints are made in relation to water supply affects from abstraction of hydrotesting water, and any issues shall be dealt with as a matter of urgency.

- Also refer to mitigation measures related to hydrotesting water abstraction in Section 7.5. Ecology and Biodiversity Impact Assessment.







Timeline

Noise generated by commissioning/start-up activities

Impact Associated with Noise

· Proactive outreach with potentially affected settlements, particularly within 10 km, is essential to reducing the potential shock to human hearing. It is recommended that clear and early communication and consultation with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken. TPCL’s contractor should provide guidance to affected populations based on H&S risks.

· There will be challenges in reducing some of the commissioning/start-up noise levels through mitigation. In particular, noise events occurring during hydrotesting activities due to the small distance between the receptors and activities. It is however anticipated that the high-pressure discharges during hydrotesting are one-off events at a given testing pipeline section and in general the commissioning/start-up works would be moving along the pipeline route alignment. Thus, the impact would be at a single location for a short period of time.

· The equipment to be used for hydrotesting is not defined yet. It is however recommended to choose quiet equipment/methods such as condensers, water injection or discharging into water as well as to fit silencers into the equipment. For this reason, these activities can be classified as temporary with reduced impact significance.

· The EPC Contractor should not exceed scheduled period for hydrotesting and this should be minimized as far as practicable.

· OESMP

· HDD EMP

· NVMP

· SEP

Prior to operation

Employment

Requirements

Impact Associated with Employment and Economic Development


· To enhance local opportunities, TPCL should implement a long-term training program to increase the level of local employment from the anticipated 5% to 10% during the first 2 years of operation.

· OESMP

· CDP

· GMP

· HRWMP

· HRMP

Prior to operation







Timeline

· TPCL shall ensure that local employment opportunities are included in the LCP prior to hiring commencing. The LCP shall include long term training for operational staff as a component of its capacity building initiative.

· LCMP

· SEP

Worker Health and Safety

Impact Associated with Increased Risk of H&S Incidents due to Accidental Leaks and Ruptures

· The eventuality of a H&S incident related to the pipeline shall be addressed in the previously recommended Community Emergency Response Plan.

· OESMP

· CHSMP

· EMRP

· GMP

· HRMP

· OHSP

· SPRP

· SEP

· TMP

Prior to and Throughout Operations

Security Impact Associated with Attacks on the Pipeline or Associated Facilities

· A key mitigation measure is to engage in relationship building with key stakeholders along the PAI, providing community development/investment to affected communities. This will increase the sense of ownership and, combined with the pledged protection, will provide for pipeline support. Access to the pipeline ROW may be restricted to limit this risk.

· OESMP

· CHSMP

· EMRP

· GMP

· HRMP

· OHSP

· SPRP

· SEP

· TMP

Prior to and throughout Operations


Operation activities on archaeology and cultural heritage

Impacts on tangible assets, impacts related to vandalism or looting, natural gas venting, accidental spillages, over-extraction of water etc.

· The implementation of a CFP as a mitigation measure and good management practice for potential impacts of the Project on known and unknown cultural heritage resources should continue to be followed into the operation phase. Tangible assets that have been avoided during the construction phase may be impacted

· OESMP

· CHMP

· CFP

· SEP

When necessary







Timeline

during operation activities, such as maintenance vehicle access. Therefore, the direct and indirect avoidance of such resources should be planned and implemented into all Project phases.

· Assets with the potential to be impacted during operation activities should be protected and clearly demarcated for continued Project avoidance and protection from vandalism or looting, and natural gas venting locations should take into consideration the location of heritage resources as to be downwind from resources. Also, avoidance and care should be taken to avoid accidental spillages and over-extraction of water resources in the area, to avoid differential ground settlement, as detailed in the ESIA Section 7.4. Physical Environment Impact Assessment.

Climate Change

Pipeline Climate Change Impacts on Pipeline Integrity

Mitigation Measures for Greenhouse Gas Emissions Contributing to Climate Change are as follows:

The CCMP should include both emission reduction and climate risk and adaptation mitigation measures.

Emission reduction climate change mitigation measures include, but are not limited to, the following:

· Regular corrosion and leak detection monitoring, intelligent pigging, and regular patrols to check for leaks and undertake prompt repairs. This is important around pressure relief valves, compressor seals around rod packing, connectors, and pneumatic controllers;

· When carrying out pipeline blow-down activities for pipeline maintenance, consider using pipeline pump-down techniques. These involve using in-line compressors either alone or in sequence with portable compressors. This removes the natural gas from sections of the pipeline before maintenance or repair.

· OESMP

· CCMP

· TMP

· SEP

Throughout Operation

Climate Change Impacts on Pipeline Instability due to Scour

Climate Change Impacts on Pipeline Instability due to Channel Migration







Timeline

This will reduce GHGs associated with natural gas venting;

· Re-evaluate the design considering the potential for increases in future scour due to projected increases in peak stream flows;

· Re-evaluate the design considering the potential influence of climate change on channel migration;

· Re-evaluate the design considering the potential influence of climate change related changes to groundwater conditions on buoyancy;

· Re-evaluate the design considering the potential influence of climate change on soil stability; and

· Where possible, through technology advances, reduce the production of GHG emissions as a result of operations, through the use of BAT.

Climate risk and climate change adaptation measures include, but are not limited to, the following:

· Every five years update the climate risk assessment provided in Section 6.9. Climate Change Baseline based on the most recent Intergovernmental Panel on Climate Change (IPPC) data;

· Following update of the climate risk assessment, undertake a Climate Risk Assessment Design Review based on the procedure develop with the detailed design. The review should include, but is not limited to, the following:

- re-evaluate the design considering the potential influence of climate change on soil stability;

- re-evaluate the design considering the potential influence of climate change

Climate Change Impacts on Pipeline Instability due to Buoyancy

Climate Change Impacts on Pipeline Instability due to Changes in Soils

Greenhouse Gas Emissions Contributing to Climate Change







Timeline

related changes to groundwater conditions on buoyancy;

- re-evaluate the design considering the potential influence of climate change on channel migration; and

- re-evaluate the design considering the potential for increases in future scour due to projected increases in peak stream flows.

Landscape and Visual Amenities

Pipeline Trench / Corridor

Impact due to Operation of Pipeline on the Landscape of Chaman

Mitigation measures for impacts due to the pipeline trench /corridor are as follows:

· The pipeline trench and applicable areas of the ROW shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope, with existing topsoil (or equivalent rocky layer) being returned, as close as possible, to its source and stored appropriately during construction;

· Reseeding should be used where appropriate to speed up the reinstatement process; and

· Native plant communities shall be allowed to revegetate naturally, so as to avoid noticeable changes in vegetation make-up across the landscape and to avoid potential long-term failures in planting.

Mitigation measures for impacts due to industrial elements are as follows:

· Buildings introduced into the landscape due to the AGIs shall, as far as practical, be coloured appropriately to minimize their visual prominence within the surrounding landscape, taking into account safety engineering requirements, cultural context, and community consultation;

· OESMP

· BAP

· BMP

· NVMP

· LVIMP

· SECP

· WAMP

· SEP

From construction and throughout operation Pipeline Trench /

Corridor Impact due to Operation of Pipeline on the Landscape of the Sulaiman Mountains


Impact due to Operation of Pipeline on the Landscape of the Sulaiman Piedmont


Impact due to Operation of Pipeline on the Landscape of the Indus Plain

Industrial Elements Impact due to Operation of Phase I AGIs on the Landscape of the Sulaiman Mountains







Timeline

Industrial Elements Impact due to Operation of Phase I AGIs on the Landscape of the Sulaiman Piedmont

· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of exposed machinery and modern materials (through reduction) on the rural landscape, and to screen ground-level views of industrial elements;

· Apply locally appropriate screen planting and site arrangements for the AGIs at the Indus Plain;

· Lighting shall only be used when required and shall be directed at the areas where it is needed, to minimize light pollution at a distance from direct shine and diffuse glare (including the use of LED rather than the highest lumen bulbs like halogen), limiting the installation’s visibility over long views in day and night; and

· Lighting shall take into account that the security requirements for lighting take precedent over landscape and visual impact mitigation.

Additional mitigation measures for impacts due to Operation of Phase I AGIs on the Landscape of the Indus Plain are as follows:

· AGIs within the Indus Plain shall be arranged to sit within the existing north/south-east/west field pattern, with locally appropriate tree and shrub planting installed around the perimeter, and within site boundaries, to screen industrial elements; and

· Planting should be considered at the AGIs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the AGIs within the fence line, if security permits.

Industrial Elements Impact due to Operation of Phase I AGIs on the Landscape of the Indus Plain



Table 4-5 – Phase 1 Decommissioning Phase



Key Mitigation Measures Relevant Management

Plan Implementation

Timeline

Noise and Vibration

Plant and equipment required to decommission the pipeline and AGIs (excluding compressor stations).

Noise associated with Pipeline and AGIs Decommissioning activities.

· Mitigation measures set out for the Construction Phase would be applicable during decommissioning. These would need to be implemented by the contractors on-site to minimize the effect of noise and maintain the noise levels at NNSRs at the minimum level practicable to avoid altering the existing noise environment at those locations.

· DESMP

· NVMP

· TMP

· SEP

Decommissioning and Closure


Land disturbance and other stressors

Habitat disturbance on land · Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP), which will be made up of the flora and fauna management and monitoring as per Chapter 10. Preliminary Environmental and Social Management Framework (ESMF);


· Restore soils and the native plant community disturbed by decommissioning activities;

· Restore soil and the native plant community in AGI footprints and roads where habitat was eliminated;

· Implement the air quality mitigation measures described in Section 7.2. Ambient Air Quality Impact Assessment;

· Minimize additional light at night;

· DESMP

· BAP

· BMP

· SEP

· SPRP







Plan Implementation

Timeline

· Implement the noise mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment;

· Assess bankside erosion control measure for integrity and only remove in the event that their integrity is likely to fail and lead to bankside erosion. In the event the structures integrity is high, repair as required and leave in place avoiding creation of sediment and noise impacts. This is especially relevant to the Indus River;

· In the event bankside erosion control measure decommissioning work is required for the Indus River the use of pingers during bankside activities to encourage Indus River Dolphins to avoid the area. Concurrently MMO during the works, restricting the speed and movement of any project-associated watercraft. These measures should include reporting / communication protocols between MMO and decommissioning crew; and

· Employ strict control measures for any spills from vessels required for the pipe bridge decommissioning.


Pipeline and AGIs dismantling (excluding compressor stations).

Impact on Soil Characteristics, Subsurface Structures, Stability and Productivity

· If parts of the pipeline are to be decommissioned and removed, activities similar to that undertaken during the construction phase will need to be executed, with a similar environmental impact assessment required for the operation.

· DESMP

· BAP

· BMP

· SECP

· WMP


Impact on drainage characteristics and natural water flow

Filling of pipes with inert material and removal of AGI and

Direct land disturbance and other stressors






Plan Implementation

Timeline

roads (excluding compressor stations).


Decommissioning activities

Impact on Permanent Populations due to Decommissioning Noise

· Contractors should implement GIIP measures to maintain the noise levels at fence line and maintain noise emissions at as a minimum level as practicable.

· DESMP

· NMP

· SEP




Erosion of tradition and cultural values, severe restriction in access of cultural/historical sites. Dust emissions and accumulation on cultural heritage sites, monuments, structures and other features.

· The implementation of a CFP as a mitigation measure and good management practice for potential impacts of the Project on known and unknown cultural heritage resources should continue to be followed into the decommissioning phase. Tangible assets that have been avoided during the previous phases may be impacted by ground disturbances that may extend beyond the construction phase. Therefore, the direct and indirect avoidance of such resources should be planned and implemented.

· DESMP

· CFP

· SEP



Decommissioning Activities - vehicle movements, active construction

Impact of Decommissioning Activities on the Landscape of Chaman

· High standards of construction site practice and good housekeeping should include the tidy storage of materials and unused machinery in laydown areas, and the

· DESMP

· BAP

· BMP







Plan Implementation

Timeline

camps, site clearance, excavations, soil storage, active machinery and demolishing of AGIs (excluding compressor stations).

Impact of Decommissioning Activities on the Landscape of the Sulaiman Mountains

appropriate handling of waste, to limit degradation in views towards the works;

· Construction camps should also be organized to keep elements that would cause an impact over long distance (such as scattered materials and machinery, and reflections off vehicles) within compounds and screened from the outside. Topsoil heaps could be used as effective ground-level screens to this end;

· Appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen), taking into account that the security requirements for lighting take precedent over landscape and visual impact mitigation. While glare will notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;

· Audits will be conducted to verify the continued implementation of the LVIMP, to ensure mitigation measures are being carried out as required.

· Once camps and construction sites are no longer required, they should be reinstated to ensure longstanding landscape effects do not occur. All arisings due to the works, which are not part of the reinstatement works (such as topsoil), should be removed from site (this predominantly relates to waste products);

· All temporary tracks, construction camps, and working areas shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope to avoid un-naturalistic scars being left

· CCMP

· NVMP

· LVIMP

· SECP

· WAMP

Impact of Decommissioning Activities on the Landscape of the Sulaiman Piedmont

Impact of Decommissioning Activities on the Landscape of the Indus Plain






Plan Implementation

Timeline

across an open landscape whose character is often driven by large-scale uniformity in colour and texture;

· Existing topsoil shall be returned, as close as possible, to its source and stored appropriately during decommissioning (in stacks of 1.5 m high or less); and

· Reseeding should be implemented following return of topsoil across where needed, with native plant communities allowed to revegetate naturally at reinstated ground, rather than being planted, to avoid noticeable changes in the vegetation make-up across the landscape and to avoid likely long-term failures in planting.

Additional mitigation measures specific to impact

of Decommissioning Activities on the Landscape of the Sulaiman Mountains are:

· Tracks and roads create distinct scars across the Sulaiman Mountain landscape, whose floor-plain has a consistent naturalized texture formed by rocky slopes, gravel, and alluvial soil. Therefore, all temporary tracks and roads within the Sulaiman Mountains should be reinstated following completion of their use, whether this be the reinstatement of alluvial topsoil, or the rocky crust of the slopes;

· Topsoil (or the equivalent rocky layer) should be returned as close to its original source as possible, and in all cases, should match the appearance of the adjacent ground;

· These areas should be left to naturally vegetate to ensure a consistency of native plant communities and to avoid likely long-term failures in planting;






Plan Implementation

Timeline

· Reinstatement should occur for any laydown areas, construction camps, and pipe yards that are no longer in use; and

· In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state.

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s ESAP for discussion with Pakistan authorities) to define erosion control mitigation measures.

· These management plans, when combined with the reinstatement measures developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized.

· Dust control measures as detailed in the ESIA Section 7.2. Ambient Air Quality Impact Assessment should be implemented to reduce the visual prominence of the works across long views.

· Noise control through the use of best practice machinery and working methods, as described in the ESIA Section 7.3. Noise and Vibration Impact Assessment, should be implemented to minimize the impact of works on the local landscape.

Ambient Air Quality






Plan Implementation

Timeline

Plant and equipment required to decommission the pipeline and AGIs (excluding compressor stations).

Dust associated with Pipeline and AGIs Decommissioning activities.

· Mitigation measures set out for the Construction Phase would be applicable during decommissioning.

· DESMP

· AQMP


Table 4-6 - Phase 1 Non-routine Events / Emergencies (applicable to all Phases)



Key Mitigation Measure Relevant Management

Plan Implementation

Timeline

Ambient Air Quality

The emergency release of natural gas through venting and the use of the emergency generator sets Off-take and Metering stations.

Increased levels of NO2, SO2 PM10 and PM2.5 associated with emissions from AGIs under emergency conditions.

· Maintenance and inspection of diesel generators according to manufacturer’s instructions.

· DESMP

· AQMP

· CHSP

· OCHS

· ERSP

All Project Phases



4.3 Environmental & Social Management Plan - Phase 2

Table 4-7 – Phase 2 General Management Measures




Management Plan/s


The ESMP is not properly implemented.

Unmitigated environmental & social impacts

· TPCL will establish an Environmental and Social Management System (ESMS) to monitor all E&S activities and implementation of the ESMP.

· CESMP

· OESMP

· DESMP

and other more specific plans, as shown below.

· All Project Phases

· TPCL will install a dedicated team in charge of supervising the ESMS and implementation of the ESMP. This will include a management team at the head office, along with in-country and local staff.

Specific Management Plans:

Environment

• Air Quality Management Plan (AQMP)

• Water Management Plan (WMP)

• Waste Management Plan (WAMP)

• Noise and Vibration Management Plan (NVMP)

• Watercourse Crossing Management Plan (WCMP)

• HDD Environmental Management Plan (HDD EMP)

• Sediment & Erosion Control Management Plan (SECP)

• Hydrotest Environmental Management Plan (HEMP)

• Spill Prevention & Response Plan (SPRP)

• Hazardous Materials Management Plan (HMMP)






Management Plan/s


• Emergency Management & Response Management Plan (EMRP)

• Biodiversity Management Plan (BMP); and Biodiversity Action Plan (BAP)

• Climate Change Management Plan (CCMP)

• Flooding Management Plan (FMP)

Socio-Economic

• Human Resources / Workers Management Plan (HRWMP)

• Traffic Management Plan (TMP)

• Community Health and Safety Management Plan (CHSMP)

• Socio-Cultural Management Plan (SCMP)

• Gender Management Plan (GMP)

• Human Rights Management Plan (HRMP)

• Tribal People Management Plan (TPMP)

• Nomadic People Seasonal Migration Management Plan (NPSMMP)

• Cultural Heritage Management Plan (CHMP)

• Chance Finds Procedure (CFP)

• Influx Management Plan (IMP)

• Landscape Visual Impact Management Plan (LVIMP)

• Cumulative Impacts Management Plan (CIMP)

• Local Content Management Plan (LCMP)

• Stakeholder Engagement Plan (SEP)

• Community Development Plan (CDP)

• Land Acquisition and Livelihood Restoration Plan (LALRP)






Management Plan/s


• Occupational Health and Safety Plan (OHSP)

• Construction Camp Management Plan (CCMP)

This list is not exhaustive and additional plans may be introduced as the Project progresses depending on the identification of new receptors.

Table 4-8 – Phase 2 Construction Phase Impacts and Mitigation Measures




Management Plan


Ambient Air Quality

Plant and equipment required to execute construction works of the Compressor Stations.


· Maintenance and inspection of diesel generators according to manufacturer’s instructions;

· Ensure all machinery is properly maintained in accordance to equipment maintenance requirements;


· Wind fences should be considered where appropriate; and

· Road stabilization by use of soil-crete (soil mixed with cement or soil mixed with lime).

· CESMP

· AQMP

· BAP

· BMP

· CCMP

· SEP

· TMP



Increased levels of PM10

and PM2.5 emissions associated with the generation of dust

· Pre-notification of critical dust producing activities and implement Community Liaison procedures;


· Dust generation will be monitored and controlled on an as-needed basis through water spraying






Management Plan


techniques and suppression methods. Dust suppression will be undertaken near populated areas and where required, on unpaved construction roads;

· Dust suppression using watering can be achieved using camp grey water. Alternatives include wood chips and calcium chloride, or other environmentally safe products developed for this specific use. Dust suppression material should not scar the area and prevent vegetation growth (salt for example is not acceptable);







· Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control






Management Plan


systems to prevent escape of material and overfilling during delivery;

· Dust suppression techniques should be implemented, such as applying water (for example, grey water from camps, subject to meeting WHO grey waster guidance WHO-EM/CEH/125/E2006) or non-toxic chemicals to minimize dust from vehicle movements.

For AGIs and temporary facilities the following additional mitigation measures may be applied on an as-needed basis:


· Imported construction material stockpiles should be located away from sensitive receptors.

Noise and Vibration

Preparation works, Plant and equipment required to execute construction works of the Compressor Stations.

Increased noise levels

· Contractors undertaking the activities should follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSR below the permitted limits. The same mitigation measures listed for construction works during Phase I are applicable to Phase II.

· CESMP

· NVMP

· TMP

· SEP

· CHSMP

· SCMP



Noise disturbance during construction




Earth works, site preparation activities;

Access Roads construction;

ROW clearance;

trenching

Impact on Soil Characteristics, Subsurface Structures, Stability and Productivity due to Construction Activities

· Ensure that the required CESMP, including the various management plans (SECP, WCMP, SPRP, HMMP, WMP, HDD EMP, EMRP, SEP) are in place prior to commencement of construction works;

· Implement erosion control measures as detailed in the Construction Concept Reinstatement Plan developed for the Project. Reinstatement will include slope stabilization, erosion protection, surface reinstatement, and bio restoration. Subsoil will be levelled to its original contour or as determined by operational requirements;

· Develop a SECP to support the Reinstatement Plan with specific measures to mitigate impacts, including but not limited to:

- minimize disruption when soil stripping and storing materials. This can be achieved by keeping the footprint of the proposed works to a minimum to minimize impact on the soil quality in the wider area;

- revegetate immediately after construction to limit erosion processes;

- manage the removal and storage of topsoil, subsoil, and any parent material to facilitate the reinstatement stage;

- the first layer of excavated material (topsoil) will be stored separately so that it can be replaced on the surface when the excavated area is restored. Implement appropriate storage of fertile topsoils separately from less productive sub soils. Topsoil from the trench is removed and stored separately from other excavated material, so that it can be used for re-vegetation after the pipe is laid and the trench back-filled;

- to minimize the risks of soil structure destabilization and surface soil compaction,

· CESMP

· BAP

· BMP

· EMRP

· FMP

· HMMP

· HDD EMP

· SECP

· SPRP

· WMP

· WCMP




Dewatering Impact on Water Resources Use and Quality

Consumption of Freshwater Resources

Impact on Water Availability



avoid construction activities during high rainfall events;

- protect topsoil/subsoil stockpiles from run-off. Topsoil storage periods will be kept to a minimum;

· The Water Management Plan shall include, as a minimum, the following measures:

- monitor discharged waters from dewatering activities to be sent to an approved disposal site, such as an evaporation pond / lagoon or river, depending on water quality and chemical composition;

- careful selection of the groundwater abstraction points should be made in order to ensure low sensitivity of the receptors in terms of water availability;

- careful management and control of the groundwater table will be implemented in cases where dewatering is necessary to minimize effects of groundwater level changes;

- monitoring of water levels and flow of the abstraction points should be conducted as appropriate to ensure that abstraction is not causing a net decline in the amount of water

- any discharge shall be approved by competent authority;

- should temporary construction dewatering be required ensure appropriate discharge measures are taken, especially in sensitive areas. Specific attention for risk of spills, contamination in areas with fresh groundwater resources in river valleys with shallow aquifers (to prevent both surface pollution or pollution of groundwater resources);

- intercept and treat run-off from the construction working area for example by using sandbags;



- minimize water consumption as much as possible, by training the workers in personal minimization and recycling practices;

- an abstraction assessment should be performed in advance to determine the volume of abstraction from each intended source, ensuring that the abstracted volume does not have a long-term impact on water levels and / or negatively impact existing water users

- negotiate water offtake with communities / authorities (as applicable);

- desalinate saline groundwater rather than using scarce freshwater;

· The SPRP shall include, as a minimum, the following measures:

- ensure that all fuel is stored in appropriately lined (e.g., double-skinned tanks) and / or bunded areas with containment systems;

- staff must be trained in the use and maintenance of all equipment on site, particularly those that could result in accidental spillages and leaks of fuels and chemicals which will affect soil and groundwater quality;

- specify a monitoring plan to detect leaks / spills and have staff trained in emergency response to deal with any such incidents if they occur;

· The Waste Management Plan shall include, as a minimum, the following measures:

- the EPC Contractors shall manage all solid and liquid wastes, including general refuse from site workers and construction wastes and hazardous wastes, generated during the construction works. Measures shall be put in place to ensure that solid or liquid wastes are not disposed of outside the construction areas;



- general waste generated on-site should be stored in enclosed bins and normal waste streams separated from hazardous;

- hazardous wastes will be stored in a secured area (to prevent vandalism, theft, accidents) and be within a covered area to prevent the ingress of rain;

- provision will be made logistically with the authorities and a local contractor to remove general refuse from the site on a daily basis to minimize odour, the attraction of pests, and litter impact;

- avoid dumping hazardous waste in a general landfill; and

· When servicing machinery, ensure waste oils, grease, and filters are placed in sealed containers and then preferably taken to recycling facilities or designated repositories.


Clearing land for project infrastructure

Direct loss of habitat and disturbance





· CESMP

· BAP

· BMP

· CDP

· HMMP

· HRWMP

· LALRP

· LCP

· SECP

· TMP

· WCMP

· WAMP

· WMP





· Restore soils and native plant community (or comparable crops where applicable) in areas subject to temporary impact;


· Develop and implement a BMP, which will be made up of the flora and fauna management and monitoring fauna management as per Chapter 10. Preliminary ESMF. The BMP will include an assignment of relative biodiversity quality to the remote sensing and a refinement of the characterization of the balance between natural and modified habitats for the purpose of defining biodiversity restoration and offset needs. If additional field data cannot be collected, an assumption regarding the average level of degradation will need to be adopted to account for the uncertainty associated with the natural category;

· Prior to commencement of the construction activities, qualified ecologists are to further document areas within the construction corridor defined in Section 6.5. Ecology and Biodiversity Baseline as natural habitat. The purpose is to support the development of restoration, compensation, and offsetting approaches and ground truth the classification done using remote sensing and transects, confirming: 1) if the areas are natural habitat or should be revised to modified habitat where evidence can be provided of extensive degradation; and 2) if areas classified as potential critical habitat are critical habitat or natural habitat or remain potential critical habitat with supporting evidence. The pre-construction survey should include the following:

- identification of plant species, ecosystem, and / or IBA, and assess according to the presence of biodiversity features and / or ecosystem



processes that are representative of the ecoregion and / or IBA and measure as:

o highly representative (3 points);

o moderately representative (2 points);

o poorly representative/not representative (1 point);

(Biological Q-rating for each survey location is assigned based on the sum of the evaluation points across these three criteria, as high [9 points], medium-high [8 points], medium [3-7 points], low-medium [2 points], or low [1 point])







· Offsets for permanent impacts to natural habitat estimated as 87.3 ha. Compensation for permanent impacts of 69.8 ha modified habitat will be addressed through the Land Acquisition Plan and Livelihood Restoration Plan;

· For the loss of natural habitat (this includes potential critical habitat and modified habitat with



significant biodiversity values), mitigation must be provided that is equivalent in value. For critical habitat, mitigation must be provided that is greater in value. Tree planting requirements under the Pak-EPA’s environmental approvals must incorporate GIIP for offsetting (IFC, 2015). Two types of offset are acceptable, namely, averted loss and restoration;








· For the design of in-place habitat restoration and biodiversity offsets, consider the habitat preferences of the species for which potential critical habitat and potential critical habitat has been identified (Table 7.5-9), and any additional CR, EN, or endemic species identified during the ongoing construction surveys;

· Select viable opportunities to create greater long-term ecological value than currently exists to help offset permanent losses. For example, converting temporarily impacted, poor quality habitat within the ROW to a higher quality level or converting developed or agricultural area into native habitat could create greater value;




· Project Net Positive Biodiversity Benefit will be included as potential objective as a topic to be investigated in the Community Development Framework, Local Content Plan, and Human Resources and Workers Management Plan. This would likely include increasing biodiversity along the restored section of the ROW and targeted offsetting in areas of critical habitat.

Clearing of land for CSs Direct Loss or Displacement of Fauna Species





· In areas where the density of animals may be high, construct trench plugs every several hundred m

· CESMP

· BAP

· CDP

· BMP

· HMMP

· HRWMP

· LALRP

· LCP

· SECP

· TMP

· WCMP

· WMP





(that is, ramped earth which enables entrapped animals to escape); and

· Adhere to the Traffic Management Plan and Water Management Plan developed for the Project.

Dust, light, and noise associated with construction activities

Indirect Impacts to Fauna and Flora




· CESMP

· BAP

· BMP

· AQMP

· NVMP


Dust, light, and noise associated with construction activities

Impact to Critical habitat · The mitigation measure listed throughout Section 7.5.2 of the ESIA should be undertaken. Based on the information gathered to date, a Project Net Positive Biodiversity Benefit in relation to the habitat for Desert Wolf will be required. For the Balochistan Forest Dormouse, based on pre-construction survey results and habitat classification review, natural habitat restoration will either be equal to greater than the area impacted and incorporated into the BMP objective of Project Net Positive Biodiversity Benefit.

