ESIA Draft Report M-9 Motorway Project

NT NL I WY UHR Y
AI A H HA ATOI
O G T

Draft Final Report
June 2012

Environmental & Social Impact Assessment (ESIA)

Karachi Hyderabad Motorway (M-9)

Bina Puri Pakistan (pvt) Ltd.

Environmental and Social Impact Assessment
Karachi Hyderabad Motorway (M-9) Project

Draft Final Report
June 2012

ENVIRONMENTAL MANAGEMENT CONSULTANTS
503, Anum Estate, Opp. Duty Free Shop, Main Shahrae Faisal, Karachi.
Phones: 9221-4311466, 4311467, Fax: 9221-4311467.
E-mail: mail@emc.com.pk, emc@cyber.net.pk
Website: www.emc.com.pk

EnvIRonMEntAl And SocIAl IMpAct ASSESSMEnt foR KARAchI hYdERAbAd MotoRwAY (M-9) pRojEct

EXECUTIVE SUMMARY
Background of the Project
The existing 136 km Karachi-Hyderabad section of N-5 (popularly known as
Super Highway) connects the port city of Karachi with the North of Pakistan.
This section of the highway is amongst the most densely trafficked in the entire
country, the existing highway is serving heavy traffic volume with large portion
of truck traffic. The route is also the shortest possible distance between the two
cities i.e. Karachi and Hyderabad and feeds into the main North – South Links
i.e. National Highway N-55 (Indus Highway) and the National Highway N-5
(Grand Trunk Road).
In order to accelerate the process of expansion of motorways the Government has
invited the private sector to participate in expansion of Motorway Network, on
the basis of build, operate and transfer (BOT) arrangement. The National
Highway Authority selected M/s Binapuri Pakistan Pvt. Ltd. (BPL) for the
construction of existing 4-lane Karachi-Hyderabad Superhighway as 6-lane,
access controlled and world class Motorway (M-9) along with its allied facilities.
Environmental & Social Impact Assessment of the proposed project Karachi-
Hyderabad M-9 has been conducted by M/s Environmental Management
Consultants in order to comply with the regulatory requirement of
environmental laws of Pakistan. Under the Pakistan Environmental Protection
Agency (Review of IEE and EIA) Regulations 2000; “Federal or provincial
highways or major roads (except maintenance or rebuilding or reconstruction of
existing roads) with total cost of Rupees 50 Million and above” is in Schedule II,
List of projects requiring an Environmental Impact Assessment”
As per the EPA Guidelines, the present Project is classified as “Schedule II” that
requires an EIA study and approval from the concerned authority, prior to the
construction. The approach adopted for conducting Environmental & Social
Impact Assessment of Karachi-Hyderabad M-9 Project is to follow the
requirements of Pakistan Environmental Protection Agency (Review of
IEE/EIA), Regulations 2000.

Proposed Project
The project starts off at Km 13+000 (Project Chainage 0+000) of the NHA
reference under the flyover/interchange provided for the Lyari Expressway on
the Lyari River and ends at Km 149+000 (Project Chainage 136+000) in the
proximity of the clover leaf interchange on the Hyderabad Bypass.
The proposed project involves rehabilitation of the existing 134.35 Km (Length

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reduced by 1.65 Km at Hyderabad end, terminating before Hyderabad
Interchange) of 4-lane carriageway both north-bound and south-bound and
construction of an additional new lane on the inner side of the Highway
wherever technically feasible. Both rehabilitation and widening bound
carriageways will be divided by a New Jersey Barrier. Extensions are to be made
to all the existing bridge structures and culverts. Four (4) bridges have an
additional extension on either side accommodating service roads to allow local
traffic to negotiate land locked areas between canals.

Table 2.1-Silent Features of the Project
Project Name Environmental & Social Impact Assessment for the proposed M-9 Karachi to Hyderabad.
Project Proponent Binapuri Pakistan Pvt. Ltd. (BPL)
Project Location Existing 136Km Karachi-Hyderabad section of National Highway N-5.
Interchanges Seven (7)
Service Area Two (2)
Facilities at Service Area:
l Restaurants and Food Courts
l Toilets
l CNG/LPG Filling Stations with Tuck Shop
l Diesel/Petrol Filling Stations with Tuck Shop
l Tyre Shop and Mini Workshop
l Trauma Centre
l Mosque
l Parking Area
l Truckers Workshop
l AamSarai and Dhaba (with Trucks/Buses Parking)
l Customer service centers where motorists can inquire about products, services,
road information, weather etc.
l Internal Roads, Sewerage, Water Supply and Electrification
Toll Plazas Two New 16-lane Toll Plazas with Electronic Toll and Traffic Management (ETTM) system
Weigh Stations Seven (7) weigh stations
Motorway Facilities l Electronic Toll Collection
l Emergency Call Service
l Centralized Operation Centre
l Traffic Counting Stations/ Weigh in Motion (WIM) system
l Variable Message Signs
l Emergency Assistance System

Project Objectives
The prime objective of the proposed project is to facilitate movement of people
and goods transport in the project area and between Sindh and other provinces
by providing better access and enhance the efficiency of the existing road
network. The scope of project is but not limited to:

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n Strengthen the existing road infrastructure,

n Construct existing 4- lane Karachi-Hyderabad Superhighway as 6-lane,
access controlled in order to provide world class Motorway (M-9) along with
its associated facilities

n Design and construct bridges, culverts, and underpasses where necessary,

n Provide helpline services, services area and other motorway facilities.