· CESMP

· BAP

· BMP

· AQMP

· NVMP



Land Acquisition and Physical Displacement/Resettlement


· The mitigation measures proposed, if there is physical displacement, are the same as those identified for Construction Phase 1.

· CESMP

· LARP / LALRP

· CDP

· GMP

· HRMP

· NPSMMP

· TPMP

· LCP




· SEP

Economic Displacement and Livelihood

Economic Displacement · The mitigation measures proposed for economic displacement, are the same as those defined for Construction Phase 1.

· CESMP

· CDP

· GMP

· HRMP

· LALRP

· LCP

· NPSMMP

· SEP

· TPMP



Impact to Persons Reliant on Ecosystem Services, Specifically Land-based Resources

· The mitigation measures proposed for persons reliant on ecosystem services, specifically land-based resources are the same as those defined for Construction Phase 1.

· CESMP

· LARP / LALRP

· CDP

· GMP

· HRMP

· NPSMMP

· TPMP

· LCP

· SEP



Impact on Persons Reliant on Ecosystem Services, Specifically Water Supplies for Local Communities

· Pre-construction planning shall identify water sources for human consumption and Project use, along with conducting an evaluation of the impacts of groundwater draws by the Project to private and community wells and boreholes. If analyses indicate that reduction in water levels will occur, TPCL must purchase water and transport to the site for use.

· Measures must be taken to prevent damage to irrigation systems which could result in orphaned farmland. Irrigation systems such as karezes are to

· CESMP

· BAP

· BMP

· CDP

· LALRP

· SEP

· WMP




be reinstated or diverted as necessary to prevent degradation of farmland.

· Should river water be abstracted, the mitigation measures for Construction Phase 1 should be followed.

Construction Activities Impact to Permanent (Non-nomadic) Populations due to Construction Noise

· During construction, TPCL must ensure that temporary noise barriers or enclosures are used to reduce noise impacts. Staff are to be instructed in using equipment to minimize noise potential; rubber stops can also be used.

· Proactive outreach with potentially affected settlements is essential to reducing the disruption to local settlements. It is recommended that clear and early communication with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken.


· CESMP

· NVMP

· SEP


Services and Infrastructure Requirements

Impact Associated with Increased Demand for Services and Infrastructure

· Prior consultation must be undertaken with any potentially impacted communities to discuss upcoming works in order to reduce potential conflict;

· TPCL will ensure that any abstractions of water including groundwater for Project use will not impact this resource availability to nearby communities. All abstractions must be permitted by the appropriate agencies;

· TPCL will ensure that the contractor provides for additional medical staff onsite trained in providing emergency services during peak construction periods to provide critical support in the field, avoiding overwhelming local healthcare resources;

· CHSP

· CDP

· IMP

· LCP

· SEP

· TMP




· As part of a community investment program and to provide for local institutional capacity building, TPCL should consider providing emergency medicine training to local medical staff who work at facilities within the PAI and donations of equipment and supplies to these institutions;

· The Grievance Mechanism will be monitored to understand if complaints are made in relation to local access to services and infrastructure with any issues dealt with as a matter of urgency; and

· The Project will monitor non-Project related influx into the area to understand if this has the potential to impact upon local services and infrastructure. In the even that this occurs, the Project will work with local authorities to manage this process and minimize impacts where possible.

Construction Activities and Workforce

Impact Associated with Increased Risk of H&S Incidents and Communicable Diseases

· The mitigation measures are the same as those identified for Construction Phase1.

· CHSP

· NVMP

· OHSP

· SEP

· SCMP

· TMP

· WMP

· WAMP


Security Impact on Facilities, Workers, and Neighbouring Community Members due to Inter-ethnic and Sectarian Tension / Conflict


· TPMP

· CHSMP

· GMP

· HRMP

· HRWMP

· LCP

· SCMP

· SEP





· The enhancement measures are the same as those identified for Construction Phase1.

· CESMP

· CCMP

· GMP

· HRWMP

· HRMP

· IMP

· LCP

· OHSP


Effects of a large-scale infrastructure construction project

Impact on Vulnerable Groups including Women, People with Disabilities, and Human Rights Issues


· CESMP

· CCMP

· GMP

· HRMP

· HRWMP

· LALRP

· LCP

· OHSP

· SEP



Construction activities Impact of Pre-construction Activities on Archaeology and Cultural Heritage.

· As stated in Section 7.7.2.2 of the ESIA, mitigation measures will largely be required in order to deal with any as-yet unidentified archaeological sites exposed during construction of the CSs. The results of the baseline survey (NAFTEC/MAB’s subcontractor, 2018) should be considered for the pre-construction planning and management process, followed by good management and a Project-specific CFP.

· The implementation of the CFP is a crucial mitigation measure and considered good management practice for potential impacts of the Project on known and unknown cultural heritage resources.

· CESMP

· CFP

· CHMP

· WCMP

· WMP

· SEP




Climate Change

Impact from Greenhouse Gas Emissions

Climate change mitigation measures to be included in a Project-specific CCMP shall include, but are not limited to, the following:


· Detailed design is to include the development of a Climate Change Risk Design Review Procedure for Operations, specifying the engineering design review to be undertaken every five years of operational life to check that the Project design is operating with design parameters following update of the climate risk assessment (refer operation phase mitigation measures outlined in Section 7.9.5.4);


· Assessing the use of alternative fuels (such as CNG, LNG, LPG, and biodiesel) versus diesel and petrol;


· Where possible, through technology advances, reduce the production of GHG emissions as a result of construction, through the use of materials and methods with lower carbon footprint.

· In addition, environmental mitigation measures included in other Project-specific management plans that also address climate change impacts include:

· Encourage the regrowth and revegetation of the AGI areas that are unused, with measures such as seeding with local grass species, re-spreading topsoil and cleared vegetation to encourage growth from the natural seedbank, and replanting in high

· CESMP

· BMP

· BAP

· CCMP

· SEP

· TMP




risk areas where stability needs to be rapidly achieved;




· Progressively rehabilitating land cleared for construction, especially exposed soils and maximizing the amount of land re-vegetated;

· Minimize the volume of natural gas released during via venting; and

· Considering good quality biodiversity offsets for land cleared.


Landscape and Visual Amenity

Construction Activities e.g., vehicle movements, active construction camps, site clearance, excavations, soil storage, active machinery and erection of Compressor Stations.

Impact of Pre-Construction Activities on the Landscape of Sulaiman Mountains

· High standards of construction site practice and good housekeeping should include the tidy storage of materials and unused machinery in laydown areas, and the appropriate handling of waste, to limit degradation in views towards the works;

· Construction camps should be organized to keep elements that would cause an impact over long distance (such as scattered materials and machinery, and reflections off vehicles) within compounds and screened from the outside. Topsoil heaps could be used as effective ground-level screens to this end;

· Appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen

· CESMP

· BAP

· BMP

· LCP

· LVIMP

· SECP

· SEP




bulbs like halogen). While glare will notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;



· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of modern materials (through reduction), and to screen ground level views of industrial elements.






· Reinstatement should also occur for any laydown areas, construction camps, and pipe yards that are no longer in use;

· In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state;

· Planting should be considered at CSs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the CSs within the fence line, if security permits;


· All temporary tracks, construction camps, and working areas shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope to avoid un-naturalistic scars being left across an open landscape whose character is often driven by large scale uniformity in colour and texture;

· Existing topsoil shall be returned, as close as possible, to its source and stored appropriately during construction (in stacks of 1.5 m high or less); and

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s ESAP for discussion with Pakistan authorities) to define erosion control mitigation measures. These management plans, when



combined with the reinstatement measures developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized.

· Dust control measures as detailed in the ESIA Section 7.2. Ambient Air Quality Impact Assessment should be implemented to reduce the visual prominence of the works across long views. Noise control through the use of best practice machinery and working methods, as described in the ESIA Section 7.3. Noise and Vibration Impact Assessment, should be implemented to minimize the impact of works on the local landscape.



Table 4-9 - Phase 2 Operational Phase Impacts and Mitigation Measures





Timeline

Ambient Air Quality

Process units and equipment during normal operation of the Compressor Stations.

Increased levels of NO2 · The FEED emission studies (TPCL, 2017a, 2017b, 2017c) have reported NOx emissions of 320 mg/Nm3 for a fired heater and 200 mg/Nm3 for a power generation unit. It is therefore proposed to remove the fired heaters from the design to reduce the NOx emissions significantly. However, it must be noted that this is representative of a worst-case maximum capacity emission scenario defined at a preliminary design stage, and actual emissions from Project units are likely to be lower.

· Detailed engineering design should perform a BAT analysis to selected what are best technologies that could be included in the design of the AGIs, to minimize NOx emission from power generation units.

· AQMP

· CCMP

· TMP

· SEP


Noise and Vibration

Process units and equipment during normal operation of the Compressor Stations.

Noise associated with operation of the Compressor Stations.

· The same mitigation measures listed for the operational impacts during Phase I are applicable to Phase II.

OESMP

HEMP

HMMP

NVMP

SEP

SPRP

WMP



Use of equipment during operations

Impact on soil, groundwater and surface water due to accidental spills/leakages

· Mitigation measures as detailed for Phase 1 operations apply.

· OESMP

· BAP

· BMP

· SEP








Timeline

· TMP

· WAMP


Operational noise/light/activity

Disturbance to ecological receptors




· Implement noise mitigation measures to keep consistent noise levels to less than 45 dBA within a short distance into native habitat; and

· Include measures in the training and code of conduct of the operations and security teams to ensure that hunting of game does not take place. This must be monitored regularly by site managers with strict regulation of any observed hunting activities.

· OESMP

· BAP

· BMP

· NVMP

· TMP

· WCMP

· SEP

· SPRP



Employment Requirements

Impact Associated with Employment and Economic Development

· The AGIs and other facilities, require specific skills which precludes primarily hiring locally. To enhance local opportunities, TPCL should implement a long-term training program to increase the level of local employment during the first 2 years of operation.

· OESMP

· CHSP

· CDP

· GMP

· HRMP

· HRWMP

Prior to operation







Timeline

· LCMP

· SEP

Worker Health and Safety

Impact Associated with Increased Risk of H&S Incidents due to Accidental Leaks and Ruptures

· While unlikely, the eventuality of a H&S incident related to the CSs should be addressed in the previously recommended Community Emergency Response Plan

· OESMP

· CESMP

· CHSMP

· EMRP

· GMP

· HRMP

· OHSP

· SPRP

· SEP

· TMP

Prior to operation

Security Impact Associated with Attacks on Associated Facilities

· An important mitigation measure is to engage in relationship building with key stakeholders in proximity of the AGIs, providing community investment to affected communities. This will increase the sense of ownership and, combined with the pledged protection, will provide for AGI support.

· OESMP

· CHSMP

· EMRP

· GMP

· HRMP

· OHSP

· SPRP

· SEP

· TMP

Prior to and throughout Operations


Operation activities on archaeology and cultural heritage

Impacts related to venting and leakages, emissions, climate change, groundwater impacts etc.

· The implementation of a CFP as a mitigation measure and good management practice for potential impacts of the Project on known and unknown cultural heritage resources should continue to be followed into the commissioning/start-up phase.

· Tangible assets that have been avoided during the construction phase will not likely be impacted by commissioning/start-up activities, as planning for direct

· OESMP

· CHMP

· SCMP

· CFP

· SEP

When necessary







Timeline

and indirect avoidance of such resources will be implemented during previous Project phases.

· Assets with the potential to be impacted during operation activities should be protected and clearly demarcated for continued Project avoidance and protection from vandalism or looting, and natural gas venting locations should take into consideration the location of heritage resources as to be downwind from resources. Also, avoidance and care should be taken to avoid accidental spillages and over-extraction of water resources in the area, to avoid differential ground settlement, as detailed in Section 7.4. Physical Environment Impact Assessment.

Climate Change

Compressor Performance

Climate Change Impacts on Cooling Compressor Performance



· Regular corrosion and leak detection monitoring;

· Conduct regular energy audits for the CSs to ensure compressor turbine operates at peak efficiency;

· Reduce leakage in reciprocating compressor rod packing, replacing packing when expected reduction in leaks will pay back costs; and



· Every five years update the climate risk assessment provided in the ESIA Section 6.9. Climate Change Baseline based on the most recent IPPC data;

· OESMP

· CCMP

· TMP

· SEP








Timeline

· Following update of the climate risk assessment, undertake a Climate Risk Assessment Design Review based on the procedure develop with the detailed design. The review should include but not be limited to the following:

- on soil stability;

- re-evaluate the design considering the potential influence of climate change related changes to groundwater conditions on buoyancy;




Permanent Compressor Stations

Impact due to Operation of Phase II AGIs on the Landscape of the Sulaiman Mountains


· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of exposed machinery and modern materials (through reduction), and to screen ground-level views of industrial elements;

· Lighting at AGIs shall only be used when required and shall be designed to minimize light pollution from direct shine and diffuse glare (including the use of LED rather than the highest lumen bulbs like halogen), limiting the

· OESMP

· BAP

· BMP

· NVMP

· LVIMP

· SECP

· WAMP

· SEP

From construction and throughout operation







Timeline

facility’s visual prominence over long views during both the day and night;

· Lighting at AGIs shall take into account that the security requirement for lighting take precedent over landscape and visual impact mitigation; and

· Planting should be considered at CSs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the CSs within the fence line, if security permits.



Table 4-10 – Phase 2 Decommissioning Phase




Plan Implementation

Timeline

Noise and Vibration

Plant and equipment required to decommission the Compressor Stations.

Noise associated with Compressor Stations decommissioning activities.

· The contractors undertaking the activities are required to follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at minimum as practicable. Mitigation measures set out for the Construction Phase would be also applicable during decommissioning.

· DESMP

· NVMP

· TMP

· SEP



Compressor Station dismantling Impact on Soil Characteristics,

Subsurface Structures, Stability and Productivity

· The mitigation measures will be similar to those in construction and commissioning/start-up phases.

· DESMP

· BAP

· BMP

· SECP

· WMP



Removal of Compressor Stations

Impact from Direct land disturbance and other stressors




· Restore soil and the native plant community in CS footprints;

· DESMP

· BAP

· BMP

· SEP

· SPRP







Plan Implementation

Timeline



· Implement the noise mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment.



Impact on Permanent Populations due to Decommissioning Noise

· Contractors shall implement GIIP measures to maintain the noise levels at fence line and maintain noise emissions at as a minimum level as practicable.

· DESMP

· NMP

· SEP




Erosion of tradition and cultural values, severe restriction in access of cultural/historical sites. Dust emissions and accumulation on cultural heritage sites, monuments, structures and other features.


· Protective avoidance barriers that have been placed around tangible assets during the previous Project phases may require repair or replacement

· DESMP

· CFP

· SEP







Plan Implementation

Timeline


Decommissioning Activities - vehicle movements, active construction camps, site clearance, excavations, soil storage, active machinery and demolishing of the Compressor Stations

Impact of Decommissioning Activities on the Landscape of the Sulaiman Mountains



· Appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen), taking into account that the security requirements for lighting take precedent over landscape and visual impact mitigation;


· All temporary tracks, construction camps, and working areas shall be reinstated back to

· DESMP

· BAP

· BMP

· CCMP

· NVMP

· LVIMP

· SECP

· WAMP







Plan Implementation

Timeline

alluvial topsoil, agricultural land, or rocky slope to avoid un-naturalistic scars being left across an open landscape whose character is often driven by large-scale uniformity in colour and texture;

· Existing topsoil shall be returned, as close as possible, to its source and stored appropriately during decommissioning (in stacks of 1.5 m high or less);

· Reseeding should be implemented following return of topsoil across where needed, with native plant communities allowed to revegetate naturally at reinstated ground, rather than being planted, to avoid noticeable changes in the vegetation make-up across the landscape and to avoid likely long-term failures in planting;









Plan Implementation

Timeline


· In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state; and

· Assessment should be implemented to reduce the visual prominence of the works across long views.

· In addition, noise control through the use of best practice machinery and working methods, as described in the ESIA Section 7.3. Noise and Vibration Impact Assessment, should be implemented to minimize the impact of works on the local landscape. and Audits will be conducted to verify the continued implementation of the LVIMP, to ensure mitigation measures are being carried out as required.



Table 4-11 - Phase 2 Non-routine Events / Emergencies (applicable to all Phases)





Timeline

Ambient Air Quality

The emergency release of natural gas through venting and the use of the emergency generator sets.

Increased levels of NO2, SO2 and PM10 and PM2.5 associated with emissions from the Compressor Stations under emergency conditions.


· AQMP

· EMPR

· ERSP




5 ENVIRONMENTAL AND SOCIAL MONITORING PLAN

The TAPI Environmental Monitoring Framework outlines the responsibilities of TPCL

and the Contractor to monitor the environmental and social mitigation measures of

the Project and to ensure it is constructed and operated in a manner that is compliant

with local government regulations and ESIA commitments.

5.1 Monitoring Plan Objectives

The objectives of the Environmental Monitoring Framework are to:

· ensure Project components are conducted in compliance with the local

government and approval conditions of the ESIA;

· measure the success of proposed mitigation measures in minimizing and/or

reducing potential environmental and socio-economic impacts, even if of low

significance;

· continuously monitor changes to baseline environmental and social conditions

during construction and operation activities;

· facilitate a continual review of post-construction and operation activities based

on performance data and consultation feedback; and

· implement corrective actions or new adaptive management programs, as

required, if proposed mitigation measures are unable to reduce and/or

eliminate potential Project related impacts or meet the predetermined level of

performance.

The monitoring framework is intended to provide guidance on the content of the

environmental monitoring procedures during construction and operation activities.

Monitoring shall start as soon as the project is given the go-ahead and shall be

implemented throughout all project phases and managed by TPCL.

Monitoring will aim to implement systematic observations to periodically measure the

result of proposed mitigation measures; and continue data collection in order to

compare baseline environmental conditions with conditions during construction.

Checklists shall be developed to identify potential environmental and social issues

early. Proper courses of actions shall be proposed if any proposed mitigation

measures are unable to properly reduce and/or eliminate environmental and/or socio-

economic impacts. If necessary, TAPI will engage outside consultants to undertake

sampling. A database of all project related monitoring and supervision data will be

developed.



5.2 Draft Monitoring Plan

5.2.1 Pre-Construction and Construction Phase 1

Table 5-1 below lists the monitoring which will need to be undertaken during the site preparation (pre-construction) and construction for

Phase 1 of the Project.

Table 5-1 – Pre-Construction / Construction Phase 1


Mitigation Measure Actions/Monitoring Measures Responsible

Person Frequency of Action

General

Implementation of the Environmental and Social Management System (ESMS).

· TPCL will appoint a dedicated team in charge of supervising the ESMS and implementation of the ESMP. This will include a Project management team at the head office, along with in-country and local staff.

General

· ESMS is established prior to construction.

· Monitoring to ensure that all required plans/actions have been developed.

Engagement

· Monitoring of grievance trends and records of responses.

· TPCL · Daily, weekly and monthly reporting where necessary

Implementation of the Environmental and Social Management Plans (ESMPs).

· TPCL will establish an ESMS to monitor all E&S activities and implementation of the ESMP.

General

· Monitoring to ensure that all required management plans have been developed.

Engagement


· TPCL · Monthly audits on compliance with Plans



Ambient Air Quality


· Develop and implement the following plans: AQMP, BAP, BMP, CCMP, SEP and

TMP

· Regularly review and continue to implement the SEP

· Implement a grievance mechanism.

General

· Periodical audits to verify implementation of management plans.

NO2 and SO2 emissions

· Periodical checks of vehicles and machinery.

· Periodical audits to verify proper completion of maintenance register according to manufacturer’s instructions.

Engagement


· EPC Contractor/Site Construction Manager

· Monthly audits on compliance to management plans

· Monthly checks on vehicles

· Monthly audit on maintenance register

· Monthly monitoring of grievances.

Increased levels of PM10 and PM2.5 emissions associated with the generation of dust

· Develop and implement the following plans: AQMP, BAP, BMP, CCMP, SEP and

TMP

· The AQMP shall include procedures for

Installation of anemometers

Maximum speed limits for vehicles

Minimize dust generating activities

Use water as dust suppressant where feasible

Stockpiles located away from sensitive receptors

Bulk cement and other fine powder

General

· Periodical audits to verify implementation of management plans

PM10 and PM2.5

· Continuous monitoring of dust, through visual inspections.

· Daily monitoring of watering activities for dust suppression.

· Weekly audits to verify storage areas proper setting and management.

· Monthly audits to verify compliance to the traffic management plan.

Stakeholder Engagement

Monitoring of stakeholder engagement activities.

Grievance Management



· Community Liaison Officer

· Monthly audits on compliance to Management Plans

· Continuous monitoring of dust

· Daily watering activities performance

· Weekly audit on storage areas

· Monthly monitoring of stakeholder engagement and grievances.



materials to be delivered in enclosed tankers and stored in silos.

· Regularly review and continue to implement the Project SEP, in particular

Notification to local public through community liaison officer prior to dust or other air and noise generating activities start.

· Implement grievance mechanism.

Noise and Vibration


· Develop and implement the following management plans: NVMP, TMP, SEP, CHSMP

· Utilise the best available technology.

· Ensure machinery is properly maintained and used in accordance to equipment maintenance requirements.

· Regularly review and continue to implement the Project Stakeholder Engagement Plan, especially

General


· Noise Levels

· Periodical checks of vehicles and machinery.


· Periodical noise monitoring at receptors.

· Monthly checks on vehicles, maintenance register and during construction activities (monthly).

· Bi-monthly noise levels monitoring.


Monitoring of stakeholder engagement activities.



· Monthly checks on vehicles, maintenance register and during construction activities (monthly)

· Bi-monthly noise levels monitoring

· Monthly monitoring of stakeholder engagement and grievance management.



Provide clear and early communication to local residents to make them aware of the activities to be undertaken and to give advice based on the health and safety risks involved.

· Implement grievance mechanism.




· Impact on Soil Characteristics, Subsurface Structures, Stability and Productivity

· Impact on Drainage Characteristics and Natural Water Flow / Impact on Surface Water Resource Quality due to Trenching Outside Watercourse Areas

· Impact on Surface Water Resources Quality due to Frac-out during HDD

· Develop and implement the following management plans: EMRP, HMMP, FMP, HDD EMP, SECP, SPRP, WMP and WCMP.

· Minimise disruption to the construction ROW and revegetate immediately the ROW.

· Develop and implement a Reinstatement Plan by including specific procedures for:

Proper top soil handling, re-use of original soil

Implement Soil revegetation practices

· Plan disposal of cuttings and bentonite fluids

General


Erosion/Sedimentation

· Periodical inspections to verify the status of the erosion/sedimentation phenomena.

· Periodical monitoring and reporting of restoration and erosion control measures.

Sediment and Suspended Particles

· Turbidity / suspended solids to be measured one week before works start at or close to the river and during the works within the river nearby crossings.

· Periodical observations of sediment runoff on site.

Water Resources Monitoring

· Monthly monitoring of the following:

water volumes;

volumes of reused water;

water quality prior to discharge

· Check workers’ training registers in order to verify that proper training/induction to cover this issue has been performed.


· Monthly audits on compliance with Management Plans

· Periodical inspections on erosion /sedimentation phenomena during construction activities:

Monthly during standard operations

Continuously during dewatering activities

Daily for water abstraction.

· Periodical monitoring on reinstatement activities progress.

· Turbidity / suspended solids to be measured one



· Impact on Flood Risk

· Impact on Soil, Groundwater, and Surface Water due to Accidental Spills / Leakages

· Impact on Water Resource Use and Quality due to Dewatering

· Impact on Water Availability due to Consumption of Freshwater Resources

· Plan trenching at river crossing during the low-flow season

· Restore ROW and channel banks immediately after backfilling

· Develop a set of mitigation measures specific to the Indus River dolphin.

· Control of the groundwater table and water resources uses within communities.

· Enhance water reuse from dewatering.

· Minimize water consumption.

· Train workers at the beginning of works.

· Regularly review and continue to implement the Project Stakeholder Engagement Plan, especially

Negotiate water offtake with communities/authorities (as applicable)

Notify in advance the scheduled activities to secure any permits or approvals that may be necessary for activities such as

· Verify compliance with water abstraction permit requirements.

Indus River Dolphin

· Monitor measures specific to the Indus River dolphin include the use of pingers during drilling activities to encourage dolphins to avoid the area. Concurrently Marine Mammal Observation (MMO) during the works, restricting the speed and movement of any project-associated watercraft. These measures should be included in the HDD EMP, together with timeframes for HDD and reporting / communication protocols between MMO and HDD crew;

· Strict control measures will be put in place for any spills or ballast discharge from vessels required for the bridge construction.


· Monitoring of stakeholder engagement activities.



week before works start.

· Daily checks /observations of sediment run-off on site.

· Monthly monitoring of water consumption and re-use.

· Monitoring water quality prior to discharge.

· Monthly training checks.




water withdrawal, disposal or transport between watersheds.

Agree with competent authorities about disposal

Select water abstraction points in coordination with authorities and communities.

In the event the contractor must undertake works at night, this will need to be approved by the relevant authority in the area in advance.

· Implement the grievance mechanism.




· Direct Loss of Habitat and Degradation

· Direct Loss of Fauna Species

· Impact to Rivers from River Crossings

· Indirect Impacts to Flora and Fauna

· Impact to Critical Habitat

· Develop and implement the following management plans: BAP, BMP, CDP, HRWMP, LALRP, LCP, SECP, WCMP and WMP.

· Undertake additional ecological surveys prior to Construction.

· Train workers.

· Minimise habitat impacts beyond ROW.

· Restore soils and the native plant community.

· Determine Project risks against construction schedule (e.g., breeding timing).

· Compensate for impacts to natural and critical habitat providing offsets.

· Regularly review and continue to implement the Project SEP.


· Develop a set of mitigation measures specific to the Indus River dolphin i.e., include monitoring of an exclusion zone, soft start, use of pingers, and

General

· Undertake periodical audits to verify

compliance with management plans.


· Monitoring of stakeholder engagement activities.








restricting the speed of any Project-associated watercraft).

Transboundary Impact - Loss of Habitat for Migratory Species

· Develop the following management plans: BMP, BAP and SECP.

· Regularly review and continue to implement the Project Stakeholder Engagement Plan and grievance mechanism.

General

· Undertake periodical audits to verify compliance with management plans.

Engagement

· Monitor grievance trends and records of responses.


Physical Displacement and resettlement of households

· Develop and implement a SEP and grievance mechanism focusing on land acquisition and livelihood restoration

· Develop and implement a LARP (should there be any physical displacement) and a CDP

· Develop and implement a LALRP (should there be only economic displacement) and a CDP

· Regularly review implementation of the Project Stakeholder Engagement Plan

· Implement the grievance mechanism

· Provide training and livelihood restoration to Project Affected People

General

· Periodical audits to verify implementation of management plans (LARP / LALRP, SEP and Community Development).

Engagement

· Fair and informed consultation and participation of key stakeholders and Affected Persons during the resettlement planning and implementation phases

· Periodical surveys of areas of displacement, return or settlement, in total or in random sample.

· Periodical informal or semi structured interviews campaigns with individuals displaced in random sample and record of feedbacks.

· Regular meetings among humanitarian agencies and with local actors and records of feedbacks.


Investments

Project Proponent

Community Liaison Officer

· Monthly Audits on compliance to Management Plans

· Prior and throughout construction and following construction as applicable - Monthly audits

· Monthly monitoring of stakeholder engagement and grievance management

· Economic Displacement and Impacts to Livelihoods

· Impact to Persons Reliant on Ecosystem Services, Specifically Land-based Resources

· Impact on Persons Reliant on Ecosystem Services, Specifically Water Supplies for Local Communities



· Provide compensation to Project Affected People

· Records of community assistance activities/meetings/events.

· Records of funds disbursed.

· Status and performance of community investment projects already implemented.

· Record of signed compensation agreements

· Record of agreements on livelihood restoration packages

Training

· Training, skills development provided including the number of sessions held and number of people trained.

· The number of awareness raising materials distributed to target stakeholders.

Engagement


Impact on Tribal People

· Develop and implement the following management plans: TPMP, NPSMMP, HRMP, SEP and CDP.

· Community consultation on the CDP and disclosure and engagement of IP

· Investigate investments for minimizing impacts.

· Regularly review and continue to implement the Project Stakeholder Engagement Plan and grievance mechanism.

General

· Periodical Audits to verify implementation of management plans

· Engagement


· Periodical informal or semi structured interviews campaigns with TPs in random sample and record of feedbacks.


Investments

Monthly Monitoring of the following:

· The number and value of projects supported for TP assistance.



· TP attitudes to community development initiatives.

Impacts Related to

Employment - increase in direct jobs.

· Implement Human Resources / Workers Management Plan (HRWMP), LCP, HRMP, GMP and SEP.

· Development the Human Resources / Workers Management Plan by including:

Design and develop a capacity building and apprenticeship program

Strategy to maximize employment and skills opportunities for local people.

Implement Human Resources Policy and Worker grievance mechanism

· Regularly review and continue to implement the Project Stakeholder Engagement Plan.


General


· Engagement

· Monitoring of grievance trends and records of responses;

· Periodical informal or semi structured interviews campaigns with employees in random sample and record of feedbacks.

Employment

Monthly monitoring of the following:

· Recruitment conducted;

· Recruitment and employment targets;

· Training conducted/given to staff and planned;

· Job descriptions and selection criteria;

· Information dissemination regarding employment, including vacancy announcements;

· Equities and inequities in recruitment process (e.g., gender, ethnicity, age);

· Cases of corruption and disciplinary actions taken; and

· Records of employees hired.

Working Conditions

· Records of hours worked;

· Records of wages paid (and against project pay structures as a cross reference);

· Records of National Service demobilisation certificates;

· Records of grievances and of disciplinary actions taken;

Project Proponent and EPC contractor






· Condition of workers on site and worker camp areas;

Training

· Training, skills development provided including the number of sessions held and number of people trained;


Impacts Related to Access, Services and Infrastructure

Impact on Public Services

· Develop and implement the following management plans: Community Health and Safety Plan (CHSP), Occupational Health and Safety Plan (OHSP), Influx Management Plan (IMP), Traffic Management Plan (TMP)

· Identify services affected and potential interruptions in collaboration with local authorities and utility companies;

· Development a training management plan for all staff and contractors;

· Implement appropriate incident response procedures

· Assess local viability of services and provide compensation/ alternatives

· Regularly review and continue to implement

General


· Engagement


Utility Services

Monthly monitoring of the following:

· Monitor total number of hours of utility service interruptions (sewage, electricity, water supply and irrigation); and

· Monitor traffic loads and traffic incidents;

· Periodical audits to verify performance of incident response procedures.





the Project Stakeholder Engagement Plan.

· Implement the grievance mechanism

Impacts Related to Community and Workforce Health and Safety

· Development and implement a Community Health and Safety Plan (CHSP), OHSP and a Security Management Plan with the following main scope:

Public access to the site;

Employee conduct and awareness (in the community);

Health and safety hazards that may arise off-site, e.g., dust deposition, traffic accidents;

Community health and wellbeing, including raising awareness about health issues and maintaining healthy lifestyles;

Health support services for the local population;

Security measures and the use of force.

· First Aid and safety training to workers

General


Community and Occupational Health and Safety


· Reporting on workforce conduct within the community;

· Any instances of workforce non-compliance with Project rules and regulations;

· Checks condition of access roads and dust suppression activities;

· Security arrangements;

· Employee personal health programme;

· Implementation of the substance and alcohol abuse policy;

· Periodical audits on trainings performed and health screening;

· Periodical audits of medical equipment on site and facilities, conditions and availability as identified in the H&S plan

· Communicable disease checks

Engagement


· Prior and throughout construction audits to verify implementation of management plans

· Monthly audit of medical equipment on site

· Health screening for all workers every 6 months




· Set Agreements with local hospitals

· Implement worker health screening

· Training on communicable diseases.


· Grievance Mechanism Implementation

Gender Impacts, Community conflict and security risks for women.

· Develop and implement a Gender Management Plan (GMP), CHSP and SEP

· Community consultation on the management plans and disclosure



· Provide opportunities for women and women’s groups to participate in the workforce

· Short-term and long-term vocational and education training programs for women and youth

· Sexual harassment Policy adoption

General


Employment

· Audit the recruitment policy to ensure that it is not gender biased and to ensure no gender discrimination during recruitment process

· Interviewers will be sensitized so as to prevent discriminating on the basis of gender (e.g., due to gender bias or stereotypes)

· Anti-TIP plan within the Contractor management system document to ensure:

equal salaries

working hours

vacations

contract conditions

· Contractor shall not tolerate harassment on the part of its employees, sub-consultants, or sub-consultant employees.

· The contractor shall give priority of the employment to eligible unskilled and semi-skilled local people, including women,

Project Proponent/EPC contractor


General


Employment

· Monthly inspections and monthly report from Contractor to TPCL

Training

· Monthly inspections and monthly report

Working Conditions


Awareness

· Monthly inspections and monthly reports

Engagement

· Monthly monitoring of stakeholder engagement and



vulnerable groups and those who are affected by the project, when they possess necessary qualifications and ability.

· Promote full understanding of available positions amongst women in order to overcome preconceived ideas about positions that could be filled by them.

· A sentence stating that women are encouraged to apply will be added to any job advertising

· Encourage local employment.

· Ensure no gender discrimination during recruitment process.

· Interviewers will be sensitized to prevent discriminating on the basis of gender

Training

· Periodical Audits to verify performance of vocational training and job opportunities

· Share results of monitoring and training program to ensure awareness

Working Conditions

· The contractor shall provide employees with appropriate benefit package such as health insurance and social security, according to relevant laws and regulations

· Audit a sample of employees (males, females) and their contract and relevant documents

· The contractor shall not employ any child who is under 18 years of age

· Contractors shall avoid the abuse of migrant workers such practices as:

unlawful withholding of passports

restrictions on movement

delayed or non-payment of wages

grievance management.

Land Acquisition/ Resettlement

· Verification during the stakeholder engagement activity and monthly report



verbal and physical abuse.

· Contractors shall employ all his foreign and domestic workers on the basis of a standard workday of maximum 8 hours duration, with paid leave, entitlement to family contact and freedom of religion

· Maintaining efficient inspection of TIP occurrence and cases, including recording and reporting procedures to document and report the occurrence of such cases to the legally responsible governmental authority for action

· Contractors shall provide all employees with a signed copy of their employment contract, in English as well as the employee’s native language, that defines the terms of their employment / compensation

Awareness

· Awareness campaign targeting behaviour change and trust in improved water quality targeting women-headed households and other disadvantaged groups.

· Awareness campaigns to promote the new women employment opportunities such as water plumbing, this may include inviting women trained on water plumbing to disuses their experience, opportunities and challenges.

· Awareness campaigns to promote the new women employment opportunities targeting the community leaders and religious groups that may influence or facilitate these new employment opportunities.

· Provide awareness raising and sensitization to all workers to prevent harassment (physical, psychological and sexual) between



employees, or directed at community members (particularly women and children)

Engagement


Land Acquisition / Resettlement

· Compensation must be equal regardless of status of vulnerability in the community.

Impacts Associated with Vulnerable Groups (excluding Tribal people) and Human Rights

· Develop and implement a GMP, HRMP, SCMP, SEP, LALRP, CHSP



· Livelihood restoration support for vulnerable parties

General


Employment

· Audit the recruitment policy to insure no vulnerable people discrimination during recruitment process.

· Interviewers will be sensitized so as to prevent discriminating vulnerable people (e.g., due to gender bias or stereotypes).


equal salaries

working hours

vacations

contract conditions


· The contractor shall give priority of the employment to eligible unskilled and semi-skilled local people, including women, vulnerable groups and those who are affected by the project, when they possess necessary qualifications and ability.

· Encourage local employment

Project Proponent


General


Employment


Training

· Periodical audits and monthly report

Working Conditions


Engagement


Resettlement / Land Acquisition



· Ensure no vulnerable people discrimination during recruitment process

· Interviewers will be sensitized to prevent discriminating on the basis of vulnerable status in the community.

Training

· Periodical audits to verify performance of vocational training and job opportunities

· Share results of monitoring and training program to ensure awareness.

Working Conditions

· The contractor shall provide employees with appropriate benefit package such as health insurance and social security, according to relevant laws and regulations.

· Audit a sample of employees (males, females) and their contract and relevant documents.

· The contractor shall not employ any child who is under 18 years of age.






· Contractors shall employ all his foreign and domestic workers on the basis of a standard workday of maximum 8 hours duration, with paid leave, entitlement to family contact and freedom of religion.

· Maintaining efficient inspection of TIP occurrence and cases, including recording and reporting procedures to document and report the occurrence of such cases to the

· Monthly monitoring and reporting



legally responsible governmental authority for action.

· Contractors shall provide all employees with a signed copy of their employment contract, in English as well as the employee’s native language, that defines the terms of their employment / compensation.

Awareness



· Awareness campaigns to promote the new women employment opportunities targeting the community leaders and religious groups that may influence or facilitate these new employment opportunities.

Training

· Provide awareness raising and sensitization to all workers to prevent harassment (physical, psychological and sexual) between employees, or directed at community members (particularly women and children)

Engagement


Resettlement / Land Acquisition

· Compensation must be equal regardless of sex of household head.



· Ensure that women (wives) are aware of the total compensation that husbands receive. The mechanism for ensuring this should be specified by the RAP Consultant, for example requiring the wife’s/wives’ signature on receipt.

Impacts on Tribal People due to Inter-Ethnic and Sectarian Tension/Conflict

· Develop and implement a TPMP, SEP, HRP, CDP, SCMP.

· Assess Project risks of inter-tribal conflicts.

· Provide equitable distribution of benefits

· Implement Community-based investments



General

· Periodical audits to verify implementation of management plans (Indigenous People Management Plan and SEP)

Engagement


· Periodical informal or semi structured interviews campaigns with TPs in random sample and record of feedbacks;

· Regular meetings among humanitarian agencies and with local actors and records of feedbacks

Investments


· The number and value of projects supported for TP assistance;

· IP attitudes to community development initiatives.

Training



· The number of awareness raising materials distributed to target IPs.

Project Proponent


General


ITPs

· Monthly reporting

Engagement


Investments


Training



Impact of Pre-construction

· Develop and implement of a Cultural Heritage

General EPC Contractor/Site

General



Activities on Archaeology and Cultural Heritage

Management Plan (CHMP), SEP and Chance Finds Procedure (CFP).

· ” Watching briefs” they participate in at specific areas/construction sites;

· Training staff to respond to Chance Finds.




Cultural Heritage Sites

· Supervision during construction


· Percentage of avoidance of cultural heritage resources;

· Percentage of Chance Finds recorded;

· Monitoring/ ” watching briefs” conducted at specific construction and other sites;

· Communication and cooperation with Local authorities;

· Information dissemination regarding cultural heritage;

· Cases of damage to, or disruption of, cultural heritage properties and actions taken.

Engagement


Construction Manager

· Monthly Audits on compliance to Mng Plans

Cultural Heritage

· Monthly monitoring of Cultural Heritage Performance Indicators

· Continuous supervision during construction

Engagement





Physical changes to the

landscape

· Develop and implement the following management plans: BAP, BMP, LCP, LVIMP, SECP and SEP

· Restoration, reduced working strip and stockpiled materials,

· minimisation of vegetation clearance to be detailed and implemented through the LVIMP



General


Landscape

· Supervision during construction of appropriate landscape impact minimization

Engagement

Monitoring of grievance trends and records of responses.

EPC Contractor/Site Construction Manager






5.2.2 Commissioning and Start-Up Phase 1

Table 5-2 below sets out the monitoring that will need to be undertaken during commission, start-up and operation for Phase 1 of the

Project.

Table 5-2 – Commissioning Start-up and Operation Phase 1


Mitigations Monitoring Measure Responsible

Person Frequency of

Action

Noise and Vibration

· Noise associated with pipeline commissioning and start-up activities.

· Develop and implement of a Noise and Vibration Management Plan (NVMP), HMMP, NVMP, SEP, SPRP and WMP.

· Ensure machinery is properly maintained and used in accordance to equipment maintenance requirements

· Utilise the best available technology

· Place the generators, which are one of the main noise sources from this activity, within acoustic enclosures and away from the sensitive locations, as much as practicable



· Do not exceed time required for hydrotesting

General

· Periodical Audits to verify implementation of management plans (Noise Management Plan and SEP).

Noise Levels

· Periodical noise monitoring at receptors

· Periodical maintenance of equipment

Engagement

· Monitoring of stakeholder engagement, grievance trends and records of responses.

EPC contractor · Monthly audits for compliance of Management Plans

· Weekly Noise levels monitoring



· Impact on Water Availability due to Hydrotesting

Develop and implement the following management plans: Water Management Plan (WMP), HMMP, LALRP, NVMP, SEP

SPRP, WAMP.

General

· Periodical Audits to verify implementation of management plans (Water

EPC contractor · Monthly audits for compliance of Management Plans



· Impact on Water Quality due to Hydrotesting

· Impact on Soil Quality due to Hydrotesting



· The water use during hydrotesting will be minimised and water will be reused where possible;

· The water required for hydrotesting shall be fresh and clean water which will be drawn from (and discharged to) water sources along the pipeline route (rivers, reservoirs, lakes).

· Minimize the usage of any additives which will affect water quality;

Management Plan and SEP).

Water Resources

· Record volumes of water abstracted and reused

Engagement

· Monitoring of grievance trends and records of responses

· The hydrotest water’s supply and disposal source should be approved by local authorities first.

· Daily Water consumption monitoring



Disturbance to ecological receptors due to operational noise/light/activity

· Develop and implement a Biodiversity Management Plan (BMP), BAP, NVMP,

TMP, SPRP.

· Minimize the time lights are on

· Determine project risks against breeding season




· Do not exceed time for hydrotesting

· Develop a set of mitigation measures specific to the Indus River dolphin. Examples could include monitoring an exclusion zone, soft start, use of pingers, and restricting the speed of any project-associated watercraft.

General

· Periodical Audits to verify implementation of management plans (Ecology Management Plan and SEP).

Engagement

· Monitoring of stakeholder engagement and grievance trends and records of responses.

EPC contractor · Monthly audits for compliance with Management Plans




5.2.3 Operational Phase 1

Table 5-3 below illustrates the type of monitoring which will need to be undertaken during routine operation for Phase 1 of the Project.

Table 5-3 – Operational Phase 1


Management Objective / Action Monitoring Measure Responsible


Ambient Air Quality

Increased levels of NO2, SO2 and PM10 and PM2.5missions

· Develop and implement a AQMP (to ensure Good Maintenance of the equipment) and a CCMP

· It is suggested to perform a best available technology (BAT) analysis. This will assist in investigating for any alternative technologies that could be included in the design of the AGIs, to reduce the NOx emissions from fired heaters and power generation units.


· Grievance Mechanism Implementation.

General



· Periodical checks of vehicles and machinery

· Ambient air quality monitoring at AGIs

· Periodical Audits to verify proper completion of maintenance register according to manufacturer’s instructions

Engagement


Project Proponent

EHS Manager



· Monthly audit on maintenance register.

· Every year Ambient Air Monitoring


Noise and Vibration

Noise associated with AGIs

· Develop and implement a NVMP and SEP.

· Noise control measures for the equipment

General

· Periodical audits to verify implementation of management plans (Noise Management Plan, Traffic Management Plan and SEP).

Noise Levels

Project Proponent

EHS Manager


· Monthly checks on vehicles and






· Fitting silencers, acoustic insulation and noise enclosures, where practicable




· Periodical audits to verify proper completion or maintenance register according to manufacturer’s instructions

· Periodical noise monitoring at receptors and AGIs

Engagement


maintenance register

· Annual noise levels monitoring (every three months during first year of operation)



Impacts on Karezes Systems / Irrigation Pattern

· Develop and implement the following management plans: CHMP, SEP, WCMP, WMP and SEP



General


· Erosion/Sedimentation

· Periodical inspections to verify the status of the Irrigation network

· Periodical monitoring and reporting of restoration measures

Engagement


Project Proponent

EHS Manager


· Every six months inspections on irrigation network and effectiveness of the reinstatement measures








Disturbance to ecological receptors for operational noise/light/activity

· Implement the following management plans: BAP, BMP, NVMP, TMP, SPRP and SEP.

· Regularly review and continue to implement the Project SEP.


· Minimise the time lights are on, particularly at night, during migration periods of birds, and within or near high biodiversity value features.

· Use low-pressure sodium lights and shielding to direct light to only where it is needed (i.e., eliminate spillage). Shielding can be provided by the fixtures or screening.

· Utilise designated roads only, at speeds within defined limits. This will confine the area of impact and minimize noise, dust and vehicle-induced animal mortality. The field survey team observed numerous reptiles, a group of organisms that are susceptible to being killed by vehicles.

· Implement noise mitigation measures to keep consistent noise levels to less than 45 dBA within a short distance into native habitat.

· Periodical audits to monitor compliance with Management Plans.

Engagement


Project Proponent

EHS Manager


· Annual biodiversity /ecology survey








Impact Associated with Abstraction of Hydrotesting Water on Communities

· Develop and implement the following management plans: BAP, BMP, HDD EMP, CHSP, SEP, WMP

General


Abstraction

· Abstraction from the Sutlej River, in particular, needs to be timed when flows exceed 5.0 m3/s, so that no more than 10% of the river flow is removed.

· Gauging of the rivers upstream of the point of abstraction should be undertaken to confirm that the abstraction is not adversely reducing the river flow and exceeding the agreed criteria.

· Abstraction from and discharges to all rivers should meet the requirements of the national and local agencies.


Engagement

· Proactive outreach with potentially affected settlements, particularly within 10 km, is essential to reducing the potential shock to human hearing. It is recommended that clear and early communication and consultation with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken.

· Monitoring of stakeholder engagement, grievance trends and records of responses.

Project Proponent

EHS Manager

· Monthly Audits to verify implementation of management plans







Noise generated by commissioning/start-up activities

· Develop and implement the following management plans: NVMP, HDD EMP and SEP.

General


Engagement

Monitoring of stakeholder engagement, grievance trends and records of responses.

Project Proponent

EHS Manager




· Develop and implement a CHSP, OHSP, SEP, LCP, GMP, HRMP and CDP with the following main scope:








· Set agreements with local hospitals


General

· Monthly audits to verify implementation of management plans (Community Health, Safety & Security Plan and Occupational Health and Safety Plans)

Safety and Health





Employee personal health programme;

Implementation of the substance and alcohol abuse policy;

Periodical audits on trainings performed and health screening;

Periodical audits of medical equipment on site and facilities conditions and availability as identified in the H&S plan.

Engagement

Project Proponent

EHS Manager

· Monthly Audits to verify implementation of management plans Safety and Health

· Monthly monitoring and reporting on health and safety and security requirements








· Relationship building with key stakeholders along the PAI, providing community development/investment to affected communities.




Impacts Related to Employment and Economic Development

· Develop and implement the following management plans: by including: HRWMP, LCMP and SEP covering


Develop a Workforce Development Strategy to maximize employment and skills opportunities for local people.

· Implement Human Resources Policy and Worker grievance mechanism

· Regularly review and continue to implement the Project Stakeholder Engagement Plan and grievance mechanism

General


Engagement



Employment

Every six months (on monthly basis during first year of operation) Monitoring of the following:






Project Proponent


Monthly Audits to verify implementation of management plans

Employment, Working Conditions and Training

· Monthly during first year of operation

· Every six months throughout the operation










Working Conditions






· Condition of workers on site and worker camp areas.

Training




Engagement





Impacts on tangible assets, impacts related to vandalism or looting, natural gas venting, accidental spillages, over-extraction of water etc.

· Development and implement the following management plans: CHMP, CFP and SEP.

· Continue to implement Chance Find Procedures

· Avoidance of cultural heritage resources

· Regularly review and continue to implement the Project Stakeholder Engagement Plan

General






· Communication and cooperation with Local Authorities;



Engagement


Project Proponent






Engagement

Monthly monitoring of stakeholder engagement and grievance management.


Impact due to presence of AGIs and permanent ROW

· Develop and implement the following management plans: BAP, BMP, LCO, LVIMP and SEP.

· Minimisation of vegetation clearance

· Reinstatement of applicable areas of ROW


General


Landscape

· Monitoring of the vegetation growth and development along ROW areas and AGIs

· Periodical Audits to verify performance of Landscape Management Plan.

Engagement


Project Proponent

General


Landscape



Engagement

Monthly monitoring of stakeholder



engagement and grievance management

Climate Change

· Climate Change Impacts on pipeline integrity, pipeline instability due to scour and channel migration, buoyancy and change in soils.

· Greenhouse Gas Emissions Contributing to Climate Change

· Develop and implement a Climate Change Management Plan (CCMP), TMP and SEP


General


Emissions, Leaks

· Regular corrosion and leak detection monitoring

· Regular patrols to check for leaks and undertake prompt repairs.

Engagement


Project Proponent

General


Emissions Leaks

· Weekly

· Weekly

Engagement

Monthly monitoring of stakeholder engagement and grievance management.



5.2.4 Construction Phase 2

Table 5-4 below lists the monitoring which will need to be undertaken during the construction for Phase 2 of the Project.

Table 5-4 –Construction Phase 2




General

Implementation of ESMS

· TPCL will install a dedicated team in charge of supervising the ESMS and implementation of the ESMP. This will include a management team at the head office, along with in-country and local staff.

General

· ESMS is established prior to construction and monitoring to ensure that all required actions have been developed.

Engagement


· TPCL · Daily, weekly and monthly reporting where necessary.


Implementation of Management Plans

· TPCL will establish an Environmental and Social Management System (ESMS) to monitor all E&S activities and implementation of the ESMP.

General

· Monitoring to ensure that all required management plans have been developed.

Engagement


· TPCL · Monthly audits on compliance to Management Plans


Ambient Air Quality


· Develop and implement the following management plans: AQMP, BAP, BMP, CCMP, TMP.

· Regularly review and continue to implement the

General












Project Stakeholder Engagement Plan.



Engagement




Increased levels of PM10 and PM2.5

emissions associated with the generation of dust

· Develop and implement the following management plans: AQMP, BAP, BMP, CCMP, TMP

· Development of an AQMP shall include procedures for

Installation of anemometers

Maximum speed limits for vehicles

Minimize dust generating activities

Use water as dust suppressant where feasible

Stockpiles located away from sensitive receptors.

Bulk cement and other fine powder materials to be delivered in enclosed tankers and stored in silos

General

· Periodical Audits to verify implementation of management plans (Air Quality Management Plan, Traffic Management Plan and SEP).

PM10 and PM2.5 emissions

· Continuous monitoring of dust, through visual inspections;

· Daily monitoring of watering activities for dust suppression;

· Weekly audits to verify storage areas proper setting and management;

· Monthly audits to verify compliance to the traffic plan

Engagement

· Pre-notification of critical dust producing activities and implement Community Liaison procedures





· Continuous monitoring of dust

· Daily watering activities performance

· Weekly audit on storage areas







Dust suppression techniques should be implemented, such as applying water


· Grievance Mechanism Implementation.

Noise and Vibration


· Develop and implement the following management plans: NVMP, TMP, SEP, CHSP, SCMP

· Utilise the best available technology

· Ensure machinery is properly maintained and used in accordance to equipment maintenance requirements.



General


Noise Levels

· Monthly checks of vehicles and machinery

· Periodical audits to verify proper completion or maintenance register according to manufacturer’s instructions

· at receptors


· Bi-Monthly Noise levels monitoring at receptors.

Engagement


· Monthly monitoring of grievances.




· Bi-Monthly Noise levels monitoring





· Impact on Soil Characteristics, Subsurface Structures, Stability and Productivity

· Impact on Soil, Groundwater, and Surface Water due to Accidental Spills / Leakages

· Impact on Water Resources Use and Quality

· Develop and implement the following management plans: SECP, WCMP, SPRP, HMMP, WMP, WAMP, HDD EMP, EMRP and SEP

· Implement a Reinstatement Management Plan by including specific procedures for:

Proper top soil handling, re-use of original soil

Implement Soil revegetation practices



General


· Engagement



· Monthly Audits on compliance with Management Plans

· Periodical monitoring on reinstatement activities progress.

· Monthly monitoring of water consumption and re-use.

· Monitoring water quality prior to discharge.

· Monthly training checks.

· Monthly monitoring of stakeholder engagement and grievances.







· Direct Loss or Displacement of Fauna Species

· Indirect Impacts to Fauna and Flora

· Impact to Critical habitat

· Develop and implement the following management plans: CESMP, BAP, BMP, CDP, HMMP, HRWMP, LALRP, LCP, SECP, TMP, WCMP, WAMP, WMP

· Minimise habitat impacts beyond infrastructure footprints.

· Restore soils and the native plant community in areas subject to temporary disturbance.

· Control illegal hunting by the work force.

· Inventory of the juniper trees that will be cut.

· Minimise additional light at night.

· Consider the sensitive points in the life cycle of ecological receptors (e.g., breeding) in defining construction schedule (to the extent practicable). These will be detailed within the Biodiversity Management Plan.

· Compensate for impacts to natural habitat, which would involve providing offsets for impacts in the form of natural resource

General

· Periodical Audits to verify compliance with the various management plans.

Engagement










value that is equivalent. The natural habitat is barren land.

Loss of Habitat for Migratory Species (Transboundary)

· Develop and implement the following management plans: CESMP, BAP, BMP, CDP, HMMP, HRWMP, LALRP, LCP, SECP, TMP, WCMP, WAMP, WMP


General

· Periodical Audits to verify compliance to Ecology Management Plan.

Engagement




· Develop and implement a LARP, CDP, LCP, TPMP



General

· Record of signed compensation agreements

· Periodical audits to verify implementation of management plans (LARP/LALRP, SEP and Community Development).

Engagement

· Periodical surveys of areas of displacement, return or settlement, in total or in random sample;

· Periodical informal or semi structured interviews campaigns with individuals displaced in random sample and record of feedbacks;


Project Proponent



· Prior and Throughout construction and following construction as applicable - Monthly audits


Economic Displacement

· Develop and implement the following management plans: LALRP, CDP, LCP, BMP, TPMP








· Provide training and livelihood assistance programs and disclosure of plan

· Provide compensation to Project Affected People


Investments

· Records of community assistance activities/meetings/events;

· Records of funds disbursed;

· Status and performance of community investment projects already implemented.

Training



Engagement


Impact on Tribal People

· Community consultation on the strategy and disclosure and engagement of TP


General


· Engagement









Impacts Related to

Employment - increase in direct jobs.

· Develop and implement the following management plans: HRWMP, LCP, SEP, CDP

· The HRWMP to include:



Implement Human Resources Policy and Worker grievance mechanism



General


Engagement



Employment










Working Conditions





Project Proponent and EPC contractor









· Condition of workers on site and worker camp areas;

Training



Impact Associated with Increased Demand for Services and Infrastructure

· Development and implement the following management plans: CHSP, CDP, IMP, LCP, SEP, TMP

· Identify services affected and potential interruptions in collaboration with local authorities and utility companies;

· Development a training Management Plan for all staff and contractors;

· Implement appropriate incident response procedures

· Assess local viability of services and provide compensation/alternatives



General

· Periodical Audits to verify implementation of management plans.

· Engagement


Utility Services


· Monitor total number of hours of utility service interruptions (sewage, electricity, water supply and irrigation)

· Monitor traffic loads and traffic incidents;

· Periodical Audits to verify performance of incident response procedures.

· Prior and throughout construction - Monthly audits







Impact Associated with Increased Risk of H&S Incidents and Communicable Diseases

· Develop and implement the following management plans including CHSP, NVMP, OHSP, SEP, SCMP, TMP, WMP, WAMP with the following main scope:










General

· Periodical Audits to verify implementation of management plans (Community Health, Safety & Security Plan and Occupational Health and Safety Plans).

Community and Occupational Health and Safety




· Checks condition of access roads and dust suppression activities;


· Employee personal health programme;

· Implementation of the substance and alcohol abuse policy;

· Periodical audits on trainings performed and health screening;

· Periodical audits of medical equipment on site and facilities conditions and availability as identified in the H&S plan.

Engagement


· Prior and throughout construction

· Monthly audit of medical equipment on site

· Health screening for all workers every 6 months










Gender Impacts, Community conflict and security risks for women.