Relevant Legislation & Guidelines
To carry out the present ESIA study, the environmental legislation and
guidelines enforced by the Pakistan Environmental Protection Agency have been
followed.
Project Alternatives
Different alternative of the project were analyzed by considering no Project,
alternative transport modes and improvement of the existing carriageway.
Improvement of existing road with widening on both sides in different lane
alignments, construction of more lanes and construction of bypass was
considered for project alternatives. Rehabilitation of existing carriageway and
construction of new lane was considered feasible due to least impact and more
benefits.

Description of Environment and
Social Conditions of the Area
Baseline conditions were studied for the physical, ecological resources and for
socioeconomic environment. The project is located in three districts of Sindh
Province; Malir, Thatta and Jamshoro.
The climate of most parts of the Project Area is arid characterized by four district
seasons in a year, that is, winter from Mid-November to February, spring during
March and April summer from May to Mid- September and autumn from Mid-
September to Mid-November. June is the hottest month in most parts of the
Hyderabad area, with mean daily maximum temperature recorded as 34.7 °C.
January is the coldest month in the area, with the mean daily minimum
temperature recorded as 20.7 °C. The air temperature prevailing at Karachi city
and its adjoining coastal areas are generally high throughout the year. During
winter the range of variation of temperature is large for Karachi coast especially
in respect of maximum and minimum temperatures. The mean maximum
summer temperature is 33°C, while the mean minimum temperature of Karachi
is 21.0°C.

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In order to analyze the existing air quality of the project area, ambient air
monitoring was conducted at four locations in association with Suparco through
their mobile monitoring lab by using USEPA designated monitoring equipment.
The estimated value of the ambient air quality data parameters when compared
with the NEQS were within the limits at all sites except the CO and NO which
are slightly higher than the NEQS limits at site of Hyderabad (Near Toll plaza).
EMC team has measured noise quality of the project area. Noise level at Damba
Goth was found to be 80.6 dB (Max) which is above the NEQs Level.
The geology of the region is divisible in three main regions, the mountain ranges
of Kirthar, Pab containing a chain of minor hills in the west and in east it is
covered by the Thar Desert and part of Indian Platform where the main exposure
is of Karonjhar Mountains, which is famous for Nagar Parkar Granite. The
geology of Sindh is divisible in three main regions, the mountain ranges of
Kirthar, Pab containing a chain of minor hills in the west and in east it is covered
by the Thar Desert and part of Indian Platform where the main exposure is of
KaronjharMountains, which is famous for Nagar Parkar Granite. The soils in the
vicinity are generally coarse textured extensively laden with gravels and pebbles.
The River Indus is the prime surface water resource of Sindh.
According to the seismic zone map of Pakistan the project area lies in Zone 2A
and 2B of Modified Mercalli (M.M) intensity scale i.e. minor to moderate
damage, distinct earthquakes may cause damage to structures with fundamental
period corresponds to intensity IV- VII the M.M Scale.
Most wildlife species were found to be present or reported quite far away from
the project area in relation to the officially notified protected areas which may
comprises ecosystems that includes wildlife reserves and forests, archaeological
sites, monuments, buildings, antiquities or cultural heritage sites. As many as 12
species of mammals, 18 species of birds and 11 species of reptiles were recorded
from the area. None of the threatened species of mammals, birds or reptiles was
recorded from the area.
On both the sides of the road several tree plantations were seen which are mainly
dominated by Eucalyptus citriodora, Azedarahtaindica, Thespeciapopulenaea,
Conocarpuslatifolia, Parkinsoniaaculeata, Neriumindicum, Callistemon sp,
Guacamofficinale, Bougainvillaglabra. There is a big tract of abandoned land on
either side of the project dominated by two invasive species viz Prosopisjuliflora
and Prosopisglandulora.
The nearest Wildlife Protected Area is the Surjan Game Reserve which is about
2.0Km from the existing Karachi-Hyderabad Super Highway. The limits of
Mahal Kohistan Wildlife Sanctuary have been extended. These may be taken into
account.
In order to assess the present socio-economic and socio-cultural conditions of the
community living in the project area, a social survey was conducted. Meetings

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were held with different Government departments, educational institutions,
NGOs and local communities to discuss the project, its components and its
expected environmental and socio-economic impacts.
Environmental Impact and Mitigations
Potential impacts were identified in relation to planning, design and location for
construction and operation phases of the proposed Karachi-Hyderabad M-9
Project. Mitigation measures have been suggested to reduce all negative impacts
to acceptable levels. These were discussed with specialists responsible for the
engineering aspects, and measures have been included in the designs for the
infrastructure. This means that the number of impacts and their significance have
already been reduced by amending the design. These including Strengthen the
existing road infrastructure without disturbing the business of the people;

n Design of structures as per seismic zone to eliminate risk;

n Design of storm water drainage system in consideration of change in
topography;

n Replantation of trees and Compensatory plantation;

n Avoiding complete closure of road by limiting the construction area to actual
M-9 RoW and allowing the traffic as per the traffic management plan.