· Develop and implement the following management plans: GMP, HRMP, HRWMP, LALRP, LCP, SEP, CDP, CHSP, Security Plan

· Community consultation on the strategy and disclosure



· Provide opportunities for women and women’s groups to participate in the work force

· Short-term and long-term vocational and education training programs for women and youth

· Sexual harassment Policy adoption

General


Employment

· Audit the recruitment policy to ensure that it is not gender biased and to ensure no gender discrimination during recruitment process

· Interviewers will be sensitized so as to prevent discriminating on the basis of gender (e.g., due to gender bias or stereotypes)


equal salaries

working hours

vacations

contract conditions


· The contractor shall give priority of the employment to eligible unskilled and semi-

Project Proponent/EPC contractor


General


Employment


Training


Working Conditions


Awareness

· Monthly inspections and monthly reports

Engagement







skilled local people, including women, vulnerable groups and those who are affected by the project, when they possess necessary qualifications and ability.

· Promote full understanding of available positions amongst women in order to overcome preconceived ideas about positions that could be filled by them

· A sentence stating that women are encouraged to apply will be added to any job advertising


· Ensure no gender discrimination during recruitment process

· Interviewers will be sensitized to prevent discriminating on the basis of gender

Training

· Periodical Audits to verify performance of vocational training and job opportunities


Working Conditions





Resettlement

· Verification during the stakeholder engagement activity and monthly report.













Awareness



· Awareness campaigns to promote the new women employment opportunities targeting






the community leaders and religious groups that may influence or facilitate these new employment opportunities.


Engagement


Resettlement

· Compensation must be equal regardless of status of vulnerability in the community.

Impacts Associated with Vulnerable Groups (excluding Tribal people) and Human Rights Issues

· Develop and implement the following management plans: GMP, HRMP, HRWMP, LALRP, LCP, SEP, CDP, CHSP



· Livelihood restoration support for vulnerable parties

General


Employment

· Audit the recruitment policy to insure no vulnerable people discrimination during recruitment process

· Interviewers will be sensitized so as to prevent discriminating vulnerable people (e.g., due to gender bias or stereotypes)


equal salaries

working hours

vacations

contract conditions

Project Proponent


General


Employment


Training



Working Conditions








· The contractor shall give priority of the employment to eligible unskilled and semi-skilled local people, including women, vulnerable groups and those who are affected by the project, when they possess necessary qualifications and ability.


· Ensure no vulnerable people discrimination during recruitment process

· Interviewers will be sensitized to prevent discriminating on the basis of vulnerable status in the community

Training

· Periodical audits to verify performance of vocational training and job opportunities


Working Conditions






Awareness


Engagement

· Monthly monitoring of stakeholder engagement o and grievance management

Resettlement













Awareness



· Awareness campaigns to promote the new women employment opportunities targeting the community leaders and religious






groups that may influence or facilitate these new employment opportunities.

Training


Engagement


Resettlement

· Compensation must be equal regardless of sex of household head.

· Ensure that women (wives) are aware of the total compensation that husbands receive. The mechanism for ensuring this should be specified by the RAP Consultant, for example requiring the wife’s/wives’ signature on receipt.

Impacts on Indigenous people due to Inter-Ethnic/Tribal and Sectarian Tension/Conflict

· Develop and implement the following management plans: TPMP, GMP, HRMP, HRWMP, LALRP, LCP, SEP, CDP.

· Assess Project risks of inter-tribal conflicts.

· Provide equitable distribution of benefits

· Implement Community-based investments

· Regularly review and continue to implement the

General


Engagement




Project Proponent


General


TPPs


Engagement

· Monthly monitoring of and reporting on stakeholder engagement and






Project Stakeholder Engagement Plan.


Investments


· The number and value of projects supported for TP assistance;

· TP attitudes to community development initiatives.

Training



· The number of awareness raising materials distributed to target TPs.

grievance management.


Impact of construction activities on archaeology and cultural heritage

· Develop and implement the following management plans: CHMP, WCMP, WMP, SEP

· Develop and implement a Project Chance Find Procedure (CFP)

· ”Watching briefs” they participate in at specific areas/construction sites;

· Training staff to respond to Chance Finds.



General



· Supervision during construction




· Monitoring/”watching briefs” conducted at specific construction and other sites;




General


Cultural Heritage

· Monthly monitoring of Cultural Heritage Performance Indicators


Engagement

· Monthly monitoring and reporting on stakeholder engagement and grievance management







Engagement



Physical changes to the

landscape

· Develop and implement the following management plans: LVIMP, BAP, BMP, LCP, SECP, SEP

· Reduced working strip and stockpiled materials


· Restoration measures to be detailed and implemented through the LVIMP



General


Landscape

· Supervision during construction of appropriate landscape impact minimization

Engagement








5.2.5 Operational Phase 2

Table 5-5 below illustrates the type of monitoring which will need to be undertaken during routine operation for Phase 2 of the Project.

Table 5-5 – Operational Phase 2

Environment and Social

Impact Management Objective / Action Monitoring Measure

Responsible Person Frequency of Action

Ambient Air Quality

Increased levels of NO2, SO2 emissions

· Develop and implement the following management plans: AQMP, CCMP, TMP, SEP

· It is suggested to perform a best available technology (BAT) analysis. This will assist in investigating for any alternative technologies that could be included in the design of the AGIs, to reduce the NOx emissions from fired heaters and power generation units.

· Development of an Air Quality Management Plan by including procedures to ensure Good Maintenance of the equipment.



General




· Ambient Air Quality monitoring at AGIs

· Periodical Audits to verify proper completion of maintenance register according to manufacturer’s instructions

Engagement


Project Proponent

EHS Manager

General


Air Quality



· Every year Ambient Air Monitoring

Engagement


Noise and Vibration

Noise associated with compressor station AGIs

· Development of and implement the following management plans: NVMP, TMP, SEP.

General


Project Proponent

EHS Manager

General






· Noise control measures for the equipment



Noise Levels


· Periodical Audits to verify proper completion or maintenance register according to manufacturer’s instructions

· Periodical noise monitoring at receptors and AGIs.

Engagement



Noise

· Monthly checks on vehicles and maintenance register

· Annual noise levels monitoring (every three months during first year of operation)

Engagement

· Monthly monitoring of and reporting on stakeholder engagement and grievance management


Disturbance to ecological receptors for operational noise/light/activity

· Develop and implement the following management plans: BAP, BMP, NVMP, TMP SPRP

· Minimise the time lights are on, particularly at night, during migration periods of birds.

· Use low-pressure sodium lights and shielding to direct light to only where it is needed (i.e., eliminate spillage). Shielding can be provided by the fixtures or screening.


· Periodical audits to monitor compliance with management plans

Engagement


Project Proponent

EHS Manager

General


Ecology

· Annual ecology/biodiversity survey

Engagement






· Implement noise mitigation measures to keep consistent noise levels to less than 45 dBA within a short distance into native habitat.

· Include measures in the training and code of conduct of the operations and security teams to ensure that hunting of game does not take place.




· Develop and implement the CHSP, CDP, HRMP, HRWMP, LCMP, SEP

· The CHSP should include the following main scope:








General

· Monthly Audits to verify implementation of management plans.

Safety and Health





Employee personal health programme;

Implementation of the substance and alcohol abuse policy;

Periodical audits on trainings performed and health screening;

Periodical audits of medical equipment on site and facilities conditions and availability as identified in the H&S plan.

Engagement


Project Proponent

EHS Manager

General

· Monthly Audits to verify implementation of management plans Safety and Health

· Monthly Monitoring and reporting

Engagement












Impacts Related to Employment

· Develop and implement the following management plans: HRWMP, CDP, GMP, HRMP, HRWMP, LCMP, SEP.

· The HRWMP to include the following main elements:



· Implement Human Resources Policy and Worker grievance mechanism


General


Engagement



Employment








Project Proponent


General


Engagement


Employment, Working Conditions and Training



Engagement









Working Conditions






· Condition of workers on site and worker camp areas.

Training




Engagement



Erosion of tradition and cultural values

· Develop and implement the following management plans: CHMP, SCMP, SEP

General

· Periodical Audits to verify implementation of management plans (Cultural Heritage Management Plan and SEP).

Project Proponent


General







· Continue to implement Chance Find Procedures (CFP)

· Avoidance of cultural heritage resources









Engagement





Engagement

· Monthly monitoring of and reporting on stakeholder engagement and grievance management.


Impact due to Operation of Phase II AGIs on the Landscape of the Sulaiman Mountains

· Develop and implement the following management plans: LVIMP, BAP, BMP, NVMP, SECP, WAMP, SEP


· Lighting at AGIs to be used only when required and shall be designed to minimize light pollution


General


Landscape

· Monitoring of the vegetation growth and development along ROW areas and AGIs

· Periodical Audits to verify performance of Landscape Management Plan.

Engagement


Project Proponent

General


Landscape



Engagement

· Monthly monitoring and reporting on grievance management.



6 COMMITMENTS REGISTER

6.1 Overview

The following sections detail the Commitments Register which sets out all the specific

mitigation measures that the Project currently proposes to adopt in relation to potential

impacts identified in the ESIA.

The Commitments Register is intended to be read in conjunction with the full text of

this ESIA document which provides important context and background, as well as

describing the impacts which the listed measures aim to mitigate or manage, and the

residual impact which may remain. The commitments are split for Phase I and Phase

II.



6.2 Phase I Commitments Register

Table 6-1 – Phase I Commitments Register



Commitment Reference

Project Phase Category

Copy of Original Text from ESIA Report / Commitment

PAK-01-01 Construction Air Quality


· Ensure all machinery is properly maintained in accordance to equipment maintenance requirements.



· Pre-notification of critical dust producing activities and implementation of Community Liaison procedures;



· Dust suppression using watering can be achieved using camps’ grey water. Alternatives include wood chips and calcium chloride, or other environmentally safe products developed for this specific use. Dust suppression material should not scar the area and prevent vegetation growth (salt for example is not acceptable);







· Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery; and

· Dust suppression techniques should be implemented, such as applying water (for example, grey water from camps, subject to meeting WHO grey water guidance WHO-EM/CEH/125/E2006) or non-toxic chemicals to minimize dust from vehicle movements.

For AGIs and temporary facilities, the following additional mitigation measures may be applied on an as-needed basis:


Imported construction material stockpiles should be located away from sensitive receptors



PAK-01-03 Commissioning and Operation

Air Quality

· The FEED emission studies (TPCL, 2017a, 2017b, 2017c) have reported NOx emissions of 320 milligrams per normal cubic meter (mg/Nm3) for a fired heater and 200 mg/Nm3 for a power generation unit. It is therefore proposed to remove the fired heaters form the design to reduce the NOx emissions significantly. However, it must be noted that this is representative of a worst-case maximum capacity emission scenario defined at a preliminary design stage, and actual emissions from Project units are likely to be lower.

· Detailed engineering design should perform a BAT analysis to select the best technologies that could be included in the design of the AGIs, to minimize the NOx emissions from power generation units.

PAK-01-04 Emergency Scenario

Air Quality Maintenance and inspection of diesel generators according to manufacturer’s instructions.

PAK-01-05 Construction and Decommissioning

Noise and Vibration

· The EPC Contractor to implement targeted mitigation as needed along the ROW (such as consultation with locals, noise monitoring, siting of equipment, barriers, etc.) once the corridor has been defined;

· It is recommended that the contractors undertaking construction activities follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at the minimum level practicable. These measures include:

· The noisiest machines to be located on the far side of the pipeline to the works. Thus, when the works are at the closest distance to a sensitive receptor, there will be less noise sources contributing to the noise level at a single location.

· Selecting equipment with low noise emission levels, wherever possible;

· Ensure machinery is properly maintained in accordance with equipment maintenance requirements captured in the contractor’s management system;

· Use machinery and equipment in accordance with the manufacturers’ instructions;

· No plant should be left running unnecessarily; and

· Noise impacts from generators will be minimized by regular maintenance and, if practicable and safe, taking into account the local temperature, keep generators within acoustic enclosures.

· Some activities can be controlled to some extent by the provision of temporary noise barriers or enclosures, but this may not be practicable in all instances.

· It is also recommended that clear and early communication with local residents be provided to make them aware of the activities to be undertaken and to give provide advice based on the health and safety risks involved.

· In addition, construction works should avoid certain sensitive time periods such as night-time hours, Fridays, and holiday periods.

· In the event the contractor must undertake works at night, this will need to be approved by the relevant authority in the area in advance.



· In the instance that the duration of the construction works at a single location is 10 days or more of working in any 15 consecutive day period or more than 40 days in any 6 consecutive months, it is recommended that temporary rehousing be considered (BSI, 2014a). The application of British Standards for the provisioning of temporary housing in rural Pakistan socially and culturally has potentially significant negative impacts. TPCL is focused on being culturally sensitive and will approach grievances and mitigation measures on a case-by-case basis.

· Community grievances in relation to noise will be address on a case-by-case basis with potential mitigation measures discussed with the affected party, including the provision of temporary housing for ongoing grievances.

· Any individual receptors in close proximity of access roads connecting the AGIs with the local road network need to be identified (preliminary routes are provided Although vibration construction works are not expected to result in significant impact, any receptors located within 10 m may experience vibration levels (of 2.6 mm/s) which are likely to be noticeable and cause a complaint but can be tolerated if prior warning and explanation has been given to residents.

· The noise from vehicles and moving plant can be minimized by regular maintenance, selection of traffic routes, and timings of traffic movement.

· In relation to rock blasting activities, it is recommended that a specific assessment is undertaken prior to the works commencing to establish the potential impacts specially from vibration on nearby structures. Engagement with local residents to inform them prior to such activities taking place is the most suitable mitigation measure. The contractor in charge of rock blasting must also minimize, as far as practicable, noise and vibration from this activity by minimizing the number of events and the period of the activity.

PAK-01-06 Commissioning

and Start-up Noise and Vibration

· Construction mitigation measures also apply here. These would need to be implemented by the contractors on-site in order to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at the minimum level practicable.

· Prior to hydrotesting, the contractor should:

- Define the exclusion zone for hydrotesting;

- Identify these locations and sensitive receptors in the proximity and inform residents about the works;

- Hydrotesting activities should be address in the Noise and Vibration Management Plan and a dedicated Hydrotest Environmental Management Plan. The Noise and Vibration Management Plan must consider hydrotesting activities and locate these away from sensitive receptors as far as practically possible (> 500 m). Where hydrotest locations cannot be located away from sensitive receptors, less noisy equipment and methods such as condensers, water injection or discharging into water, and fitting of silencers must be used;

- Place the generators, which are one of the main noise sources from this activity, within acoustic enclosures and away from the sensitive locations, as much as practicable; and



Do not exceed the scheduled period for hydrotesting and this should be minimized as far as practicable.

PAK-01-07 Operation Noise and Vibration

The following engineering controls are recommended as a form of GIIP measures:

· Utilize the best available technology by selecting equipment with the lowest noise emission levels, wherever possible;

· Fit silencers, acoustic insulation, and noise enclosures, where practicable;

· Ensure new plant equipment is properly maintained in accordance with equipment maintenance requirements to avoid any potential increase in the noise levels caused due to poor maintenance;

· Use machinery and equipment in accordance with the manufacturers’ instructions; and

No plant should be left running unnecessarily.























· The BMP should include potentially relevant habitat and consider the habitat preferences of the species in biodiversity offsetting design.


and Start-Up Physical

Environment

The following mitigation measures should be applied for Medium significance impacts during Phase I commissioning/start-up:

· Develop a Project-specific Hydrotest Environmental Management Plan (HEMP) to capture all activities involved in the abstraction, potential additives, testing, treatment, discharge, and performance monitoring of hydrotesting water, including relevant health and safety considerations (such as exclusion zones to be implemented);

· Ensure there is an adequate SPRP, Water Management Plan, Waste Management Plan, and HMMP prior to commencement of commissioning works;

· Schedule in advance the proposed hydrotest date and ensure the area where it is to be conducted is assessed and surveyed for environmentally sensitive receptors;

· Notify in advance the scheduled activities to secure any permits or approvals that may be necessary for activities such as water withdrawal, disposal or transport between watersheds. Land owners and relevant government agencies should also be notified prior to conducting large-scale hydrotests;

· Ensure than land needed for hydrotesting activities is included in the Land Acquisition Plan for proper management before the use;

· Landowners and relevant government agencies should also be notified prior to conducting large-scale hydrotests;

· The following additive design mitigation measures shall be implemented:

- for any hydrotest additives, ensure the use of low environmental impact and or biodegradable substances;

- minimize the usage of any additives which will affect water quality;



- water used for hydrotesting can typically be returned to its source or released to land with the landowner’s permission. Regulatory approval conditions may require laboratory analyses to verify that the water has not become contaminated during handling. In such situations, it is advised that samples of the source water be collected and analysed prior to hydrotesting to ensure that background concentrations of certain parameters are acceptable;

- water containing additives or water used to hydrotest an existing section of pipeline is likely to require treatment prior to discharge;

- conduct aquatic toxicity tests on sample water prior to discharge, if additives are used (for example, biocides, oxygen scavengers, corrosion inhibitors, detergents, antifreeze, or leak detection tracers) and treat if toxicity is higher than reference water from the waterbody;

- in the event that hydrotesting water does not meet toxicity test discharge criteria, treatment and disposal options at the test location (including transporting the water through the pipeline for storage and eventual treatment) are to be evaluated;

- should discharge criteria not be available in the legislation and guidelines referred to in this section of the ESIA report, the EPC Contractor is referred to the UK Environment Agency Refining Sector Guidance Note EPR 1.02 (2009);

- if water is to be discharged from one river to another, analyse the presence of living alien species prior to discharge;

· The following water abstraction and discharge physical mitigation measures shall be implemented:

- pump intakes during withdrawal from surface water bodies must be located at least 0.3 m above the bed, whenever possible;

- ensure that pump intakes point downstream;

- ensure the use of screen pump intakes with a maximum mesh size of 2.5 mm to prevent the removal of juvenile fish and other organisms from the water body;

- ensure that a 0.038 m/s velocity of flow at the screen is not exceeded;

- if the water is particularly turbid, additional filtering or sufficient settling time in a holding tank may be required to reduce suspended solids prior to use;

- ensure the use of best practices to minimize the quantity of water supplied for testing purpose by requiring recycling and reuse;

- the withdrawal rate shall not exceed 10% of the stream flow; however, the regulatory agency may identify specific requirements through permit or approval conditions. There may also be restrictions pertaining to the time of year that water withdrawal is allowed to take place;

- this may limit abstraction to specific times of the year. Gauging of the rivers upstream of the point of abstraction should be undertaken to confirm that the abstraction is not adversely reducing the river flow and exceeding the agreed criterion;



- abstraction from, and discharges to, all rivers should meet the requirements of the national and local agencies;

- monitor discharged waters from hydrotesting activities to be sent to an evaporation pond / lagoon or river depending on water quality and chemical composition;

- for discharge to land, water must be released in a manner that will not cause soil erosion;

- release water at a rate that will not increase the temperature or decrease the dissolved oxygen levels within a short distance from the discharge point;

· The following hazardous material storage, management, and spill response mitigation measures shall be implemented:

- whenever possible, the pumps used to pressurize a section of pipeline for a hydrotest should be located a minimum of 50 m away from any surface water bodies or ditches that may lead directly into one. As an added precaution, all pumps, tanks and associated piping should be situated within a bermed area to contain the inadvertent release of any deleterious liquids;

- storage for fuel, lubricants, and other hazardous materials must be situated as far away from water courses as possible within an impermeably lined, bermed area; and

spill kits and emergency response equipment will be stationed nearby during a hydrotest to deal with the release of any deleterious materials. An exclusion boom may be pre-deployed to protect sensitive areas identified during the pre-test site survey.

PAK-01-10 Operation Physical

Environment

· Temporary waste disposal tanks can be used to collect debris from pipeline internal inspection operations.

· Vegetation waste resulting from periodic ROW maintenance should be heaped and composted or managed under arrangement with input from local community members as potential beneficiaries.


Environment

· In line with mitigation set out Section 7.7. Cultural Heritage Impact Assessment, avoidance of karez systems is recommended. Suitable stakeholder consultation will need to take place to ensure the owners and users of any karezes that may be impacted by the Project are consulted with prior to construction works commencing, this will be detailed with the Stakeholder Engagement Plan.

· Location of karezes will be checked against the FEED database and, where different, the Project will be informed;

· Staff involved in construction will be well trained on karez management prior to construction;

· Location of karezes in the vicinity of the pipeline ROW will be marked on the ground;

· A geotechnical engineering evaluation of the risk of collapse of a karez at location of pipeline crossing will be done prior to constructing the pipeline across the karez;

· Works over an area marked as the karez will progress as quickly as possible to minimize time that higher loads are placed above the structure;

· All heavy vehicles will avoid parking in a 50 m exclusion zone on either side of marked karez;



· For each karez crossing, the mitigation methods employed will be documented;

· Contingency water supply shall be immediately available in the event of a karez collapse;


· The location of existing irrigation systems in the vicinity of the pipeline ROW will be recorded prior to construction works commencing;

· Any drainage systems used as a water source will be mapped prior to works commencing and impacts will be avoided and mitigated;

· Avoidance of channels used as a water source, including those for agricultural land, will be a priority; if they cannot be avoided then the impacts will be mitigated fully by temporarily redirecting water flow during construction to ensure the existing flow is maintained for the duration of the Project;

· Any cut-off of existing drainage systems shall be communicated in advance to the interested parties and any action shall be authorized by specific agreement; and


PAK-01-12 Decommissioning Physical

Environment

· If parts of the pipeline are to be decommissioned and removed, activities similar to that undertaken during the construction phase will need to be executed, with a similar environmental impact assessment required for the operation.

PAK-01-13 Pre-Construction and Construction





· Restore soils and plant native vegetation (or comparable crops where applicable) in areas subject to temporary impact comprising 1,346 ha of natural habitat and 1,260 ha of modified habitat;


· Develop and implement a Biodiversity Management Plan (BMP) and Biodiversity Action Plan (BAP). The BMP will include an assignment of relative biodiversity quality to the remote sensing and a refinement of the characterization of the balance between natural and modified habitats for the purpose of defining biodiversity restoration and offset needs. If additional field data cannot be collected, an assumption regarding the average level of degradation will need to be adopted to account for the uncertainty associated with the natural category.

· Prior to commencement of the construction activities, qualified ecologists are to further document areas within the construction corridor defined in Section 6.5. Ecology and Biodiversity Baseline as natural habitat.



The purpose is to support the development of restoration, compensation, and offsetting approaches and ground truth the classification done using remote sensing and transects, confirming: 1) if the areas are natural habitat or should be revised to modified habitat where evidence can be provided of extensive degradation; and 2) confirming if areas classified as potential critical habitat are critical habitat or natural habitat or remain potential critical habitat with supporting evidence. The pre-construction survey should include the following:


- highly representative (3 points);

- moderately representative (2 points);

- poorly representative / not representative (1 point); Biological Q-rating for each survey location is assigned based on the sum of the evaluation points across these three criteria, as high [9 points], medium-high [8 points], medium [3-7 points], low-medium [2 points], or low [1 point])







· Offsets for permanent impacts to natural habitat estimated as 444 ha. Compensation for permanent impacts of 450 ha modified habitat will be addressed through the Land Acquisition Plan and Livelihood Restoration Plan;

· For the loss of natural habitat (this includes potential critical habitat and modified habitat with significant biodiversity values), mitigation must be provided that is equivalent in value. For critical habitats, mitigation must be provided that is greater in value. Tree planting requirements under the Pak-EPA’s environmental approvals must incorporate GIIP for offsetting (IFC, 2015). Two types of offset are acceptable, namely, averted loss and restoration;










· For the design of in-place habitat restoration and biodiversity offsets, consider the habitat preferences of the species for which critical habitat and potential critical habitat have been identified by province (Table 7.5-9), and any additional CR, EN, or endemic species identified during the ongoing construction surveys;



· Project Net Positive Biodiversity Benefit will be included as potential objective as a topic to be investigated in the Community Development Plan (CDP), Local Content Plan (LCP) and Human Resources and Workers Management Plan (HRWMP). This would likely include increasing biodiversity along the restored section of the ROW and targeted offsetting in areas of critical habitat.


and Start-Up Ecology and Biodiversity






· In areas where the density of animals may be high, construct trench plugs every several hundred meters (that is, ramped earth which enables entrapped animals to escape);



· Before blasting, survey for important natural resources that may be impacted. Scare off or move animals in the immediate vicinity. Use blast mats to minimize impacts to vegetation and important environmental features. Do not use ammonium nitrate-based explosives in or near water due to the production of toxic by-products; and

· Adhere to the Traffic Management Plan and Water Management Plan that will be developed for the Project.

PAK-01-15 Commissioning and Start-Up



· It should be noted that the use of HDD is a river crossing mitigation measure in its own right, as it is an alternative to open-cut, which would have a higher impact if used on the Indus River. Many of the mitigation measures for open-cut river crossings, as discussed in Section 7.5.2.11, also apply to HDD.

In addition to those outlined in detail in Section 7.4 Physical Environment Impact Assessment, the following mitigation measures should be included in an HDD EMP prior to construction:

· Mitigation measures specific to the Indus River dolphin include the use of pingers during drilling activities to encourage dolphins to avoid the area. Concurrently Marine Mammal Observation (MMO) during the works, restricting the speed and movement of any project-associated watercraft. These measures should be included in the HDD EMP, together with timeframes for HDD and reporting / communication protocols between MMO and HDD crew;

· During HDD, storage of cuttings and bentonite fluids is required to have secondary containment;

· HDD cuttings and waste drilling fluids should be tested prior to disposal and the final disposal method should be approved by regulatory agencies as specified in the Waste Management Plan;

· Contingency measures should be in place prior to drilling for a frac-out event during HDD activities. This should include monitoring of equipment and the water crossing, provision of silt curtain materials and fasteners at the HDD site, and machinery to remove bulk bentonite in the event of a major frac-out;

· Work areas for drilling and pipe pull should avoid the riparian zone if possible, taking into account the constraints of working at the upper limits of the technology. In the event that the riparian zone cannot be avoided, planting / seeding of native vegetation should occur in riparian zone as soon as possible after habitat impact to minimize erosion;

· Consider the sensitive points in the life cycle of ecological receptors (such as migratory aquatic birds and spawning fish) in defining construction schedule. To the extent practicable, avoid construction during these periods. Definable sensitive life cycle points will be detailed within the BMP;

· The HDD EMP should be read and implemented in conjunction with the WCMP; and



TPCL will provide a copy of the draft HDD EMP to WWF India and Punjab EPA for review comment. TPCL will provide regular progress updates and MMO summaries of HDD activities to WWF India and Punjab EPA.

PAK-01-16 Commissioning and Start-Up





























· The BMP and BAP should include potentially relevant habitat and consider the habitat preferences of the species in biodiversity offsetting design.

PAK-01-19 Operation Ecology and Biodiversity




· Utilize designated roads only, at speeds within defined limits, and adhere to the Traffic Management Plan. This will confine the area of impact and minimize noise, dust and vehicle-induced animal mortality. The survey team observed numerous reptiles, a group of organisms that are susceptible to being killed by vehicles;

· Implement noise mitigation measures to keep consistent noise levels to less than 45 dBA within a short distance into native habitat;

· Develop a set of mitigation measures specific to the Indus River Dolphin, including monitoring an exclusion zone for any activities that could produce noise or light that could potentially disturb marine mammals. These measures should be included in a Marine Mammal Mitigation section of the BMP and BAP; and




PAK-01-20 Decommissioning Ecology and Biodiversity




· Restore soil and the native plant community in AGI footprints and roads where habitat was eliminated;


· Minimize additional light at night;

· Implement the noise mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment;

· Assess bankside erosion control measure for integrity and only remove in the event that their integrity is likely to fail and lead to bankside erosion. In the event the structures integrity is high, repair as required and leave in place avoiding creation of sediment and noise impacts. This is especially relevant to the Indus River;

· In the event bankside erosion control measure decommissioning work is required for the Indus River the use of pingers during bankside activities to encourage Indus River Dolphins to avoid the area. Concurrently MMO during the works, restricting the speed and movement of any project-associated watercraft. These measures should include reporting / communication protocols between MMO and decommissioning crew; and

· Employ strict control measures for any spills from vessels required for the pipe bridge decommissioning.


Socio-economics

· The Project will actively consider adjustments of the pipeline within the 500 m corridor to avoid physical displacement and to reduce economic displacement as far as possible.

· A Land Acquisition and Resettlement Policy Framework (LARF) has been developed for the Project, which sets out the national and international standards and laws to be followed during the land acquisition process. A Preliminary Land Acquisition and Resettlement Plan (LARP), which has also been prepared, will be replaced by a Land Acquisition Plan (LAP) and Livelihood Restoration Plan (LRP) prior to Project construction. The aim of these documents is to ensure that national legal requirements and international standards for land acquisition and resettlement are met. As part of this process, the GOP and TPCL will be required to organize resettlement for all occupants or users of affected land and residences (if applicable), irrespective of their tenure or legal status. The aim of this process is to ensure that affected parties are able to restore, and ideally improve their living conditions and livelihoods.

· Mitigation measures for physical displacement will be developed in consultation with affected parties, providing alternative housing and / or cash compensation and livelihood restoration measures where appropriate. Special consideration will be taken for those viewed as being severely affected and/or vulnerable prior to the commencement of any Project construction.



Under the Preliminary LARP, the following provisions are made in terms of promoting restoration of land and livelihoods:

· A comparison between LAA 1894 and IFC PS 5 will be prepared to inform discussions with Pakistan authorities responsible for land acquisition and compensation;

· TPCL will work closely with the Pakistan authorities responsible for land acquisition and compensation to ensure the process meets both national regulatory requirements and GIIP, such as stakeholder engagement, fair compensation, replacement land where possible, and support to vulnerable people;

· Affected Persons who will by physically displaced (i.e., will lose their place of residence, if applicable) will be offered a package of compensation measures that will include in-kind replacement (the provision of a replacement property and replacement structures) or cash compensation based on replacement value. TPCL, the competent authorities, and Affected Persons will negotiate on the package of options consistent with the land acquisition procedures established in the country;

· TPCL will promote fair and informed consultation and participation of key stakeholders and Affected Persons during the resettlement planning and implementation phases. This will include direct engagement with Affected Persons in terms of the package of compensation options, the determination of their preferences and suitable training if cash compensation is chosen. All forms of engagement and negotiations will be recorded consistent with national regulatory requirements and to GIIP;

· Affected Persons that are deemed eligible for resettlement assistance and compensation are not limited to landowners or structure-owners but also include persons with customary rights to land and assets or persons with no recognizable legal right or claim to land and assets under national law. This will include persons who derive benefits from the land under a fixed-term or annualize tenancy agreement, or persons who have a long-term occupation or use of land with expanded rights under the principle of adverse possession (or when a person, who does not have legal title to a property, may make a legal claim based on a history of possession or occupation);

· TPCL acknowledges the responsibility not just to pay compensation for losses, but also to assist potentially affected households (and vulnerable households in particular) to restore their livelihoods and improve their standard of living. The LRP will be developed to meet these responsibilities, in compliance with both international good practice and guidelines. Livelihoods are multi-faceted, and a combination of approaches is therefore required to support restoration of income and the reestablishment of community support networks. Measures should include:


- livelihood and income restoration should be achieved by providing suitable compensation packages that prioritize replacement assets over pure cash compensation, as defined in the Preliminary LARP;

- as most livelihoods are land and agriculture based, the provision of replacement land is deemed a priority with respect to livelihoods restoration. Where possible, the GOP will allocate unclaimed or unutilized state or village land and transfer the land to private title under the Affected Person’s name. Where such cannot be secured, TPCL and the GOP will explore the acquisition of private land on the open market and



transfer the acquired land to the Affected Persons. Where this second option fails, and replacement land cannot be guaranteed, cash compensation for the land will be provided at replacement value to allow Affected Persons to secure their own alterative land, or for individual livelihood investment;






- provide mechanisms for those receiving cash compensation to optimize opportunities such as financial management training;

- engender self-reliance and foster socio-economic empowerment in the affected community;

- TPCL in collaboration with the GOP may, at their discretion, promote a range of alternative livelihood development programs, where replacement land and other assets cannot be secured. The range of programs will be defined in a separate LRP to be developed alongside the finalization of the Preliminary LARP. The development of alternative livelihoods is prone to failure and requires significant investment therefore it should not be treated as a preferred option, but rather should be defined as developmental programs in addition to the provision of replacement assets and compensation;

- active participation of intended beneficiaries in planning and decision making is required to ensure proposed support reflects local realities / priorities and have active buy-in;

- Affected Persons should be provided with choices so that they can self-determine how their household will best benefit from the livelihood restoration options;

- vulnerable households are less able to adapt to changes and therefore require targeted support through the planning and implementation of livelihood restoration; and

- financial management training or advisory support including basic numeracy, money management and budgeting, and basic literacy.

A set of principles is recommended to guide the land acquisition and compensation effort, including:

· A transparent compensation procedure with multiple information and consultation steps so that all village residents can see that no other resident is gaining an advantage;

· Sensitivity to cultural practices and local legal requirements;

· Recording all compensation transactions; and



· Avoiding resettlement of households through Project redesign where possible.


Socio-economics

· International best practice stipulates that livelihoods should be considered to encompass the full range of means that individuals, families, and communities utilize to make a living, such as wage-based income, agriculture, fishing, foraging, other natural resource-based livelihoods, trade, and bartering. A livelihood is sustainable when it enables people to cope with and recover from shocks and stresses (such as natural disasters and economic or social upheavals) and enhance their well-being and that of future generations without undermining the natural environment or resource base. Since the Project cannot avoid economic displacement impacts, an LRP will be developed in close liaison with authorities and Affected Persons including the following:

- A comparison between the LAA 1894 and IFC PS5 will be prepared to inform discussions with Pakistan authorities responsible for land acquisition and compensation;

- TPCL will work closely with the Pakistan authorities responsible for land acquisition and compensation to ensure the process meets both national regulatory requirements and GIIP, such as stakeholder engagement, fair compensation, replacement land where possible, and support to vulnerable people;

- Affected Persons eligible for livelihood restoration assistance and compensation are not limited to landowners or structure-owners but also include persons with customary rights to land and assets or persons with no recognizable legal right or claim to land and assets under national law. This will include persons who derive benefits from the land under a fixed-term or annualize tenancy agreement, or persons who have a long-term occupation or use of land with expanded rights under the principle of adverse possession (or when a person, who does not have legal title to a property, may make a legal claim based on a history of possession or occupation);

- TPCL acknowledges the responsibility not just to pay compensation for losses, but also to assist potentially affected households (and vulnerable households in particular) to restore their livelihoods and improve their standard of living. The LRP will be developed in compliance with international best practice and guidelines including:










- provide mechanisms for those receiving cash compensation to optimize opportunities such as financial management training; and

- engender self-reliance and foster socio-economic empowerment in the affected community.

Where damages are sustained to crops or economic trees, fair compensation will be determined by a number of differing methods as established in the LAA 1894 including:

· Crops: The prices of crops including additional inputs costs (such as the price of seeds sowed, chemical fertilizers, and costs of farming) will be determined. The price of crops will be determined based on local market value in neighbouring areas for the three months prior to the valuation;

· Non-Productive Trees: The value of non-productive trees will be determined on the basis of the price of firewood, according to the local tradition. The Law does not establish how firewood is equated to the number or size of non-productive trees;

· Non-Productive Ornamental Trees: The value of non-productive ornamental trees will be determined on the basis of five times that of the price of firewood, according to the local tradition. The LAA 1894 does not establish how firewood is equated to the number or size of non-productive ornamental trees; and

· Productive Trees: The value of productive trees will be determined on the basis of the price of firewood as well as the price of products of the trees over the period of 5 years. Where fruit produce is directly lost, the price of the fruits will also be included in the compensation.

As a means of comparison and to allow for alignment with GIIP requirements, the value of crops and trees will be determined using the Income Method where the crops and economic trees are valued based on the estimated income/profits generated from the produce over a pre-determined transition period. The Income Method also factors in costs for the re-establishment of annual crops, perennial crops and trees, including costs of seedlings/saplings, input costs, and the loss of productivity over the period which perennial crops and trees need to become productive.

The LALRP will identify households that will no longer be able to continue with their existing livelihood activities. These households will be provided with access to a livelihood restoration process. The aim of this is to help



affected households access alternative livelihoods and replace those lost by the Project. This will include training on improved agricultural techniques such post-harvest handling or accessing low-cost inputs, diversification of employment, assistance in accessing savings and credit opportunities, and providing local business and enterprise training. Particular attention will be paid to vulnerable groups and individuals who may require additional support, in particular during the transitional period between loss of existing livelihoods and reestablishment of improved/alternative livelihoods.

A Project SEP has been developed as a living document that shall be updated as the Project evolves, in accordance with key milestones, to ensure full stakeholder participation in Project decision-making, guided by GIIP including the following:

· Involve stakeholders to facilitate inclusive communication and capture a wide range of issues and concerns;

· Ensure that stakeholders, particularly those directly affected by the proposed development, have information at their disposal with which to make informed comments and enable them to plan for the future to reduce levels of uncertainty and anxiety. Information should allow affected parties to develop an understanding of potential impacts, risks and benefits and an open and transparent approach is central to achieving this aim; and

· Implement a Grievance Mechanism to monitor and manage stakeholder grievances. The Grievance Mechanism is to be closely monitored for any potential issues related to conflicts or creating any new clashes between ethnic groups, workers and/or villages. Urgent action will be likely be required in the event of complaints being made in relation to conflict between groups.

· Regular review and continued implementation of the Project SEP will be undertaken, ensuring that consultation with affected communities continues and that the needs of vulnerable community members are considered.


Socio-economics

At this stage it is not clearly understood how many affected parties will be impacted by changes to access to ecosystem services. As part of the ongoing land acquisition process and during the finalization of the LAP and LRP, it is the responsibility of TPCL to conduct the following:

· Identify areas along the pipeline route that are used communally for natural resource collection;

· Determine the land tenure status of this land, how the land is used and by whom;

· Identify whether the ecosystem services accessed in the PAI are unique or ubiquitous; and

· Determine if there is an impact that requires mitigation measures.

All mitigation measures must be developed in consultation with relevant stakeholders, including affected communities and relevant government officials.




Socio-economics

· The CESMP shall include a Water Management Plan (as per guidelines provided in the Water Management Framework in Appendix F). Mitigation measures for groundwater, surface water, and irrigation channels are to be included in the Water Management Plan.

· Pre-construction planning must identify water sources for human consumption and Project use, along with conducting an evaluation of the impacts of groundwater draws by the Project to private and community wells and boreholes. If analyses indicate that reduction in water levels will occur, TPCL must purchase water and transport to the site for use. Measures must be taken to prevent damage to irrigation systems which could result in orphaned farmland. Irrigation systems are to be reinstated or diverted as necessary to prevent degradation of farmland.

· TPCL will ensure that any abstractions of water including groundwater for Project use, will not impact this resource availability to nearby communities. All abstractions must be permitted by the appropriate agencies.

Measures to protect river water quality to minimize the release of sediment related to construction methods used for river crossings or other wastes either directly or diverted into water bodies should be implemented. In Punjab, in particular, canals and rivers are a key irrigation source for surrounding agriculture. Minimizing sediment content and transport is essential to maintaining agricultural output.

Should river water be abstracted, the following mitigation measures should be followed:

· Screens should be used at water abstraction points in order to prevent the removal of juvenile fish and other organisms from the water body;

· Monitoring of water levels and flow of the abstraction points should be conducted as appropriate to ensure that abstraction is not causing a net decline in the amount of water;

· No more than 10% of the river flow should be abstracted at any point in time, so that downstream flows are maintained for natural systems; and

· A Grievance Mechanism shall be implemented to monitor and manage stakeholder grievances related to water availability and quality.

· In the event HDD is applied to river crossings, risks will be mitigated by the measures described in the HDD EMP.

· Stakeholder engagement will keep communities informed of the construction schedule.


Socio-economics

· Proactive outreach with potentially affected settlements is essential to reducing the disruption to local settlements.

· It is recommended that clear and early communication with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken.





Socio-economics

Prior to construction, the CESMP shall be developed to include the following specific management plans: Community H&S Plan, Community Development Plan, and Influx Management Plan.

· The Community H&S Plan

- establish preventive and control measures consistent with GIIP, such as in the World Bank/IFC EHS Guidelines or other internationally recognized source;

- anticipate and avoid adverse impacts on the H&S of the affected community during the Project life from both routine and non-routine circumstances;

- promote the safeguarding of personnel and property carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the affected communities;

- design, construct, operate, and decommission the structural elements or components of the Project in accordance with GIIP, taking into consideration safety risks to third parties or affected communities;

- avoid or minimize the potential for community exposure to hazardous materials and substances that may be released by the Project;

- identify those risks and potential impacts on priority ecosystem services that may be exacerbated by climate change - adverse impacts should be avoided;

- avoid or minimizes the potential for community exposure to water-borne, water-based, water-related, and vector-borne diseases, and communicable diseases that could result from Project activities, taking into consideration differentiated exposure to and higher sensitivity of vulnerable groups;

- avoid or minimizes transmission of communicable diseases that may be associated with the influx of temporary or permanent Project labour; and

- in addition to the emergency preparedness and response requirements (as per IFC PS1) assist and collaborate with the affected communities, local government agencies, and other relevant parties, in their preparations to respond effectively to emergency situations, especially when their participation and collaboration are necessary to respond to such emergency situations.


Socio-economics

· Community Development Plan

- TPCL shall consider developing a Community Development Framework (and subsequently a Community Development Plan) that shall include needs assessments and priority ranking to identify needs of local communities. The plan shall include local institutional capacity building to ensure that communities manage and maintain their projects, striving towards sustainability;

- as part of a community development program and to provide for local institutional capacity building, TPCL should consider providing emergency medicine training to local medical staff who work at facilities along the PAI and donations of equipment and supplies to these institutions; and



- the Grievance Mechanism shall be used to manage and monitor community complaints. Grievances shall be analysed to understand if complaints are made in relation to local access to services and infrastructure with any issues dealt with as a matter of urgency.

· Influx Management Plan

- prior to construction, ensure that the CESMP includes a specific Influx Management Plan to manage this process and minimize service and infrastructure demand impacts where possible;

- TPCL will ensure that the contractor provides for additional medical staff onsite trained in providing emergency services during peak construction periods to provide critical support in the field, avoiding overwhelming local healthcare resources;

- the Project will monitor non-Project related influx into the area to understand if this has the potential to impact upon local services and infrastructure. In the even that this occurs, the Project will work with local authorities to manage this process and minimize impacts where possible; and

- prior consultation must be undertaken with any potentially impacted communities to discuss upcoming works in order to reduce potential conflict.


Socio-economics

· Develop and implement a Community Health and Safety Plan

· In addition to complying with the World Bank/IFC EHS Guidelines for Onshore Oil and Gas Development, which address occupational and community H&S, a complete H&S Program that includes emergency response plans will be developed and implemented by the EPC Contractor.

· This program will be cascaded down through the supply chain, requiring stringent adherence for all participating organizations.

· This program will include first aid and safety training for project leaders and workers, regular testing of emergency response plans in coordination with public service agencies (such as law enforcement, healthcare organizations, and others), and community stakeholders, construction camp regulations to be developed to minimize local nuisance (for example, limiting or preventing workers from socializing in the PAI), onsite healthcare at each construction camp and in the pipeline construction area, PPE, and limiting exposure/providing hydration when working in high temperature environments

· An Occupational H&S Plan (OHSP) will be developed prior to construction. The program will cascade down through the supply chain requiring adherence for all participating organizations.

· The program will include, but not be limited to the following list of H&S plans, standards and procedures which are to be developed as a function of Project H&S execution. As such these will be undertaken separately to core ESMS documents.

· H&S Regulatory Permits will be managed under Projects Permits and Compliance System.

· An Occupational H&S Plan will be prepared by the Contractor, which will include the following items:



o Initial Safety Induction Course. All workers will be required to attend a safety induction course before they are allowed access to the work area;

o Periodic Safety Training Courses. Safety courses will be conducted not less than once every six months. All EPC Contractor (and subcontractor) employees will be required to participate in relevant training courses appropriate to the nature, scale and duration of the works. Training courses will be provided for all workers and at all levels of supervision and management. A list of training participants’ names and time-stamped photographic evidence of the training will be provided by the EPC Contractor to TPCL;

o Safety Meetings. Regular safety meetings will be conducted on a monthly basis. TPCL will be notified of all safety meetings in advance. TPCL may attend in person or by representative at their discretion. Minutes of all safety meetings will be taken and sent to TPCL within seven days of the meeting and will include a list of participants names and time-stamped photographic evidence of the training;

o Safety Inspections. The EPC Contractor will regularly inspect, test and maintain all safety equipment (including firefighting equipment), scaffolds, guardrails, working platforms, hoists, ladders and other means of access, lifting, lighting, signing and guarding equipment. Lights and signs will be kept clear of obstructions and legible to read. Equipment, which is damaged, dirty, incorrectly positioned or not in working order, will be repaired or replaced immediately by the EPC Contractor;

o PPE. Workers will be provided (before they commence works) with appropriate PPE suitable for construction work such as safety boots, helmets, gloves, protective clothes, goggles, and ear protection at no cost to the workers. Life vests will be provided for all staff working around, or above water channels or rivers;

o Workers H&S Training Plan including communicable disease prevention; o Workers Fit for Work Plan including communicable disease checks; o Injury Management and Rehabilitation Plan; o Heat Stress Management Plan; o Mobile Equipment Use and Inspection Plan; o Site Vehicle Inspection; o Project HSE Standards and Procedures; o H&S Management System documents including:

· H&S Induction documents including H&S handbook;

· Risk Assessments. Task specific – Method statements can have risk assessment appended to the document;

· Permits to Work;

· Weekly and Monthly Safety Report Template;

· Mandatory Incident Report Template;

· Project Emergency Contact List;

· Project Map; and

· Activity Planner.

· The EPC Contractor shall keep a log of both training records and safety incidents including near misses;



· All construction plant and equipment used on or around the work area will be fitted with appropriate safety devices. These will include, but not be limited to effective safety catches for crane hooks and other lifting devices, and functioning automatic warning devices and, where applicable, an up to-date test certificate, for cranes and hoists;

· Zones with noise levels above 80 dBA shall be marked with safety signs and appropriate PPE must be worn by workers;

· Portable toilet facilities for workers at work sites shall be provided;

· Barricading of all areas of excavation greater than 2 m deep along with warning signs;

· Ensure sufficient fresh air supply to confined workspaces;

· Keep air inlet filters clean and free of dust and microorganisms;

· Ensure reversing signals are installed on all construction vehicles;

· Implement fall prevention and protection measures whenever a worker is exposed to the hazard of falling more than two meters or falling into operating machinery or through an opening in a work surface. (Note: fall prevention / protection measures shall include installation of guardrails with mid-rails and toe boards at the edge of any fall hazard area, proper use of ladders and scaffolds by trained employees, use of fall prevention devices, including safety belt and lanyard travel limiting devices to prevent access to fall hazard, fall protection devices such as full body harnesses);

· Mark the areas where risk of injuries from falling objects exist with rope or flagging to minimize risks and injuries;

· Provide spotters. Employ flag persons to control traffic when construction equipment is entering or leaving the work area;

· All Project subcontractors shall be supplied with copies of the H&S Plan. Provisions shall be incorporated into all subcontracts to ensure compliance with the H&S Plan at all tiers of subcontracting. All subcontractors will be required to appoint a safety representative who will be available on the site throughout the operational period of the respective subcontract unless TPCL approval to the contrary is given in writing. In the event of TPCL approval being given, the EPC Contractor shall ensure, as far as is practically possible, that employees of subcontractors of all tiers are conversant with appropriate parts of the H&S Plan. To implement the above items, the EPC Contractor shall designate qualified environmental, H&S personnel.

· Water supply. If groundwater or surface water is to be used as potable water, it shall be tested prior to use and weekly thereafter to ensure that the water quality meets drinking water standards.

· Socio-Cultural Management Plan

- A Workers’ Code of Conduct that include communication and behaviour protocol related to socio-cultural values and promote cultural awareness to reduce cultural clashes and misunderstandings in the workplace as well as with neighbouring communities and community members. This is particularly important in today’s multicultural environment. It can help prevent cultural conflicts and allow workers to better deal with each other;



- Policies limiting interactions between foreign workers and the communities, particularly after hours;

- Contract bilingual staff to help ensure the participation of ethnic, linguistic, and cultural minorities in the workplace;

- Local socio-cultural knowledge and skills as job requirements for Project staff, in addition to Project induction and awareness creation;

- Time provision to have discussion on socio-cultural values and differences and how to manage it;

- Training in conflict prevention, resolution, and other negotiation mechanisms that can avoid socio-cultural clashes;

- Training of key Project officials in cultural sensitivity to better enable them to manage procurement, service delivery, communications, and conflict-resolution mechanisms; and

- Recruitment of Project team members that are able to speak the language of Affected Persons to ensure efficient and effective community consultation and participation.

· Communicable Diseases: To mitigate the potential for communicable disease transmission, the following key measures targeting workers and community members shall be taken:

- As part of the H&S Program, there shall be awareness creation and training modules HIV/AIDS and STD risks and a recreational activity plan to provide for activities outside of working hours. HIV/AIDS awareness and prevention programs shall also be undertaken in communities to reduce the transmission HIV/AIDS and other STD;

- Construction workers shall be instructed and required to comply with a Worker’s Code of Conduct which addresses issues such as anti-social behaviour, drug and alcohol consumption, HIV/AIDS, weapons, and respect for women;

- Construction workers shall be required to complete health screening to minimize the spread of communicable diseases. Health screening for all workers shall include active tuberculosis (TB). Where workers are handling food or water production and distribution the workers shall have received typhoid and Hepatitis A (full series) vaccinations, in addition to TB vaccination. At least the first inoculation in the Hepatitis A series must be given prior to the start of employment, with continuation and completion of the inoculation series. Once the complete Hepatitis A vaccination series is completed, it does not have to be repeated. Typhoid inoculation shall be completed within two years prior to the date of employment in the food and water service capacity. Typhoid vaccination shall also include periodic booster immunization as required. Proof that employees and contractor employees have received vaccinations shall be provided to TPCL. The contractor shall maintain their employees’ vaccination records for examination and make these available for inspection as required;

- Vector borne diseases such as malaria should also be controlled by awareness creation and not allowing standing water in trenches or in camps; and

- Awareness creation on prevention practices to ensure safe drinking water, health and hygiene, sanitation, and solid waste management needs to be promoted



This could readily be extended to cover advice on pre-natal and post-natal care to benefit women in the local communities.


Socio-economics

· The EPC Contractor should develop and implement a Traffic Management Plan to address construction traffic and reduce the potential for accidents. This will include information related to vehicle maintenance, equipment transport by phase, schedule, signage and control, hours and volume of equipment and worker transport, lighting conditions, driver safe driving training requirements, material movement, areas of restricted carriageway width, haul routes, speed limits and separation distances, geotagging to track road speed, reversing alarms, limiting working hours, limiting driving after dark, accommodating the needs of local residents, record keeping, driver training, and inspections;

· Community Emergency Response Plans addressing traffic incidents and potential releases of chemicals and other hazardous materials will be developed, tested, and implemented throughout construction. Plan testing will involve workers, public sector agencies, and residents in the vicinity of Project-related traffic. Response plans will address traffic accidents, the potential releases of chemicals, and other hazardous materials and fires. The contractor shall involve external stakeholders (such as the police and local authorities) in any on or off-site security incidents and ensure that appropriate incident response procedures are implemented; and

· Major road and railway crossings will be undertaken using trenchless methods to minimize disruption and damage to major roads and railway lines.


Socio-economics

Measures implemented to mitigate this impact will help to avoid additional conflict, but will not alter the firmly established social systems. The following documents will be key to managing this issue:

· The Community Emergency Response Plan (CERP) as part of the CHSMP should be developed and tested to determine effectiveness of protocols related to each of the three potential conflict groups described above. The contractor shall involve external stakeholders (such as the police and local authorities) in any on or off-site security testing or actual incidents and ensure that appropriate incident response procedures are implemented;

· The Human Resources and Workers Management Plan (HRWMP) as well as the Local Content Plan (LCP) should clearly articulate and communicate how hiring will occur. Transparency in implementing hiring to engender equal opportunities is essential;

· The Worker’s Code of Conduct should mandate appropriate behaviour requirements for all staff within the Project area and external to it during the Project construction period;

· Grievance Mechanism implementation and monitoring is essential to understanding if the Project is exacerbating any existing conflicts or creating any new clashes between ethnic groups, workers and/or villages. Urgent action will be required in the event of complaints being made in relation to conflict between groups; and



Unskilled labour should preferably be selected via a ballot system to ensure that the selection process is fair and equitable. It is also advisable that unskilled labour workers stay in one Lot and are not moved to other parts of the country as it may create tension with locals who are in need of employment.


Socio-economics


The positive impacts associated with employment and economic development should be monitored throughout construction to ensure that sourcing is occurring locally (as expected) and to identify/maximize opportunities for additional local development. There are several key measures that should be conducted simultaneously in support of this impact.

· Local Consultation

- Consultation with local residents along the pipeline route will be conducted post the ESIA process, prior to commencement of the construction hiring process.

- The Project plans to engage CLOs in all districts to assist in the direct communication and engagement of local residents. This will enable sharing of information on available positions and the Project’s policy on fair and equitable employment and recruitment practices.

- The CLOs will also allow for the sharing of grievances, should they occur, in relation to employment and recruitment. The aim of this is to ensure that all villages affected by the Project are able to share concerns, along with being provided with feedback on how the Project is approaching employment and equitable benefit sharing with those directly impacted.

· Outreach to Potential Employers: To ensure local participation, contractors and subcontractors shall be required to:

- Comply with requirements of the Project’s Human Resources and Workers Management Plan and LCP;

- Hire local staff as far as possible to support construction and as part of supply chain provisions and;

- Regularly report on the local hiring compliance.

- This requirement shall be included as part of the Project’s procurement commitment. Contractors shall also be required to identify the number of positions and skills necessary as well as the steps to be taken to ensure compliance with this provision. Contractors shall designate a person to lead this local hiring initiative, with responsibilities including the collection of employment information and leading the outreach program. In addition to the Project’s Human Resources and Workers Management Plan and LCP, the contractor shall provide training and support to the workforce and ensure that vulnerable people benefit equitably with other people from the general population.

· Engagement with Potential Workers and Vendors

- The Project’s SEP, Human Resources and Workers Management Plan, and LCP shall be used to engage with and inform relevant stakeholders (such as local leaders) of employment opportunities.

- It shall also be done through awareness creation within Project affected communities including verbal announcements (such as through focus group and other meetings) and by providing culturally (language and literacy) appropriate materials.



- There should be a unique focus and emphasis on conducting outreach to high unemployment level groups (such as youth) and vulnerable people.

· Local Workforce and Development Monitoring and Evaluation: Prior to construction, an LCP shall be developed that shall address the following as a minimum:

- Responds to government regulations or investment agreements stipulating local content levels and percentages;

- Includes requirements of any agreement reached between the Project and the host country on local content (such as percentages related to skilled, semi-skilled and unskilled workers);

- Includes the requirements for engagement and the context in which the various tribes / communities need to be engaged in employment and procurement;

- Include the activities of:

workforce development (employment of local workforce, skills development and training of the local workforce);

investment in supplier development (developing supplies and services locally);

procurement of supplies and services locally (creating business opportunities with local enterprises for economic development);

training to local businesses to produce goods and services that meet the standards and requirements of multinational operators;

developing a retrenchment plan;

create opportunities to consistently renew the Project’s license to operate;

develop and implement a mobilization plan

develop and implement a demobilisation plan (as skills and training already starts during construction)

- Enhance engagement with stakeholders; and

- Manage and monitor implementation of LCP.

PAK-01-32 Commissioning,

Start-up and Operation

Socio-economics

· Local Labour Targets

- It is advisable that the target to employ local people is raised.

- For unskilled labour it should be very high (80% or higher).

- There should also be a gender element, if possible and subject to the security and safety of women, for camps.

- For unskilled workers, a ballot system could be used to ensure the employment system is fair and equitable.





Socio-economics

· A Nomadic Peoples Seasonal Migration Management Plan should be developed prior to construction to include the following mitigation measures as a minimum:

- Construction works should be timed where possible to avoid seasonal migration routes, or steps should be taken to identify alternative migration routes or ensure safe passage across the ROW;

- Alternate routes could be in public or community spaces when current routes are under construction; and

- In addition to coordinating with nomadic groups, the coordinator should collaborate with community councils, religious networks, or civil service organizations serving indigenous communities to help communicate impacts.

· Mitigation measures for this impact are aimed at avoiding or reducing negative impacts on communities and on planning and implementing a robust community engagement program. The ADB (2013) recommends 1) integrating social interventions at a community level in Pakistan versus focusing measures at an indigenous group or subgroup level, and 2) recognizing that the tribal context and expectations mandate heightened consultation and participation. This will prevent conflict that may be caused by focusing on ethnic or indigenous distinctions.

· As part of the TPMP, a robust construction and nomadic migratory schedule should be developed.

· An onsite nomadic crossing coordinator should conduct a census of nomadic groups crossing the two provinces to determine whether construction timing coincides with winter and summer migratory seasons. Following this determination, the coordinator should undertake engagement and/or outreach sessions one season in advance of construction into provinces through which construction will occur and migrants will be crossing.

· The coordinator shall engage with local elders within construction Lots to identify possible passageways and negotiate passage during construction.



Socio-economics

As part of the Gender Management Plan, Human Resources and Workers Management Plan, and LCP developed for this Project, the EPC Contractor shall integrate opportunities for disadvantaged persons and persons with disabilities. These plans should provide opportunities for women and women’s groups to participate in the work force to the extent safe and practical, and assist them in having good quality work standards so that they can train others and are able to work with other companies or government agencies in the future.

· The Gender Management Plan shall be developed to include the following mitigation measures as a minimum:

- Ensure that women and girls are provided a safe space where they can fully participate in Project engagement and consultation;

- Establish appropriate hours and locations of meetings that allow women to participate (taking onto account that it should be culturally appropriate);



- As far as possible, given security and socio-cultural constraints, influence/inform authorities responsible for the LAP, to explicitly consider and compensate for loss of land experienced by women and girls who do not have control over their income;

- As far as possible, develop employment opportunities that prioritize equal opportunities for women’s training schemes to ensure women have the basic skills necessary for employment;

- Establish codes and training for staff prohibiting the provision of transportation or rides to community members to minimize perceptions of inappropriate behaviour or additional risk to women and children;

- As far as possible, given security and socio-cultural constraints, ensure requirements for contractors explicitly state recruitment of women, as well as equal amount and form of pay, occupational H&S support, and anti-discrimination/ abuse contracts;

- As far as possible, given security and socio-cultural constraints, provide support for female contractors to obtain any certification or formal registration needed;

- As far as possible, given security and socio-cultural constraints, alter schedules or timelines allowing women entrepreneurs to provide services at convenient times (deliveries during the day etc.); and

- As far as possible, given security and socio-cultural constraints, provide transportation support if female subcontractors do not have their own access and negotiate rates to counter cost of fuel etc. at cost.

· As part of the Human Resources and Workers Management Plan developed for this Project, the EPC Contractor should:

- Integrate opportunities for women and persons with disabilities where wherever it is safe and culturally acceptable to do so.

- All gender focused initiatives will, as the first priority, take into account women’s security. Security for women is TPCL’s primary concern and all opportunities for including women in the workforce must first be screened against TPCL’s Security Plan.

- Where such opportunities are approved safe for women, good quality work standards are to be provided.

· As part of the Community Development Plan, TPCL shall:

- Consider developing training programs for women and persons with disabilities, with the aim of increasing their future employment opportunities.

- Training should as far as possible include food and health safety standards courses and other technology training programs. These shall be offered as an in-kind compensation measure that will help them to establish new and/or improved livelihoods.

- Short-term vocational training will be offered to eligible households for an agreed amount and period of time.

· The Project’s SEP shall be reviewed regularly, ensuring that consultation with affected communities continues and that the needs of vulnerable community members, are considered.

· Additional livelihood restoration support for vulnerable parties, including women, which are economically displaced by the Project, shall be provided.



· Within the PAI, female-headed households were reported to be 0.34%, which is much lower than the national average. Given the need to safeguard female-headed households and women in general, the recommendation is that a gender specialist to be retained as part of the LAP and LRP.

· TPCL should also consider health intervention to increase the immunization coverage in the TAPI pipeline districts with lowest indicators of immunization. This could readily be extended to cover advice on pre-natal and post-natal care to benefit women in the local communities.

· Overall, vulnerable groups may require additional measures to obtain compensation and Project benefits. Targets should be set for the EPC Contractor to employ people from disadvantaged groups.

PAK-01-35 Operation Socio-

economics

· Abstraction from the Sutlej River, in particular, needs to be timed when flows exceed 5.0 m3/s, so that no more than 10% of the river flow is removed. The 10% criterion is for guidance only and should be discussed and agreed with the appropriate agencies. The river needs to support other abstractions and support fisheries and the abstraction should not result in a deterioration in the ecological health of the surface waters or groundwater. Abstraction should also meet the criteria specified in Impact SEPAK04.

· This may limit abstraction and hence hydrotesting based on river water use to specific times of the year. Gauging of the rivers upstream of the point of abstraction should be undertaken to confirm that the abstraction is not adversely reducing the river flow and exceeding the agreed criteria. Abstraction from and discharges to all rivers should meet the requirements of the national and local agencies.

· The following measures specific to hydrotesting should be included in the Project’s Occupational H&S Plan:

- Hydrotesting can be hazardous in nature due to the high pressures and flows of water involved. A hazard assessment must be undertaken for this activity and any other hazardous activity identified. This would likely include designation of a safe zone and appropriate signs and barriers, never tightening fittings under pressure and wearing hearing protection;

- Hydrotests will predominately be located at a minimum distance of 500 m from local communities. Noise impacts for hydrotesting will be mitigated by measures outlined in the Noise and Vibration Management Plan and to a lesser extent through the Hydrotest EMP.

- The Grievance Mechanism will be monitored to understand if complaints are made in relation to water supply affects from abstraction of hydrotesting water, and any issues shall be dealt with as a matter of urgency.

- Also refer to mitigation measures related to hydrotesting water abstraction in Section 7.5. Ecology and Biodiversity Impact Assessment.


economics

· Proactive outreach with potentially affected settlements, particularly within 10 km, is essential to reducing the potential shock to human hearing. It is recommended that clear and early communication and consultation with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken. TPCL’s contractor should provide guidance to affected populations based on H&S risks.



· There will be challenges in reducing some of the commissioning/start-up noise levels through mitigation. In particular, noise events occurring during hydrotesting activities due to the small distance between the receptors and activities. It is however anticipated that the high-pressure discharges during hydrotesting are one-off events at a given testing pipeline section and in general the commissioning/start-up works would be moving along the pipeline route alignment. Thus, the impact would be at a single location for a short period of time.

· The equipment to be used for hydrotesting is not defined yet. It is however recommended to choose quiet equipment/methods such as condensers, water injection or discharging into water as well as to fit silencers into the equipment. For this reason, these activities can be classified as temporary with reduced impact significance.



economics


· To enhance local opportunities, TPCL should implement a long-term training program to increase the level of local employment from the anticipated 5% to 10% during the first 2 years of operation.

· TPCL shall ensure that local employment opportunities are included in the LCP prior to hiring commencing. The LCP shall include long term training for operational staff as a component of its capacity building initiative.


economics · The eventuality of a H&S incident related to the pipeline shall be addressed in the previously recommended

Community Emergency Response Plan.


economics

· A key mitigation measure is to engage in relationship building with key stakeholders along the PAI, providing community development/investment to affected communities. This will increase the sense of ownership and, combined with the pledged protection, will provide for pipeline support. Access to the pipeline ROW may be restricted to limit this risk.

PAK-01-40 Decommissioning Socio-

economics

· Contractors should implement GIIP measures to maintain the noise levels at fence line and maintain noise emissions at as a minimum level as practicable.

PAK-01-41 Pre-Construction, Construction and Decommissioning

Archaeology and Cultural

Heritage

· Although the survey team identified only one karez system (the Inzargai Karez System) during the field survey, there is potential for a number of other karez systems to be present along the pipeline route. A pre-construction survey dedicated to investigating the Khojak Tunnel, the Inzargai Karez System, along with any as-yet unidentified karez systems will be required. This will inform the need for any relevant rerouting or engineering solutions required as part of the detailed design process;



· In the case of the Khojak Tunnel, the Inzargai Karez System, and any as-yet unidentified karez systems, care will be taken during the pre-construction activities to ensure that the pipeline does not cross the path of the tunnel or karez system;

· In relation to the Tomb of Hazrat Shah Yousaf and the Naqiba Abad Archaeological Mound, these sites should be avoided by the pipeline route. There is ample flexibility within the 500 m corridor to strategize accordingly. It is recommended that caution be taken to avoid any damage to these sites and structures, including any indirect damage from vibration;

· If the identified sites cannot be avoided, the Project and their contractors must work with the relevant national authorities to understand whether affected sites can be reinstated following construction and the impact that this will have on the overall value of the site;

· If anything gets unearthed during the excavations of the pipeline, either known or unknown, the incident must be recorded fully, authorities contacted, and the discovery and its location must be documented;

· The results of the baseline survey (NAFTEC/MAB’s subcontractor, 2018) should be considered for the pre-construction planning and management process;

· TPCL will undertake GIS-based predictive modelling prior to construction, and provide the EPC Contractor with GIS mapping layer showing relative likelihood zones of archaeologic area, features, or artefact being present prior to construction; and

· The EPC Contractor shall develop a Cultural Heritage Management Plan (CHMP) and a CFP to define management measures for archaeological and cultural heritage impacts. The CHMP will include the GIS-based predictive modelling mapping undertaken by TPCL. The CHMP and CFP shall be developed in accordance with the frameworks provided in Appendix F.

A Chance Finds Procedure (CFP) is a Project-specific procedure that outlines the actions to be taken if previously unknown cultural heritage is encountered. The implementation of the CFP is a crucial mitigation measure and considered good management practice for potential impacts of the Project on known and unknown cultural heritage resources.

· In addition to being required to meet international good practice, the CFP also follows the 1975 Antiquities Act, under which the Project Proponent is obligated to:

- Ensure that no activity is undertaken in the proximity of a protected antiquity, within 200 m of protected sites unless prior permission has been obtained from the Federal Department of Archaeology and Museums; and

- If during the course of the Project an archaeological discovery is made, it shall be reported to the Federal Department of Archaeology and Museums.

· The CFP will be communicated to all construction and site staff and be included in all training.




and Start-Up


Heritage


· Tangible assets that have been avoided during the construction phase may be impacted by commission/start-up activities. Therefore, the direct and indirect avoidance of such resources should be planned and implemented into all Project phases.

PAK-01-43 Operation Archaeology and Cultural

Heritage

· The implementation of a CFP as a mitigation measure and good management practice for potential impacts of the Project on known and unknown cultural heritage resources should continue to be followed into the operation phase. Tangible assets that have been avoided during the construction phase may be impacted during operation activities, such as maintenance vehicle access. Therefore, the direct and indirect avoidance of such resources should be planned and implemented into all Project phases.

· Assets with the potential to be impacted during operation activities should be protected and clearly demarcated for continued Project avoidance and protection from vandalism or looting, and natural gas venting locations should take into consideration the location of heritage resources as to be downwind from resources. Also, avoidance and care should be taken to avoid accidental spillages and over-extraction of water resources in the area, to avoid differential ground settlement, as detailed in the ESIA Section 7.4. Physical Environment Impact Assessment.

PAK-01-44 Decommissioning Archaeology and Cultural

Heritage



Landscape and Visual

Measure that will be carried out to minimize impacts will be included in the Landscape and Visual Impacts Management Plan (LVIMP) and are detailed below:

· high standards of construction site practice and good housekeeping should include the tidy storage of materials and unused machinery in laydown areas, and the appropriate handling of waste, to limit degradation in views towards the works;

· construction camps should be organized to keep elements that would cause an impact over long distance (such as scattered materials and machinery, and reflections off vehicles) within compounds and screened from the outside. Topsoil heaps could be used as effective ground-level screens to this end;

· appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen), taking into account that the security requirements for lighting take precedence over landscape and visual impact mitigation. While glare will



notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;

· buildings introduced into the landscape due to the non-CS AGIs in Phase I shall, as far as practical, be coloured appropriately to minimize their visual prominence within the surrounding landscape, taking into account safety engineering requirements, cultural context, and community consultation;

· local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of modern materials (through reduction), and to screen ground-level views of industrial elements; and

· audits will be conducted to verify the continued implementation of the LVIMP, to ensure mitigation measures are being carried out as required;

· Additional measures for impacts on the Sulaiman Mountains include:

- tracks and roads create distinct scars across the Sulaiman Mountain landscape, whose floor-plain has a consistent naturalized texture formed by rocky slopes, gravel, and alluvial soil. Therefore, all temporary tracks and roads within the Sulaiman Mountains should be reinstated following completion of their use, whether this be the reinstatement of alluvial topsoil, or the rocky crust of the slopes;

- topsoil (or the equivalent rocky layer) should be returned as close to its original source as possible, and in all cases, should match the appearance of the adjacent ground;

- these areas should be left to naturally vegetate to ensure a consistency of native plant communities and to avoid likely long-term failures in planting;

- reinstatement should occur for any laydown areas, construction camps, and pipe yards that are no longer in use; and

- In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state;

· Additional measures for impacts on the landscape of the Indus Plain include:

- tracks and roads (including temporary roads), construction camps, and pipe yards should be arranged to sit within the north/south-east/west grid of the Indus Plain, rather than breaking the strong land pattern. This will increase the success and speed of reinstatement works and minimize impact while the elements are still present.

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s Environmental and Social Management Action Plan [ESAP] for discussion with Pakistan authorities) to define erosion control mitigation measures.

· These management plans, when combined with the reinstatement measures developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized. The management plans shall be developed in accordance with the frameworks provided.




PAK-01-46 Operation Landscape and Visual

Mitigation measures for impacts due to the pipeline trench /corridor are as follows:

· The pipeline trench and applicable areas of the ROW shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope, with existing topsoil (or equivalent rocky layer) being returned, as close as possible, to its source and stored appropriately during construction;

· Reseeding should be used where appropriate to speed up the reinstatement process; and

· Native plant communities shall be allowed to revegetate naturally, so as to avoid noticeable changes in vegetation make-up across the landscape and to avoid potential long-term failures in planting.

Mitigation measures for impacts due to industrial elements are as follows:


· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of exposed machinery and modern materials (through reduction) on the rural landscape, and to screen ground-level views of industrial elements;

· Apply locally appropriate screen planting and site arrangements for the AGIs at the Indus Plain;

· Lighting shall only be used when required and shall be directed at the areas where it is needed, to minimize light pollution at a distance from direct shine and diffuse glare (including the use of LED rather than the highest lumen bulbs like halogen), limiting the installation’s visibility over long views in day and night; and

· Lighting shall take into account that the security requirements for lighting take precedent over landscape and visual impact mitigation.

Additional mitigation measures for impacts due to Operation of Phase I AGIs on the Landscape of the Indus Plain are as follows:

· AGIs within the Indus Plain shall be arranged to sit within the existing north/south-east/west field pattern, with locally appropriate tree and shrub planting installed around the perimeter, and within site boundaries, to screen industrial elements; and

· Planting should be considered at the AGIs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the AGIs within the fence line, if security permits.



PAK-01-47 Decommissioning Landscape and Visual


· Construction camps should also be organized to keep elements that would cause an impact over long distance (such as scattered materials and machinery, and reflections off vehicles) within compounds and screened from the outside. Topsoil heaps could be used as effective ground-level screens to this end;

· Appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen), taking into account that the security requirements for lighting take precedent over landscape and visual impact mitigation. While glare will notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;



· All temporary tracks, construction camps, and working areas shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope to avoid un-naturalistic scars being left across an open landscape whose character is often driven by large-scale uniformity in colour and texture;

· Existing topsoil shall be returned, as close as possible, to its source and stored appropriately during decommissioning (in stacks of 1.5 m high or less); and

· Reseeding should be implemented following return of topsoil across where needed, with native plant communities allowed to revegetate naturally at reinstated ground, rather than being planted, to avoid noticeable changes in the vegetation make-up across the landscape and to avoid likely long-term failures in planting.

Additional mitigation measures specific to impact

of Decommissioning Activities on the Landscape of the Sulaiman Mountains are:






· Reinstatement should occur for any laydown areas, construction camps, and pipe yards that are no longer in use; and

· In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state.

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s ESAP for discussion with Pakistan authorities) to define erosion control mitigation measures.

· These management plans, when combined with the reinstatement measures developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized.


· Noise control through the use of best practice machinery and working methods, as described in the ESIA Section 7.3. Noise and Vibration Impact Assessment, should be implemented to minimize the impact of works on the local landscape.


Climate Change

Climate change mitigation measures to be included in a Project-specific Climate Change Management Plan (CCMP) shall include, but are not limited to, the following:


· Detailed design is to include the development of a Climate Change Risk Design Review Procedure for Operations, specifying the engineering design review to be undertaken every five years of operational life to check that the Project design is operating with design parameters following update of the climate risk assessment (refer to operation phase mitigation measures outlined in the ESIA Section 7.9.3.7);


· Assess the use of alternative fuels (such as CNG, LNG, LPG, and biodiesel) versus diesel and petrol;


· Source energy efficient lighting (such as LED) that must also meet security and ecological requirements.


· Encourage the regrowth and revegetation of the pipeline ROW, with measures such as seeding with local grass species or returning to agricultural use, re-spreading topsoil and cleared vegetation to encourage growth from the natural seedbank, and replanting in high-risk areas where stability needs to be rapidly achieved;






· Clear the minimum amount of vegetation for ROW clearance;

· Progressively rehabilitate land cleared for construction, especially exposed soils;

· Maximize the amount of land revegetated;

· Minimize the volume of natural gas released during venting; and

· Consider good quality biodiversity offsets for land cleared.


PAK-01-49 Operation Climate Change

Mitigation Measures for Greenhouse Gas Emissions Contributing to Climate Change are as follows:



· Regular corrosion and leak detection monitoring, intelligent pigging, and regular patrols to check for leaks and undertake prompt repairs. This is important around pressure relief valves, compressor seals around rod packing, connectors, and pneumatic controllers;

· When carrying out pipeline blow-down activities for pipeline maintenance, consider using pipeline pump-down techniques. These involve using in-line compressors either alone or in sequence with portable compressors. This removes the natural gas from sections of the pipeline before maintenance or repair. This will reduce GHGs associated with natural gas venting;

· Re-evaluate the design considering the potential for increases in future scour due to projected increases in peak stream flows;

· Re-evaluate the design considering the potential influence of climate change on channel migration;

· Re-evaluate the design considering the potential influence of climate change related changes to groundwater conditions on buoyancy;

· Re-evaluate the design considering the potential influence of climate change on soil stability; and





6.3 Phase II Commitments Register

Table 6-2 – Phase II Commitments Register

· Every five years update the climate risk assessment provided in Section 6.9. Climate Change Baseline based on the most recent Intergovernmental Panel on Climate Change (IPPC) data;

· Following update of the climate risk assessment, undertake a Climate Risk Assessment Design Review based on the procedure develop with the detailed design. The review should include, but is not limited to, the following:

- re-evaluate the design considering the potential influence of climate change on soil stability;







Commitment Reference

Project Phase Category Copy of Original ESIA Text


· Maintenance and inspection of diesel generators according to manufacturer’s instructions;

· Ensure all machinery is properly maintained in accordance to equipment maintenance requirements;


· Wind fences should be considered where appropriate; and

· Road stabilization by use of soil-crete (soil mixed with cement or soil mixed with lime).


· Pre-notification of critical dust producing activities and implement Community Liaison procedures;



· Dust suppression using watering can be achieved using camp grey water. Alternatives include wood chips and calcium chloride, or other environmentally safe products developed for this specific use. Dust suppression material should not scar the area and prevent vegetation growth (salt for example is not acceptable);







· Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery;



· Dust suppression techniques should be implemented, such as applying water (for example, grey water from camps, subject to meeting WHO grey waster guidance WHO-EM/CEH/125/E2006) or non-toxic chemicals to minimize dust from vehicle movements.

For AGIs and temporary facilities the following additional mitigation measures may be applied on an as-needed basis:


· Imported construction material stockpiles should be located away from sensitive receptors.

PAK-02-03 Commissioning and Operation

Air Quality

· The FEED emission studies (TPCL, 2017a, 2017b, 2017c) have reported NOx emissions of 320 mg/Nm3 for a fired heater and 200 mg/Nm3 for a power generation unit. It is therefore proposed to remove the fired heaters from the design to reduce the NOx emissions significantly. However, it must be noted that this is representative of a worst-case maximum capacity emission scenario defined at a preliminary design stage, and actual emissions from Project units are likely to be lower.

· Detailed engineering design should perform a BAT analysis to selected what are best technologies that could be included in the design of the AGIs, to minimize NOx emission from power generation units.


Noise and Vibration

Noise associated with operation of the Compressor Stations

· Contractors undertaking the activities should follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSR below the permitted limits. The same mitigation measures listed for construction works during Phase I are applicable to Phase II.

PAK-02-05 Operation Noise and Vibration

· The same mitigation measures listed for the operational impacts during Phase I are applicable to Phase II.

PAK-02-06 Decommissioning Noise and Vibration

· The contractors undertaking the activities are required to follow GIIP measures to minimize the effect of noise and maintain the noise levels at the fence line and NNSRs at minimum as practicable. Mitigation measures set out for the Construction Phase would be also applicable during decommissioning.



· Ensure that the required CESMP, including the various management plans (SECP, WCMP, SPRP, HMMP, WMP, HDD EMP, EMRP, SEP) are in place prior to commencement of construction works;

· Implement erosion control measures as detailed in the Construction Concept Reinstatement Plan developed for the Project. Reinstatement will include slope stabilization, erosion protection, surface



reinstatement, and bio restoration. Subsoil will be levelled to its original contour or as determined by operational requirements;

· Develop a SECP to support the Reinstatement Plan with specific measures to mitigate impacts, including but not limited to:

- minimize disruption when soil stripping and storing materials. This can be achieved by keeping the footprint of the proposed works to a minimum to minimize impact on the soil quality in the wider area;

- revegetate immediately after construction to limit erosion processes;

- manage the removal and storage of topsoil, subsoil, and any parent material to facilitate the reinstatement stage;

- the first layer of excavated material (topsoil) will be stored separately so that it can be replaced on the surface when the excavated area is restored. Implement appropriate storage of fertile topsoil separately from less productive sub soils. Topsoil from the trench is removed and stored separately from other excavated material, so that it can be used for re-vegetation after the pipe is laid and the trench back-filled;

- to minimize the risks of soil structure destabilization and surface soil compaction, avoid construction activities during high rainfall events;

- protect topsoil/subsoil stockpiles from run-off. Topsoil storage periods will be kept to a minimum;

· The Water Management Plan shall include, as a minimum, the following measures:

- monitor discharged waters from dewatering activities to be sent to an approved disposal site, such as an evaporation pond / lagoon or river, depending on water quality and chemical composition;

- careful selection of the groundwater abstraction points should be made in order to ensure low sensitivity of the receptors in terms of water availability;

- careful management and control of the groundwater table will be implemented in cases where dewatering is necessary to minimize effects of groundwater level changes;

- monitoring of water levels and flow of the abstraction points should be conducted as appropriate to ensure that abstraction is not causing a net decline in the amount of water

- any discharge shall be approved by competent authority;

- should temporary construction dewatering be required ensure appropriate discharge measures are taken, especially in sensitive areas. Specific attention for risk of spills, contamination in areas with fresh groundwater resources in river valleys with shallow aquifers (to prevent both surface pollution or pollution of groundwater resources);

- intercept and treat run-off from the construction working area for example by using sandbags;



- minimize water consumption as much as possible, by training the workers in personal minimization and recycling practices;

- an abstraction assessment should be performed in advance to determine the volume of abstraction from each intended source, ensuring that the abstracted volume does not have a long-term impact on water levels and / or negatively impact existing water users

- negotiate water offtake with communities / authorities (as applicable);

- desalinate saline groundwater rather than using scarce freshwater;

· The SPRP shall include, as a minimum, the following measures:

- ensure that all fuel is stored in appropriately lined (e.g., double-skinned tanks) and / or bunded areas with containment systems;

- staff must be trained in the use and maintenance of all equipment on site, particularly those that could result in accidental spillages and leaks of fuels and chemicals which will affect soil and groundwater quality;

- specify a monitoring plan to detect leaks / spills and have staff trained in emergency response to deal with any such incidents if they occur;

· The Waste Management Plan shall include, as a minimum, the following measures:

- the EPC Contractors shall manage all solid and liquid wastes, including general refuse from site workers and construction wastes and hazardous wastes, generated during the construction works. Measures shall be put in place to ensure that solid or liquid wastes are not disposed of outside the construction areas;

- general waste generated on-site should be stored in enclosed bins and normal waste streams separated from hazardous;

- hazardous wastes will be stored in a secured area (to prevent vandalism, theft, accidents) and be within a covered area to prevent the ingress of rain;

- provision will be made logistically with the authorities and a local contractor to remove general refuse from the site on a daily basis to minimize odour, the attraction of pests, and litter impact;

- avoid dumping hazardous waste in a general landfill; and

· When servicing machinery, ensure waste oils, grease, and filters are placed in sealed containers and then preferably taken to recycling facilities or designated repositories.


Environment

Impact on soil, groundwater and surface water due to accidental spills/leakages:

· Mitigation measures as detailed for Phase 1 operations apply.








· Restore soils and native plant community (or comparable crops where applicable) in areas subject to temporary impact;


· Develop and implement a BMP, which will be made up of the flora and fauna management and monitoring fauna management as per Chapter 10. Preliminary ESMF. The BMP will include an assignment of relative biodiversity quality to the remote sensing and a refinement of the characterization of the balance between natural and modified habitats for the purpose of defining biodiversity restoration and offset needs. If additional field data cannot be collected, an assumption regarding the average level of degradation will need to be adopted to account for the uncertainty associated with the natural category;

· Prior to commencement of the construction activities, qualified ecologists are to further document areas within the construction corridor defined in Section 6.5. Ecology and Biodiversity Baseline as natural habitat. The purpose is to support the development of restoration, compensation, and offsetting approaches and ground truth the classification done using remote sensing and transects, confirming: 1) if the areas are natural habitat or should be revised to modified habitat where evidence can be provided of extensive degradation; and 2) if areas classified as potential critical habitat are critical habitat or natural habitat or remain potential critical habitat with supporting evidence. The pre-construction survey should include the following:


o highly representative (3 points);

o moderately representative (2 points);

o poorly representative/not representative (1 point);

(Biological Q-rating for each survey location is assigned based on the sum of the evaluation points across these three criteria, as high [9 points], medium-high [8 points], medium [3-7 points], low-medium [2 points], or low [1 point])









· Offsets for permanent impacts to natural habitat estimated as 87.3 ha. Compensation for permanent impacts of 69.8 ha modified habitat will be addressed through the Land Acquisition Plan and Livelihood Restoration Plan;

· For the loss of natural habitat (this includes potential critical habitat and modified habitat with significant biodiversity values), mitigation must be provided that is equivalent in value. For critical habitat, mitigation must be provided that is greater in value. Tree planting requirements under the Pak-EPA’s environmental approvals must incorporate GIIP for offsetting (IFC, 2015). Two types of offset are acceptable, namely, averted loss and restoration;








· For the design of in-place habitat restoration and biodiversity offsets, consider the habitat preferences of the species for which potential critical habitat and potential critical habitat has been identified (Table 7.5-9), and any additional CR, EN, or endemic species identified during the ongoing construction surveys;



· Project Net Positive Biodiversity Benefit will be included as potential objective as a topic to be investigated in the Community Development Framework, Local Content Plan, and Human



Resources and Workers Management Plan. This would likely include increasing biodiversity along the restored section of the ROW and targeted offsetting in areas of critical habitat.







· In areas where the density of animals may be high, construct trench plugs every several hundred m (that is, ramped earth which enables entrapped animals to escape); and

· Adhere to the Traffic Management Plan and Water Management Plan developed for the Project.








· The mitigation measure listed throughout Section 7.5.2 of the ESIA should be undertaken. Based on the information gathered to date, a Project Net Positive Biodiversity Benefit in relation to the habitat for Desert Wolf will be required. For the Balochistan Forest Dormouse, based on pre-construction survey results and habitat classification review, natural habitat restoration will either be equal to greater than the area impacted and incorporated into the BMP objective of Project Net Positive Biodiversity Benefit.

PAK-02-13 Operation Ecology and Biodiversity



Implement the noise and vibration mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment.

PAK-02-14 Decommissioning Ecology and Biodiversity





· Restore soil and the native plant community in CS footprints;



· Implement the noise mitigation measures described in Section 7.3. Noise and Vibration Impact Assessment.


Socio-economics

· The mitigation measures proposed, if there is physical displacement, are the same as those identified for Construction Phase 1.


Socio-economics

· The mitigation measures proposed for economic displacement, are the same as those defined for Construction Phase 1.


Socio-economics

· The mitigation measures proposed for persons reliant on ecosystem services, specifically land-based resources are the same as those defined for Construction Phase 1.



Socio-economics

· Pre-construction planning shall identify water sources for human consumption and Project use, along with conducting an evaluation of the impacts of groundwater draws by the Project to private and community wells and boreholes. If analyses indicate that reduction in water levels will occur, TPCL must purchase water and transport to the site for use.

· Measures must be taken to prevent damage to irrigation systems which could result in orphaned farmland. Irrigation systems such as karezes are to be reinstated or diverted as necessary to prevent degradation of farmland.

· Should river water be abstracted, the mitigation measures for Construction Phase 1 should be followed.



Socio-economics

· During construction, TPCL must ensure that temporary noise barriers or enclosures are used to reduce noise impacts. Staff are to be instructed in using equipment to minimize noise potential; rubber stops can also be used.

· Proactive outreach with potentially affected settlements is essential to reducing the disruption to local settlements. It is recommended that clear and early communication with local residents is provided along with schedule information in order to make them aware of the activities to be undertaken.






Socio-economics

· Prior consultation must be undertaken with any potentially impacted communities to discuss upcoming works in order to reduce potential conflict;

· TPCL will ensure that any abstractions of water including groundwater for Project use will not impact this resource availability to nearby communities. All abstractions must be permitted by the appropriate agencies;

· TPCL will ensure that the contractor provides for additional medical staff onsite trained in providing emergency services during peak construction periods to provide critical support in the field, avoiding overwhelming local healthcare resources;

· As part of a community investment program and to provide for local institutional capacity building, TPCL should consider providing emergency medicine training to local medical staff who work at facilities within the PAI and donations of equipment and supplies to these institutions;

· The Grievance Mechanism will be monitored to understand if complaints are made in relation to local access to services and infrastructure with any issues dealt with as a matter of urgency; and

· The Project will monitor non-Project related influx into the area to understand if this has the potential to impact upon local services and infrastructure. In the even that this occurs, the Project will work with local authorities to manage this process and minimize impacts where possible.



Socio-economics

· Mitigation measures associated with increased risk of H&S incidents and communicable diseases are the same as those identified for Construction Phase1.

· Mitigation measures associated with impact on facilities, workers, and neighbouring community members due to inter-ethnic and sectarian tension / conflict, are the same as those identified for Construction Phase1

· Enhancement measures associated with employment and economic development, are the same as those identified for Construction Phase1

· Enhancement measures associated with impact on vulnerable groups including women, people with disabilities, and human rights issues, are the same as those identified for Construction Phase1


economics

· The AGIs and other facilities, require specific skills which precludes primarily hiring locally. To enhance local opportunities, TPCL should implement a long-term training program to increase the level of local employment during the first 2 years of operation.

· While unlikely, the eventuality of a H&S incident related to the CSs should be addressed in the previously recommended Community Emergency Response Plan

· Engage in relationship building with key stakeholders in proximity of the AGIs, providing community investment to affected communities. This will increase the sense of ownership and, combined with the pledged protection, will provide for AGI support.



PAK-02-23 Decommissioning Socio-

economics

· Contractors shall implement GIIP measures to maintain the noise levels at fence line and maintain noise emissions at as a minimum level as practicable.



Heritage

· As stated in Section 7.7.2.2 of the ESIA, mitigation measures will largely be required in order to deal with any as-yet unidentified archaeological sites exposed during construction of the CSs. The results of the baseline survey (NAFTEC/MAB’s subcontractor, 2018) should be considered for the pre-construction planning and management process, followed by good management and a Project-specific CFP.

· The implementation of the CFP is a crucial mitigation measure and considered good management practice for potential impacts of the Project on known and unknown cultural heritage resources.

PAK-02-25 Operation Archaeology and Cultural

Heritage


· Tangible assets that have been avoided during the construction phase will not likely be impacted by commissioning/start-up activities, as planning for direct and indirect avoidance of such resources will be implemented during previous Project phases.

· Assets with the potential to be impacted during operation activities should be protected and clearly demarcated for continued Project avoidance and protection from vandalism or looting, and natural gas venting locations should take into consideration the location of heritage resources as to be downwind from resources. Also, avoidance and care should be taken to avoid accidental spillages and over-extraction of water resources in the area, to avoid differential ground settlement, as detailed in Section 7.4. Physical Environment Impact Assessment.

PAK-02-26 Decommissioning Archaeology and Cultural

Heritage


· Protective avoidance barriers that have been placed around tangible assets during the previous Project phases may require repair or replacement


Landscape and Visual





· Appropriate lighting should be used to limit glare and prevent direct shine outward from construction sites (including the use of LED rather than highest lumen bulbs like halogen). While glare will notably increase the construction site’s prominence during the night, direct light will impact upon the wider landscape during the day and night;



· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of modern materials (through reduction), and to screen ground level views of industrial elements.





· In no case should bare and levelled subsoil be left exposed where land is no longer in use, as this will take a prolonged amount of time to recover to a naturalized state;

· Planting should be considered at CSs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the CSs within the fence line, if security permits;




· All temporary tracks, construction camps, and working areas shall be reinstated back to alluvial topsoil, agricultural land, or rocky slope to avoid un-naturalistic scars being left across an open landscape whose character is often driven by large scale uniformity in colour and texture;

· Existing topsoil shall be returned, as close as possible, to its source and stored appropriately during construction (in stacks of 1.5 m high or less); and

· In addition, the EPC Contractor will develop a BMP with mitigation measures for natural vegetation reinstatement and a SECP (including reseeding of applicable areas along the ROW, which is included in TPCL’s ESAP for discussion with Pakistan authorities) to define erosion control mitigation measures. These management plans, when combined with the reinstatement measures developed by the EPC Contractor in the detailed design, will ensure the landscape impacts are minimized.

· Dust control measures as detailed in the ESIA Section 7.2. Ambient Air Quality Impact Assessment should be implemented to reduce the visual prominence of the works across long views. Noise control through the use of best practice machinery and working methods, as described in the ESIA Section 7.3. Noise and Vibration Impact Assessment, should be implemented to minimize the impact of works on the local landscape.

PAK-02-28 Operation Landscape and Visual


· Local materials similar to those used in the existing surrounding buildings (including locally produced concrete blocks) shall be used for construction (where appropriate) and around the periphery of AGIs to reduce the impact of exposed machinery and modern materials (through reduction), and to screen ground-level views of industrial elements;

· Lighting at AGIs shall only be used when required and shall be designed to minimize light pollution from direct shine and diffuse glare (including the use of LED rather than the highest lumen bulbs like halogen), limiting the facility’s visual prominence over long views during both the day and night;

· Lighting at AGIs shall take into account that the security requirement for lighting take precedent over landscape and visual impact mitigation; and

Planting should be considered at CSs within 1.5 km from nearby settlements and where there are visual impacts on sensitive receptors. This planting could include rows of native trees or lower native planting around the CSs within the fence line, if security permits.


Climate Change

Climate change mitigation measures to be included in a Project-specific CCMP shall include, but are not limited to, the following:




· Detailed design is to include the development of a Climate Change Risk Design Review Procedure for Operations, specifying the engineering design review to be undertaken every five years of operational life to check that the Project design is operating with design parameters following update of the climate risk assessment (refer operation phase mitigation measures outlined in Section 7.9.5.4);


· Assessing the use of alternative fuels (such as CNG, LNG, LPG, and biodiesel) versus diesel and petrol;


· Where possible, through technology advances, reduce the production of GHG emissions as a result of construction, through the use of materials and methods with lower carbon footprint.


· Encourage the regrowth and revegetation of the AGI areas that are unused, with measures such as seeding with local grass species, re-spreading topsoil and cleared vegetation to encourage growth from the natural seedbank, and replanting in high-risk areas where stability needs to be rapidly achieved;




· Progressively rehabilitating land cleared for construction, especially exposed soils and maximizing the amount of land re-vegetated;

· Minimize the volume of natural gas released during via venting; and

· Considering good quality biodiversity offsets for land cleared.


PAK-02-30 Operation Climate Change

In terms of compressor performance:

· The CCMP should include both emission reduction and climate risk and adaptation mitigation measures.




· Regular corrosion and leak detection monitoring;

· Conduct regular energy audits for the CSs to ensure compressor turbine operates at peak efficiency;

· Reduce leakage in reciprocating compressor rod packing, replacing packing when expected reduction in leaks will pay back costs; and



· Every five years update the climate risk assessment provided in the ESIA Section 6.9. Climate Change Baseline based on the most recent IPPC data;

· Following update of the climate risk assessment, undertake a Climate Risk Assessment Design Review based on the procedure develop with the detailed design. The review should include but not be limited to the following:

- on soil stability;



re-evaluate the design considering the potential for increases in future scour due to projected increases in peak stream flows.




7 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM

7.1 Introduction

This chapter describes the Project ESMS that has been established by TPCL. As the

Project progresses from FEED to construction and as the EPC contract is awarded,

the various components of this ESMS will be resourced and further developed.

Figure 7-1 shows the process of how the Project ESMS will develop from FEED/ ESIA

through to EPC contract award and construction.

Figure 7-1: Development Process of ESMS

Source: TPCL, 2019



7.2 Objectives

The ESMS is a set of processes and practices to consistently meet the Project’s

objectives. The main objective of the ESMS is to help to assess and control Project

risks and is the key to continual improvement through an ongoing process of

reviewing, correcting, and improving the system. It will mainly be done through the

Plan-Do-Check-Act-Adopt cycle described below:

· Plan – establish objectives and processes required, specifically to identify

and manage the risks related to environmental and social management;

· Do – implement the processes that are designed and minimize exposure to

the risks identified in order to prevent the occurrence employment related

issues;

· Check – measure and monitor the processes and report results against the

objectives;

· Act – take action to improve performance of the management system

based on results; and

· Adopt – adopt a continual improvement process.

7.3 ESMS Elements

As per IFC guidelines (2015), the ESMS includes the following elements:

· Policies;

· Identification of risks and impacts;

· Management programs;

· Organizational capacity and competency;

· Emergency preparedness and response;

· Stakeholder engagement;

· External communications and grievance mechanisms;

· Ongoing reporting to Affected Communities; and

· Monitoring and review.

These are discussed in more detail in the following sections.

7.4 Policies and Policy Objectives

The cornerstone of the ESMS is the Project’s set of E&S policies that summarize the

commitment the Project has made to managing E&S risks and impacts. They

establish the expectations for conduct in all related aspects of the Project. Throughout

the development, construction, and operation, the Project, is committed to:

· Achieving compliance with the highest H&S and quality standards;

· Performing the works in an environmentally and socially responsible

manner;



· Supporting the economic development of the transit countries; and

· Protecting the sustainability of natural resources for each of the transit

countries.

In line with the overall Project objectives, the E&S policies and their objectives are

briefly discussed as follows. Copies of these policies and supporting documents are

included as Appendix E.

7.4.1 Code of Conduct

The objective of the Code of Conduct is to preserve and foster the integrity and

reputation of the Project, to help its employees to avoid misconduct, with the meaning

that all Project personnel shall ensure compliance with legal and regulatory

requirements as well as with internal policies and directives, while upholding good

market practices at all times.

7.4.2 Environmental Policy

TPCL will provide all necessary resources and shall seek to establish and maintain

an effective environmental management system to prevent pollution and other

environmental harm in line with this overall objective.

7.4.3 Social Policy

TPCL will provide all necessary resources and shall seek to establish, maintain, and

continuously improve an effective social management system to avoid any negative

social effects of the Project and its activities, and to maximize the positive social

effects of the Project.

7.4.4 Health and Safety Policy

The objective of the H&S Policy is put in place safe and healthy working conditions

conforming to the letter and the spirit of applicable laws and international best

practices.

7.5 Identification of Risks and Impacts

Project E&S risks and impacts have been identified and are discussed in the ESIA.

The Project will implement mitigation measures to manage these risks and impacts

and conduct risk assessments at regular intervals. Additional risks assessments will

be undertaken any time there are significant changes to operations or when there are

external changes such as new laws or regulations.

Risk assessments shall, where applicable, include input from all levels of workers and

managers, Affected Communities, and other external stakeholders. Risks will be



assessed and prioritized according to both their probability and the severity of

negative impacts, and monitoring plans will be linked to prioritized risks.

7.6 Management Programs

This ESIA has identified impacts (both positive and negative) to the physical, natural,

and socio-economic environments, as well as to community and workers health. In

order to avoid, minimize, and reduce negative impacts, and to ensure opportunities

for the enhancement of positive impacts are realized, Chapter 10. Preliminary ESMF

contains the relevant information for the EPC Contractor to develop Project-specific

ESMPs for implementation.

The ESMF is an umbrella document that includes multiple specific environmental and

social framework documents, as presented in Appendix F, which will serve as

guidelines for the EPC Contractor to develop a complete set of detailed ESMPs.

The Project ESMPs will be centred on actions and procedures to avoid, minimize, or

compensate for the risks and impacts that were identified. Whatever actions the

Project decides to take, it will be regarded as a continual improvement process and

targets, deadlines, and methods will be set to measure the results, and adjust the

plans if necessary

In addition, the Project will develop and document clear, detailed procedures to:

· Help embed E&S policies into the Project’s daily operations;

· Serve as step-by-step instructions for workers, supervisors, and managers;

· Allow for everyone to have a common understanding of how to behave; and

· Enable the rules to be followed even when there is staff turnover.

Procedures will be developed in a way for everyone to understand (such as written

for managers and supervisors and illustrations for less literate or immigrant workers).

All employees will be made aware of procedures and their contents and why it is

important to follow them. This will be achieved through routine communication and

effective training. Employees will be made aware of when procedures are changed,

and they will have access to the current version of each procedure. Out-of-date

documentation will be removed or clearly marked as outdated to ensure that no one

unintentionally follows the old procedure.

7.7 Organizational Capacity and Competency

The following sections provide a summary of the external and internal interfaces

between the main role players, namely TPCL, Project Management Consultant/s

(PMC) and the EPC Contractor responsible for the implementation, management and

monitoring of the ESMP and the general roles and responsibilities associated with it:



· PMC and TPCL: The most significant interface is the relationship between PMC

and TPCL. This will largely be fostered at Contract Management and Board Level;

however, all PMC Managers and Engineers will have a responsibility to interface

with their respective counterparts in TPCL; and

· PMC and EPC Contractor(s)/Vendors: The interface between PMC and EPC

Contractor(s) and external vendors will for the most part be through the PMC

Management, Supply Change Management and construction supervision.

The main external interfaces are represented graphically in Figure 7-2 below:

Figure 7-2 External Interfaces

7.7.1 Internal Interfaces

The main internal interfaces which will affect the PMC are as follows, with PMC

operating in a matrix organization structure (both functional and contract reporting

lines):

· PMC Project Manager / PMC Technical Representatives / TPCL Client

Representative: The main interfaces the PMC Project Manager will have to

facilitate, is between the PMC Technical Representatives (separate Engineering

and Construction) and the overall Client Representative;

· PMC Project Manager / PMC Project Director: The relationship between the TPCL

Contract Manager and PMC Project Director will be the contracts route for external

assistance with respect to additional engineering support on an as-required basis.

The PMC Project Manager will have a link to the on-site supervisors based on the

TAPI Pipeline facilities;

· Support Functions (E&S / Logistics / HR / HSE / Security / Training / SCM / IT /

Finance): The support functions will have functional heads. The functions support

position will be a mix of part-time and full-time resources assigned to the contract

Vendors Vendors

Various

EPC EPC

Various

Client Client

TPCL

Contractor Contractor

PMC



and their role is to interface directly with their counterparts within the PMC, but also

to provide functional support to the contract;

· Engineering Discipline Leads: The Engineering Discipline Leads will report to the

PMC Project Manager and are responsible for reporting EPC Engineering and

Projects execution performance and progress. Project Engineers inside the PMC

contract will communicate with technical representatives and Engineering Leads on

a weekly basis through a formal progress meeting. The Engineering Discipline

Leads will also communicate with the respective EPC focal points and the PMC

Project Manager will take a more holistic portfolio review of project progress. The

intention of meetings is also to forecast into the future progress and workloads,

whilst considering resource histograms;

· Project Engineer: The role of the Project Engineer will be to interface directly with

the respective EPC representatives and the TPCL engineers responsible for each

project. Additionally, regular interfacing with PMC’s internal engineering team is

required to manage effective project control. Formal reporting through defined

project reports will be needed, however, daily communication will also take place

to ensure that Project compliance is monitored. The Project Engineer will also

interface with the respective TPCL focal points throughout the duration of the

project; and

· Project Controls: Reporting operationally to the Project Manager, Project Controls

will also report functionally to the Business Services Manager. Internal to the

contract, the respective Project Controls departments from EPC Contractor and

PMC Projects will have a direct communication link to ensure that Project

Controls’ philosophy and reporting are consistent with contract requirements and

expectations.

Additional positions, roles, and responsibilities of PMC will be defined following the

award of the PMC.

7.7.2 Roles, Responsibilities, and Authorities to Implement the ESMP

7.7.2.1 TPCL

Turkmengas State Concern is the main shareholder and consortium leader of the

TAPI Project.

TPCL is the Project implementation company for the TAPI Project, which is

responsible for the development and implementation of the TAPI Project, including:

· Liaison with all host governments (Turkmenistan, Afghanistan, Pakistan, and

India) for the conclusion of the main Project agreements;



· Engagement with the nominated Land Rights Entities in Afghanistan and Pakistan

for the development of the Land Acquisition and Livelihood and Restorations

Plans in compliance with national legislation and international lending institutions;

· Liaison with governmental authorities of the relevant host countries for the

identification and obtaining of necessary Project permits and authorizations;

· Liaison with PMC on project management and monitoring an ongoing basis. TPCL

may potentially also be involved in monitoring the EPC Contractor's activities,

which should benefit the Project and increase TPCL’s knowledge of the project.

In these cases, it will be essential that PMC and TPCL are aligned and provide a

united front to EPC Contractor who will seek to find division and use this to its

advantage;

· Liaison with EPC Contractor when and where required;

· E&S management of the Project during the entire Project lifecycle from

engineering, through construction, commissioning/start-up, and operation to the

decommissioning of the Project, which includes in particular the ensuring that

mitigation measures identified through the ESIA and included in the ESMP are

implemented, in full conformance with applicable E&S, legal, regulatory, lender

and corporate requirements

The host country governments have realized the strategic importance of the TAPI

pipeline for peace, security (including energy security), and socio-economic

development in the region, and have recognized that the implementation of the Project

is supported by all Parties.

7.7.2.2 PMC

In addition to the key roles and functions explained in Section 11.7.1, the PMC

appointed by TPCL will mainly be responsible to:

· Be accountable for overall delivery and compliance with regulatory and lender

requirements;

· Manage the EPC Contractor on behalf of TPCL;

· Review and approve the Constructor’s CESMP;

· Supervise contractor activities through management controls;

· Interact with EPC staff where Project activities take place; and ensure that

communication with EPC is handled in a manner that minimizes risk and provides

appropriate visibility to help deal quickly with problems when they do arise;

· Hold Project Management Team meetings (frequency to be established) to

conduct regular reviews of progress, and to devise actions and processes for

continual improvement of Project environmental and social performance;



· Review the EPC Contractor’s progress on a regular basis to identify if schedule

slippages have occurred;

· Consider trend reviewing to identify potential risks, threats or delays at an early

stage so that remedial corrective actions can be requested as defined in the EPC

contract;

· Attend Health, Safety, Social & Environmental Management meetings as required

· Monitor and audit the EPC Contractor and its subcontractors work to ensure

compliance with the contract (including the ESMP);

· Approve compliance reports and environmental performance reports to be

submitted to relevant authorities;

· Advise TPCL when problems are not resolved and request TPCL to authorize in

writing the deviation or issue appropriate instructions or requests for actions to the

EPC Contractor.

7.7.2.3 EPC Contractor

Key positions, roles, and responsibilities related to the implementation of the ESMP

are defined, but not limited to the information in Table 7-1 as it will also be defined

following the award of the EPC Contractor.

Table 7-1: Key Positions, Roles, and Responsibilities

Name/Title Responsibilities / Duties

EPC Contractors · Whilst performing work on the Project, EPC Contractors shall be accountable to the

Project’s Project Management Team;

· Project Construction Manager shall comply with all relevant Project and Statutory

Regulations, standards and procedures applicable to the scope of work and

contract conditions; and

· Specific HSE and Social critical responsibilities include but are not restricted to:

o Actively participate in Project HSE initiatives;

o Line Management effectively planning the work in order to remove the

employee’s exposure to any risk greater than low risk while undertaking the

task;

o Where a business need arises, practice meeting the required HSE standards

set by the Project HSE plan and the Regulator. This can be achieved by

working with project HSE personnel to seek opportunities for integrating the

specification with the way the contractor works;

o Comply with all Environmental Plan components including; reporting all

environmental incidents and non-compliances; communicating all concerns

and factors that affect their environmental performance; acting to correct or

report any substandard environmental performance or practices; submit and

administer their own Environmental Plan; and

o Work with Social Manager to resolve community grievances and to maintain a

social license to operate.

Project Managers · Ensure planning, implementation and monitoring of Project plans up to the hand-

over to Operations;

· Ensure that execution activities are performed in application of the best

technologies and in compliance with requirements and standards set;

· Execute Project in accordance with the approved program and budget; coordinate

the assigned integrated multidisciplinary Project teams and manage contractors,




ensuring that all services are provided and interfaces managed; report project

progress and costs trends to Project management and other relevant functions and

coordinate any corrective action required;

· Ensure the preparation of plans and budgets for the activities of competence;

· Manage any investment proposals and authorization process;

· Obtain all the necessary approvals and authorizations by Government Authorities to

run Project operations; and

· Attend Technical Committee and Operating Committee meetings.

HSE Manager · Develop, implement and maintain the HSE Integrated Management System;

· Monitor compliance with IFC PSs, HSE legislation, certification standards and

company policies;

· Identify HSE and hazards and assess the HSE risks of all Project activities; define

HSE risk mitigation measures and develop a suitable and traceable approach to

monitor such measures;

· Develop, implement and maintain HSE procedures in line with HSE best practices

for all locations under Project responsibility (exploration and production assets,

buildings and operating bases) and provide advice for the HSE management of

these locations;

· Implement and maintain an emergency preparedness and response capability with

procedures duly tailored to the Project’s organization and activities, in compliance

with company policies and standards;

· Ensure the development of detailed annual HSE plans and budgets for the Project;

plan the resources allocation according to priorities and ensure reporting and

follow-up of these plans;

· Manage the HSE audit activities plan and ensure the follow up of the audit action

plans; identify, in compliance with Project standards, HSE key performance

indexes appropriate for the process and ensure the maintenance and

dissemination of accurate HSE statistics, reflecting HSE performances against

established goals;

· Propose training and information programs on HSE and ensure training and

associated competency appraisal are carried out and recorded, in order to ensure

all personnel in the organization are competent to perform their duties in a safe,

healthy and environmentally sound manner;

· Maintain liaison with relevant government bodies, partners and other oil companies

to promote strong health, safety and environment policies and activities to ensure a

continued high level of focus on HSE issues; and

· Liaise with Health and Human Resources competent functions for the matters

related to health management system and in particular on occupational health,

industrial hygiene.

Environmental

Manager

· Monitoring the compliance of personnel and contractors to effectively implement

the environmental requirements of the ESMP including the requirements of the

applicable regulator;

· Mentor, guide, or advise the Project Management Team, or EPC Contractor line

management on the effective implementation of the Projects ESMP;

· Review changes and developments of environmental and regulatory and legislative

standards, guidelines and policies and advise Project Management Team or EPC

Contractor line management on how any such changes may require functional

changes in the ESMP;

· Oversee the implementation and monitoring of the environmental components of

the ESMP;

· Manage and maintain the ESMP and updating it as necessary; and

· Manage and maintain the Project’s ESMS and update these documents as

necessary.

Human Resources

and Training

Manager

· Develop and implement a human resources policy appropriate to the Project size

and workforce that sets out its approach to managing workers consistent with the

requirements of legislation and IFC PS 2 and a human resources / workers




management and monitoring plan that outlines the approach to managing workers

consistent with requirements set in the Workers Management Plan;

· Provide workers with information regarding their rights under national labor and

employment law, including their rights related to wages and benefits;

· Document and communicate all working conditions and terms of employment to all

workers and base employment decisions on the principle of equal opportunity and

fair treatment;

· Manage the recruitment of the required staff (also those recruited through

manpower agencies), ensuring that critical and strategic competence is attracted

and retained;

· Document and communicate to all employees and workers directly contracted by

the Project their working conditions and terms of employment, including their

entitlement to wages and any benefits;

· Develop a plan to mitigate the adverse impacts of retrenchment on workers;

· Provide a grievance mechanism for workers to raise reasonable workplace

concerns and manage and close out grievances as far as possible within a

reasonable timeframe;

· Protect the workforce by ensuring that no child labor will be used and that the

Project, its contractors, and suppliers will not employ forced labor;

· Promote the development and training of human resources, implementing

performance appraisal, potential evaluation, career planning and organizing

training activities;

· Ensure that employment relationships are based on principle of equal opportunity

and fair treatment;

· Enable means for workers to express their grievances and protect their rights

regarding working conditions and terms of employment;

· Coordinate human resources administration and management (for local and

international staff and expatriates), using dedicated IT systems, in accordance with

local legislation and company regulations;

· Manage organizational activities related to Project organization, regulatory system

and delegation of authorities’ system, supporting systems;

· Manage internal communication process according to Project needs;

· Ensure the management of medical services for employees in accordance with

local health policy, also through Project policies and agreements with local

hospitals and/or dedicated insurance schemes, in agreement with Project function;

and

· Ensure the development and implementation of the health management system

and standards of occupational health and industrial hygiene in collaboration with

the HSE Manager

Contracts and

Procurement

Manager

· Develop, implement and maintain an integrated strategy on procurement activities,

in accordance with business requirements and in compliance with Project policies;

· Develop, implement and keep updated the Project’s procurement regulations in

compliance with Project standards and in conformity with the applicable law;

· Implement the LCP in compliance with the requirements by the ESMP and law;

· Manage the Project’s procurement process and coordinate the purchase and

contract awarding process, by receiving the request of material/services, arranging

the tendering process, preparing the purchase order/contract to be awarded and

relevant amendments; guarantee the cost effectiveness and transparency of the

process and the achievement of planned savings;

· Ensure the planning and reporting of procurement activities for the Project as well

as the consolidation and timely transfer of relevant data;

· Ensure the implementation and the maintenance of a Vendor Qualification System

and to identify and evaluate potential suppliers and update relevant vendors list;

· Advise and support the user units on contract administration matters; and

· Assist the Social Manager to develop local suppliers once they are under a

contract.




Social Manager · Identify government acts, policies or practices that may affect Project operations,

profitability, and reputation and advise senior management regarding proposed

responses and actions;

· Provide strategic advice to the Project Director / Managing Director, working closely

with External Relations, visiting senior leadership on engagement with external

stakeholders to achieve business goals and enhance the Project’s license to

operate;

· Oversee plans to support Project Director / Managing Director´s capability in all

representation areas such as government, community leaders, media, NGOs and

think tanks;

· Advise senior management of proposed actions, particularly where there are

delays (such as a result of community issues);

· Raise awareness across the Project that stakeholder relations are a collective

responsibility and give staff across the company an incentive to serve as

ambassadors in helping to cultivate and maintain good working relationships with

external stakeholders;

· Update and maintain the stakeholder database;

· Monitor grievances, report any risks to Senior Management and ensure that the

grievance database is updated;

· Develop and implement a plan to proactively procure and maintain relevant permits

and licenses required by the Project;

· Work closely with HSE function to identify and mitigate potential social risks and

issues that could potentially harm the Project’s reputation and Affected

Communities;

· Develop and implement a strategic plan to ensure effective engagement with

Chiefs, Community Elders, Local Government Authorities and the Lands

Commission concerning the acquisition of land for the operations and

compensation of persons affected by the Project;

· Negotiate with any parties involved to agree the size of land, lease duration, price

and compensation to affected persons;

· Oversee the implementation and monitoring of the Social components of the

ESMP;

· Monitor the compliance of personnel and contractors to effectively implement the

requirements of the ESMP including the requirements of the applicable Regulator

and the actions resulting from Project Steering Committee or Leadership Team

meetings;

· Mentor, guide, or advise the Project Management Team or EPC/contractor line

management on the effective implementation of the Project’s Environmental and

Social Management Plan;

· Ensure adequate implementation of a community investment strategy;

· Responsible for Stakeholder Engagement Plan (SEP), including communicating

technical information to relevant audiences in an appropriate form, via reports,

workshops, educational events, public hearings;

· Ensure that contractors have the capability to deal effectively with stakeholders and

putting such requirements into their contract. Contractual requirements might

include having their own mechanism for managing grievances, their own manager

of community relations, and providing training for their staff and sub-contractors on

how to interact with the local population; and

· Track changes in the quality of stakeholder relationships.

Community Liaison

Officers (CLOs)

· Directly report to the Social Manager as the concerns of local stakeholders might

pose a risk or reputational issue for the Project;

· Engage with Project neighboring communities on an ongoing basis to build good

relations and to serve as the Project’s ‘eyes and ears’ on the ground;

· Receive and register grievances and close them out as soon as possible; and

where necessary, bring it to the attention of the Social Manager (as guided by the

grievance mechanism and procedure);




· Arrange and facilitate community meetings as and when required (as per the

Stakeholder Engagement Action Plan); and

· Monitor contractor actions on the ground and assist in resolving any complaints

from Project stakeholders about contractors.

Industrial Relations

Officers (IROs)

· Directly reports to the Human Resources Manager (with dotted lines to the Social

Manager);

· Resolve contractor/employee issues and handle complaints to protect the Project’s

general interests;

· Develop and ensure healthy work relationships and a supportive atmosphere at the

workplace;

· Provision of advice for department managers on how to deal with

contractors/employees, most of all in extraordinary situations;

· Leading of negotiations between the Project and contractors/employees;

· Monitor and report on contractor compliance with the Human Resources / Worker

Management Plan; and

· Monitor and report on worker grievances and advise on risk management

measures.

7.7.3 Communication and Training

Communication and training will be undertaken as it is key in ensuring that ESMS

procedures are followed. In achieving this, the Project will follow three key steps that

build on each other, namely to:

· Make all employees aware of the ESMS (what it is, what its goals are, and

why it is needed);

· Help all employees to understand that the ESMS is necessary and that it

will improve the Project (how it helps the Project, how it will help the various

departments to achieve its goals, what it will change, and how it will help

each individual employee); and

· Ensure that all employees obtain the skills and knowledge to be effective

in their roles (what the new policies and procedures are, what they have to

do exactly, how they have to do things, and what will happen if they do not

do it).

Employees will need to understand the basics of the Plan-Do-Check-Act cycle as

discussed in Section 11.2.

7.7.3.1 Health, Safety, Security and Environment Induction and Training

The Senior Site Manager will be responsible for ensuring all personnel working onsite

have received an initial site induction. Under no circumstances can anyone enter or

work onsite without having first attended a formal induction session. Records of

induction will be maintained in a Training Register and will be provided prior to each

employee commencing work onsite.

Visitors must undergo a short induction that includes basic environmental and H&S

considerations and procedures, including H&S training when applicable. Visitors must

be accompanied by a fully inducted employee or contractor at all times. The HSE



Manager will also be responsible for training on hazards, risks, and emergency

response connected to the ESMP.

Job specific training including competency assessment shall also be provided to staff

carrying out activities with environmental implications such as waste or hazardous

materials handling and disposal operations. This will be developed following a

detailed training needs analysis.

7.7.3.2 Environmental and Social Awareness Training

TPCL commitment to E&S protection shall be passed on to all workers, visitors,

delivery personnel, and every person involved in the Project development in order to

ensure no significant environmental or social impact. Awareness and training on

environmental importance and requirements is therefore of the utmost importance

and shall be understood as a priority while performing the works.

In addition, the HSE Manager and the Community Liaison Officer will prepare and

schedule more specific E&S training sessions regarding air and noise emissions,

physical environment impacts, hazardous materials management, waste

management, cultural heritage management, landscape, social impacts, indigenous

people issues, as far as necessary. This training program will be modified as required

in order to ensure all workers are familiar with E&S protection and mitigation

measures. For all training activities, a written record will be kept including information

of the time, place, attendance, and topics discussed. This record will be signed by all

attendants and kept as an attendance register at HSE and social department.

7.7.3.3 EPC Contractor Training

The EPC Contractor is responsible for training all their employees in relation to their

ESMP and all relevant E&S issues prior to the commencement of any work.

Documented proof of this training is required to be presented to the Senior Site

Manager prior to commencement of onsite works.

Training will include at minimum the following topics;

· General site issues;

· Traffic and access;

· Reporting procedures including incident/emergency response procedures

and reporting accountabilities;

· Relevant environmental legislation;

· Environmental responsibilities and accountabilities;

· Environmental aspects and potential impacts identified in the ESIA and

Project ESMPs, including, but not limited to:

- air quality, including dust and odour;

- noise and vibration;

- waste disposal and recycling;

- visual aspects;



- heritage and archaeology;

- soils and geology;

- water;

- flora and fauna;

- groundwater;

- rehabilitation;

- communities; and

- Tribal People.

7.8 Emergency Preparedness and Response

Even though the Project has considered all the risks and impacts and put the

appropriate emergency management plan in place, accidents and emergency

situations can happen. The Project is a dynamic operation with many things change

from day to day, for example, people will go in and out of workforce, materials and

suppliers will enter and exit the supply chain, and facilities and equipment will be

added or removed. The management system will help to maintain continuity and

consistency throughout these changes. However, there may be a momentary lapse

or gaps in the system (for example, someone not properly trained, someone not

following the procedures, a machine breakdown), or an external force (such as natural

disaster) that can lead to an accident or emergency situation. While it is not always

possible to prevent such situations, the Project will have in place before construction

commencement an Emergency Preparedness and Response Plan (EPRP) to ensure

the Project can effectively prevent and minimize any harm to workers, communities,

and the environment.

The key to effective response is effective preparation. The following steps shall be

included in the Project EPRP to help anticipate the possible scenarios and prepare

accordingly:

· Identify the areas where accidents and emergency situations may occur,

and communities and individuals that may be impacted;

· Develop response procedures for each identified emergency situation that

clearly explain what actions need to be taken. These need to be detailed

clearly for everyone working for the Project to understand what he or she

needs to do;

· Provide the necessary equipment and resources to effectively implement

the response plans;

· Assign responsibilities so that each activity has people responsible for

carrying it out. Also designate people who will routinely analyse how well

the system is working and update the risk assessment and plans;

· Communicate so that everyone understands the importance of the

emergency preparedness and response system and is encouraged to help

monitor and improve its effectiveness. Also include people in the

community who may be affected;



· Provide periodic training so that everyone has an overview of the system,

and knows the response plans;

· Work with government agencies and community groups to identify areas

where the Project can collaborate to respond effectively to internal and

external situations;

· Conduct periodic checks and drills to test how well the system is working

and to re-assess the risks to reflect changing conditions. Incorporate the

findings to continually improve the system;

· Ensure that the emergency response plan is site specific and that it is

independently reviewed for its suitability and effectiveness;

· Identify specific hazards that are relevant to the Project’s operations and

define action plans to eliminate the hazard or mitigate the risk; and

· Provide technically appropriate PPE and train staff on the appropriate use

and maintenance of supplied PPE. In addition to emergencies that may

result from workplace hazards, all workplaces are also vulnerable to

emergencies caused by external events.

Emergencies that are related to security risk and impact are addressed in the Security

Plan. Emergencies covered in the EPRP may be interrelated, for example, security

related fire or explosion. Both the EPRP and the Security Plan should be developed

to take into account this interrelationship including the dynamic nature of how risks

and impacts change over time and location.

7.9 Stakeholder Engagement

A Stakeholder Engagement Plan (SEP) for the Project has been developed and

presented in Chapter 12 of the ESIA). The SEP is a live document and will be updated

on an ongoing basis.

7.10 External Communications and Grievance Mechanisms

As mentioned above, a SEP for the Project has been developed that guides external

communications. A basic grievance management mechanism has been provided in

the SEP. TPCL is now working towards fully understanding the local socio-cultural

and security context to inform and establish a grievance mechanism.

E&S performance information, including feedback on the results from ESMP

monitoring process, will need to be shared with a range of stakeholders. This includes,

but is not limited to, the following:

· Project staff;

· Contractors;

· Local communities;

· National authorities; and

· Project shareholders.



The type and method of communication will be different for each stakeholder

depending on their interest in the Project. A formal communications protocol should

be set up during all Project phases. The aim of the protocol should be to ensure that

effective communication on key issues that may arise during construction be

maintained between key parties such as the Project Environmental and Social

Manager, Project HSE Officer, Project Manager, and EPC Contractor. The protocol

should ensure that concerns/issues raised by stakeholders are formally recorded and

considered and, where necessary, acted upon. If necessary, a forum for

communicating with key stakeholders on a regular basis may need to be established.

This section sets out the different methods of communication required for ESMP

information sharing. Additional information on stakeholder engagement and

communication can be found in the ESIA in addition to the overall Project SEP.

7.10.1 Communication Process

Table 7-2 describes the lines of communication for construction workers, local

villagers, local authorities, Project organizations, and other Project-related individuals

with respect to filing external communication like grievances or incidences throughout

the construction and operation of the Project.

Table 7-2: Lines of Communication

Stakeholder Potential Concern Means of Contact Key Contact

Project Affected Communities in the Corridor

Adequate compensation package

Complaints/concerns shall be communicated through a grievance process

HSE Manager

CLO

Disturbance from

construction camp and associated activities

Grievance process HSE Manager

CLO

Loss of agriculture

lands, trees, and fisheries

Grievance Mechanism for

Compensation and Land Acquisition Framework

Project Compensation Specialist

Project Livelihood Restoration Specialist

CLO

Maintenance of cultural heritage

Cultural Property and CFP

HSE Manager

CLO

Safety and security of

local villagers and communities

Direct Contact Security Manager

HSE Manager

CLO

Potential Employees

Employment opportunities affected households)

Recruitment of locals at the Project site

IRO

CLO

Security Manager

Adequate resources (such as food and water) and shelter

Issues shall be conveyed to TPCL

Competitive wages TPCL or Contractor’s hiring representative

Government Stakeholders

Chronic or severe E&S impacts

Bring attention to HSE manager

Project E&S Manager

Project Manager Team

Construction Workers and

Camp Sites

Worker code of conduct Weekly meetings with construction workers

IRO

Social conflicts

between local villagers and workers

Individual meeting with

disorderly workers re: IRO



Stakeholder Potential Concern Means of Contact Key Contact

Non-compliance with Project prohibitions

established in worker code of conduct

prohibitions – decision on

whether removal is

necessary

IRO

Environmental issues

(such as exploitation of natural resources)

Bring attention to HSE

manager HSE Manager

Project E&S Manager

The Site Construction Manager and the HSE Manager will be responsible for

submitting a monthly E&S report on the status and effectiveness of overall E&S

mitigation and management compliance. Reports shall be produced through the

course of implementation of monitoring programs, collecting incident/grievances

forms, consulting with local authorities and community representatives, and auditing

performance of existing programs / mitigation measures within the ESIA and ESMP.

7.10.2 External Communication Protocol

Due to the size, importance, and geopolitical sensitivity of the Project, a range of

external actors will have an interest in understanding how the ESMP is being

implemented and overall Project E&S performance. It is important that the Project is

open with sharing of information and installs regular lines of communication with the

various interested parties. In establishing an external communication protocol, the

Project will help reduce risks and sharing of false information, which has the potential

to harm the Project’s reputation and increase security risks in the region.

The form of communication and the type of information to be shared with external

actors will differ depending on their interest in the Project. The different stakeholder

communication requirements are included in the following sections and will be

described in more detail in the Project SEP.

All external communications will be managed by TPCL and Project contractors are

not permitted to report externally on monitoring results unless written permission from

TPCL is sought in advance.

7.10.2.1 National Authorities

Communication protocols with national authorities will be formalized through TPCL

Project Corporate Affairs and negotiation with the relevant authorities. Land

acquisition will largely be managed by the national governments of Pakistan and

Afghanistan; however, close communication and collaboration will be maintained with

the Project.

Information on communication expectations and protocols with the national authorities

is also likely to be included as a condition of the environmental permit. This section

will be updated once the Corporate Affairs and the permitting process has been

finalized.



7.10.2.2 General Public and Other Stakeholders

Public sharing of information on E&S performance, including areas of compliance and

areas requiring improvement, shows that the Project is being transparent and open

about meeting the ESMP objectives. Not all information needs to be made public, but

an overview of measures and progress in meeting specific targets can assist in

providing a positive image of the Project.

Information sharing with the general public will primarily be focused on the Project

website and in some cases, such as with specific NGOs and special interest groups,

direct mailing of information. It will be the responsibility of the Project Management

Team to use the SEP to define who would benefit from information sharing and how

this should be managed.

7.10.2.3 Local Communities

Local communities are often those that will be directly affected by Project impacts and

therefore have a significant interest in the degree to which mitigation measures are

implemented. Regular sharing of information with local communities on how negative

impacts are being minimized and positive impacts enhanced will help build confidence

in the Project. Information sharing will largely be the responsibility of Project CLOs

who will meet regularly with local communities. The form of information sharing will

be verbal, with some written information provided depending on the level of literacy of

local inhabitants.

Despite the CLOs being largely responsible for formal communication with local

communities, other Project workers or contractors must also be trained in what

information can be shared should questions arise during contact with local residents.

Records of communications will be required to include information on any issues and

their resolution, community health and safety concerns and any areas of conflict or

unrest.

7.11 Ongoing Reporting to Affected Communities

See Section 7.10.2.

7.12 Monitoring and Review

7.12.1 Definition

Monitoring is an umbrella term that includes various methods for evaluating

performance. These may include visual observation, measuring and testing,

questionnaires, surveys, interviews with employees and external stakeholders, and

document review. It is important that the Project design its monitoring program to

obtain qualitative and quantitative information. It is also important that workers and

managers are monitoring the workplace on an ongoing basis. Auditing is a formal,



onsite evaluation against a specific set of criteria. Audits can be conducted internally

by Project staff or by outside parties.

The basics of monitoring include the following;

· Visual observation – physical walk-throughs of facility and surrounding

land;

· Interviews – consultations with workers, managers, and external

stakeholders;

· Measuring and testing – checking, using equipment that is properly

calibrated; and

· Document review – looking through documents and records.

7.12.2 Monitoring Tools

The following tools and techniques will be used to monitor progress, identify risks, and

take actions to continually improve performance as well as the management system.

7.12.2.1 Indicators

A key aspect of monitoring is defining relevant indicators. These are quantitative or

qualitative measures of progress against set goals. Some indicators might focus on

performance, evaluated against the criteria defined in the ESIA, ESMP, and SEP,

while others can look at the processes or inputs used to try to achieve performance.

The Project shall establish clear indicators in its monitoring plan to measure E&S

performance.

7.12.2.2 Information Management System

Project documentation and recording of E&S performance will be managed through

the ESMS. A key part of this ESMS will include the development of an electronic

information management system, which will gather information as part of the ESMP

monitoring, verification, assessment, audit, and performance indicator processes.

This will act as a central database for all data relating to this ESMP and is designed

to handle and manipulate data as required to facilitate reporting. The information that

is input into the electronic system will be gathered by staff, contractors, and

subcontractors using a range of data gathering tools. This section outlines the tools

that will be used to gather information related to the ESMP.

Stakeholder engagement information from the commencement of the ESIA process

is currently managed in a stakeholder engagement database. This database will be

upscaled as the Project moves into the construction phase.

7.12.2.3 Record Keeping

Monitoring requirements are specified in the monitoring section of the ESMP. The

results of any monitoring shall at a minimum be:



· Maintained in a clear legible format;

· Retained for at least four years after the monitoring or event; and

· Maintained with the following details for each sample required to be

collected: on the date(s) on which the sample was collected:

- the time(s) at which the sample was collected;

- sample method;

- the point at which the sample was collected; and

- the name of the person who collected the sample.

7.12.2.4 Reporting

The ESMP provides a set of indicators and periodic reporting requirements, which

aim to monitor the effectiveness of implementation E&S measures. Periodic reporting

will include qualitative and quantitative data, reporting against performance indicators,

non-conformance and incident data, and other information as relevant.

Sharing of information will be required both internally and externally. Internal reporting

will be shared among the management team and specific functions. External reporting

will be required to provide information to stakeholders including the national

government, lenders, and Affected Communities (see Section 11.10).

Project contractors will be expected to submit monthly reports on E&S performance.

Information should be included on:

· A summary of the previous month’s activities (including tasks completed,

problems, and concerns);

· Status of all non-compliances with the ESMS and actions for rectifying non-

compliance issues;

· Summary of all E&S related incidents and stop work incidents (including

the time of occurrence and a description of each incident, measures taken

to mitigate each incident, and the current status of all environmental, socio-

economic, and cultural heritage parameters affected by each incident);

· Summary of all E&S regulatory and legal issues;

· Monitoring register of all sampling and analysis of discharge and emissions;

· Monitoring register of all waste volumes generated and disposed;

· Monitoring reports against the agreed Key Performance Indicators (KPIs);

and

· Reporting on grievances including the nature and status of any complaints

received (nature of grievance, mitigations measures proposed, and date of

close out).

7.12.3 Compliance Auditing and Review

The HSE management shall develop a compliance audit program to verify the

compliance with the provisions set by the ESMP during the Project lifetime. The HSE

audits shall be planned based on risks and managed (as a minimum) through the



assurance system in accordance with the Project Audit and Review Procedure (refer

to the Project Quality Management Plan). The following types of audit processes have

been identified in the ESIA process:

· Desk audit, encompassing the review of Project-specific documentation

and interviews with appropriate Project staff to the compliance to ESMP

provisions;

· Field audit, encompassing a desk audit followed by a site visit(s) by the

auditor to verify compliance to the ESMP provisions;

· Inspection, systematic technical examination of work conditions,

equipment, or practices; and

· Self-assessment, an inspection conducted by assigned staff to regularly

assess an activity’s compliance with applicable ESMP specifications and

procedures.

A site E&S checklist shall be used during the audit process to establish specific audit

objectives and then used as a checklist to guide the audit. It provides a series of items

that can be quickly examined to provide an accurate indication of the effectiveness of

safeguards contained in the ESMP. A sample of a typical checklist used in Site

Environmental Inspections is presented in Table 7-3. The auditors shall be identified

from within TPCL management according to the existing onsite procedures. The audit

process shall be applied to the activities performed by both internal and external

personnel as detailed in the following subsection.

Site Management will determine the frequency of audits and findings will be reviewed

throughout the Project.

Table 7-3: Checklist for Site Environmental Inspections (SAMPLE)

PROJECT NAME: Project Phase: Construction

Date:

Item Number Action

Description

Documents

Generated

Responsible Comments Issue

Closed/opened

Completed by: ______________________________ Date: _____________

Signature: _________________________

The ESMP implementation and its effectiveness shall be reviewed at least annually.

Review will be undertaken by the HSE Manager under the direction of the Senior Site

Manager. Participation from other project staff, specialist consultants, and

stakeholders, as appropriate, will be included.

The Site Management Team will:

· Review the results of audits at least annually;



· Undertake a system critique during which improvements and corrective

actions will be sought; and

· Undertake an operational critique during which the operation of the ESMS

will be examined.

Any changes to the ESMP as a result of its review will be approved by the HSE

Manager.

7.12.4 Monitoring of EPC Contractor and Subcontractor Activities

Site management will review the individual contractor’s specific management plans

and monitoring program by periodically reviewing results, auditing procedures and

spot check monitoring. This should be performed both randomly and in response to

questionable results.

The EPC Contractor must ensure that the conditions of the ESMP are adhered to.

Should the EPC Contractor require clarity on any aspect of the ESMP, the EPC

Contractor must contact the Project HSE Officer and the CLO for advice. For all

training activities, a written record will be kept including information of the time, place,

attendance, and topics discussed for review by Project upon request. This record will

be signed by all attendants and kept as an attendance register at HSE department.

The EPC Contractor will be responsible for monitoring the performance of the

mitigation measures against its own plans and KPIs.

Contractors are responsible for developing and implementing audit programs

consistent with the site’s requirements to ensure that their actions and those of their

subcontractors comply with the environmental requirements in the Contractor ESMS.

All findings shall consist of factual descriptions and must be assigned recommended

corrective actions and correction dates based on the severity of the finding, the

resources needed to correct the finding, and the Project schedule.

Recommended corrective actions should address all identified root causes in order to

prevent recurrence of the observation. An audit report shall be issued by the auditor

and submitted to the site management, including a copy of the check list completed

during the audit process.

Cases of non-compliance identified as a result of audits, inspections, or environmental

monitoring performed on EPC Contractor’s activities will be recorded and

communicated to the same EPC Contractor for appropriate action. Non-compliances

will be ranked according to their potential impact. EHS Management will determine

the appropriate ranking system and notification methodology. Early identification can

reduce incidents by pre-empting any problems before any environmental damage is

caused.

An example of non-compliance ranking is provided below:



· Level 1: A non-compliance situation not consistent with the original

requirements but not presenting an immediate threat to an identified

resource, community, or employee H&S. If left unattended, a Level 1 non-

compliance may become a Level 2 concern. If repeated or not corrected in

a timely manner, a formal non-compliance may be generated;

· Level 2: A non-compliance situation that has not yet resulted in clearly

identified damage or irreversible impact to a sensitive resource, but to

prevent such an occurrence requires prompt corrective action and site-

specific attention. If left unattended or continuously recurring, a Level 2

non-compliance may become a Level 3 concern. A corrective action

request and formal non-compliance notice will be issued to the contractor;

and

· Level 3: A critical non-compliance situation which typically damages a

sensitive resource or reasonable expectation of the same. A Level 3 non-

compliances may result in a stop work order.

7.12.5 Corrective and Preventative Action

Corrective and preventive action shall be managed in the management system

database.

The management system database shall be used within the TAPI Project to capture

the following record types:

· Non-conformity reports;

· Preventive action;

· Corrective Action Plan for major non-conformance; and

· Client feedback.

All instances of technical incidents shall be formally documented with remedial and

corrective actions captured in the system as per TPCL’s Control of Non-Conformity

Process (refer to the Quality Management Plan).

The database allows the capture of improvement actions highlighted both internally

and externally from execution of work by the Project Management Team and EPC

Contractor(s). These actions are the result of improvements identified from any of the

following:

· Client feedback;

· Audits and reviews;

· Inspections and monitoring activities;

· Risk reviews;

· Business or technical incident investigation;

· Management reviews; and

· Lessons learned (TPCL, Project Management Team, and EPC Contractor).



Should any of the actions be of a sensitive nature, the database contains the

functionality to retain sensitive actions by limiting visibility and circulation.

Corrective Action Plans may be disclosed on Lenders websites.

Any actions which are captured in the system shall first be agreed with the proposed

actioner. Agreeing the content and proposed action required is essential to ensuring

mitigating actions are effectively assigned and deployed. Prior to closure, all actions

taken shall be reviewed (as a minimum) with the action originator and management

system focal point to ensure they address the root cause of the record.

The database shall be regularly reviewed to identify any themes or trends arising from

the Project Management Team and EPC Contractor(s) performance. If required,

remedial action shall be undertaken to address any negative trends.

7.12.6 Continual Improvement

The ESMS is designed to ensure that throughout the construction and operation

phase of the Project, the operational and biophysical environment associated with the

site is maintained or improved. Continual improvement will be achieved by continually

evaluating environmental management performance against environmental policies,

objectives, monitoring criteria, and targets for the purpose of identifying opportunities

for improvement. The continual improvement process for the scheme will be designed

to;

· Identify areas of opportunity for improvement of environmental

management which leads to improved environmental performance;

· Determine the root cause or causes of non-conformances and deficiencies;

· Develop and implement a plan of corrective and preventative action to

address root causes;

· Verify the effectiveness of the corrective and preventative actions;

· Document any changes in procedures resulting from process improvement;

and

· Make comparisons with objectives and targets.

Implementation of strategies/techniques to improve the environmental performance

of the Project is the responsibility of the Project Management Team. Actions and

further opportunities for continual improvement will be discussed at Management

Team Meetings. These discussions should be held as often as necessary but shall

be at least annually.

7.12.7 Management of Change

The ESIA was prepared based on the design information provided by TPCL. Further

design development / changes in construction methods, including the detailed design

necessary for the construction of the pipeline will occur.



The ESMPs will require a mechanism to manage change effectively. Such a

mechanism to manage change, or a change management system, must ensure that

changes to the scope of the proposed Project are subjected to a robust social and

environmental assessment process.

Substantive design / technology changes that might potentially alter the ESIA findings

(such as those that result in changes to the predicted significance of E&S impacts)

will be subject to re-assessment, further stakeholder consultation, supplementary

reporting and revision of the Project’s ESMPs. Typically, such substantive changes

will be submitted as an addendum to this ESIA.

Any changes to engineering design shall follow the Project Management of Change

processes (000-PM-CHA-011) to ensure that the impact of the change is effectively

assessed, and changes incorporated including amendment to ESMP requirements.

The Management of Change Process will be performed by the FEED engineers of the

TAPI Project and it will include a Project Environmental and Social Manager to assess

E&S issues of any proposed changes. This will mean that proposed changes that are

clearly of no relevance with respect to E&S topics will not be subject to further work.

A desk-based review will be performed for any proposed changes that have the

potential to give rise to new or additional significant impacts (positive or negative)

which differ to those as presented in the ESIA report.

For those proposed changes for which the review suggests significant/potentially

significant ESIA-related impacts, the Project Environmental and Social Manager will

undertake appropriate consultation internally and with the ESIA Consultants (if

required) regarding any further mitigation or other measures (including further design

development) needed to comply with the relevant ESIA standards. The determination

of significance of a potential impact will be largely based on the corresponding

definitions in the ESIA for the relevant E&S topics.



8 REFERENCES

IFC EHS Guidelines, 2007

IFC PS, 2012

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Asian Infrastructure Investment Bank, 2016. Environment Framework

ILF Consulting Engineers, 2017. Construction Concept. K358-ILF-OVA-GEN-CM-

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ILF Consulting Engineers, 2017c. Basis of Design. K358- ILF-OVA-GEN-GE-REP-

0001/REV2.

ILF Consulting Engineers, 2017j. Specification for Site preparation and Earthworks.

K358-ILF-OVA-GEN-CI-SPC-0006/REV.1

ILF Consulting Engineers, 2017m. Specification for Emergency Diesel Generator

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ILF Consulting Engineers, 2017v. Logistic and Transpiration Study. K358-ILF-OVA-

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ILF Consulting Engineers, 2017y. Operation and Control Pipeline System Philosophy.

K358- ILF-OVA-GEN-PR-REP-0006/Rev.2

ILF Consulting Engineers, 2017z. Operation and Maintenance Organisation Report.

K358- ILF-OVA-GEN-GE-REP-0016/Rev.2

ILF Consulting Engineers, 2017aa. Pipeline Internal Inspection Philosophy. K358-ILF-

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ILF Consulting Engineers, 2017ab. Maintenance Philosophy. K358- ILF-OVA-GEN-

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ILF Consulting Engineers, 2017ac. K358- ILF-OVA-GEN-CI-SPC-0004/Rev.1

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ILF Consulting Engineers, 2017ad. K358-ILF-OVA-GEN-HS-REP-0002_3_Fire

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ILF Consulting Engineers, 2017ae. Corrosion Study Report. K358- ILF-OVA-GEN-

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Turkmenistan - Afghanistan - Pakistan - India (TAPI) Gas Pipeline Project.

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