n Provide provision of chain link fence and all necessary arrangement on both
sides of defined RoW;
During the construction phase, impacts mainly arise from generation of dust
from soil excavation and refilling; and from the disturbance of residents,
businesses, traffic and important buildings by the construction work. Among
these, public and worker safety due to large scale construction using heavy-duty
construction equipment, traffic disturbance during construction is considered to
be significant.
Important measures suggested include:

n Dust control measures such as water sprinkling and covering the loose
material during transport;

n Proper planning and scheduling of noise generating activities;

n Providing alternative traffic routes/detours and informing public about the
same;

n Providing public information boards at site (project details, traffic
arrangements, executing agency and contractor details; safety and contact
information);

n Following standard and safe construction practices (barricading the site

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properly; avoiding accidental traffic entry including pedestrians;
deployment of safety and security staff; providing warning/sign boards;
provision of protection equipment; special precautions during risky works
like arranging the pre-cast elements and equipment safety checks, etc.)

n By considering the above mentioned factors and the road will now be
constructed first on one side and then on the other side from centerline of
the existing road to a 6 lane carriageway. This will have the advantage of
enhanced safety during construction and operational stages, and less
disruption to the passing traffic during construction. It will also minimize
resettlement of structures, trees and other utilities
The construction of the existing road will be in such a way with minimal land
acquired and less disruption to the traffic hence no major impacts are envisaged.
The main beneficiary of the proposed project is to provide a future access to the
Karachi- Hyderabad Motorway that would be achievable in the most
appropriate location.
Mitigation will be assured by a program of environmental monitoring
conducted to ensure that all measures are provided as intended, and to
determine whether the environment is protected as envisaged. This will include
observations on and off site, document checks, and interviews with workers and
beneficiaries, and any requirements for remedial action will be reported to the
EPA.
Stakeholders were involved in developing the ESIA through face-to-face
discussions in meetings at ESIA preparatory stage and a large public hearing
will be held, after which views expressed will be incorporated into the ESIA and
the planning and development of the project.
There are two essential recommendations that need to be followed to ensure that
the environmental impacts of the project are successfully mitigated. The
proponent and NHA shall ensure that:

n All mitigation, compensation and enhancement measures proposed in this
ESIA report are implemented in full, as described in the document;

n The Environmental Management and Monitoring Plan proposed is also
implemented in letter & spirit.
Environmental Management Plan
A comprehensive, Environmental Management Plan (EMP) has been developed
for Karachi-Hyderabad M-9 Project. An Environmental Mitigation Matrix has
also been prepared considering impacts on different components of the physical,
biological and socio-economic environment. In addition, a comprehensive
monitoring plan has been proposed for the project.

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The EMP includes review of regulatory requirements and applicable standards,
EMP institutional arrangements for implementation of EMP, roles and
responsibilities of different agencies & Environmental Monitoring plan.

Conclusion
The proposed project will increase the economic activities around the area,
creating avenues for direct/indirect employment in the post project period. It
will improve the commercial activity in the project area resulting in economic
uplift of the people of the Project area. There would be a wider economic impact
in terms of generating opportunities for other business like transportation,
marketing, repair and maintenance tasks, etc.
Property value especially near interchanges may increase in future. It is planned
by the Government to develop Industrial Zones near each interchange, which
will enhance the commerce and trade activities.
It gives a speedy as well as safe way for traveling and trade (as there are
minimum chances of accidents due to controlled speed). Decreasing the vehicle
operating cost and travel time costs due to better/ improved road facility,
reduced traffic congestion, uninterrupted and smooth traffic flow, and for
shorter route between Karachi and Hyderabad.
Due to better condition of road, the wear and tear of vehicles/engines of
vehicles is very much reduced resulting in the reduction of maintenance
expanses of vehicles. Free flow conditions throughout M-9 will reduce traffic
congestion and in turn reduce both air and noise pollution.
Generally the project will show positive impacts once completed but may cause
some short term negative impacts during its construction stage. These negative
impacts however, can be minimized or avoid if proposed mitigation measures
are duly taken into account.
The overall conclusion is that providing the mitigation, compensation and
enhancement measures are implemented in full, there should be no significant
adverse environmental impacts as a result of location, design, construction or
operation of the project.

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environmental and social impact assessment for Karachi hyderabad motorway (m-9) project

contents
01 Introduction 01 of 07
1.1 General 01 of 07
1.2 Overview of the Project 01 of 07
1.2.1 Project Location 01 of 07
1.2.2 Scope of the Project 02 of 07
1.2.3 Profile of the Proponent 02 of 07
1.3 Environmental and Social Impact Assessment of the Proposed Project 02 of 07
1.3.1 Justification and Categorization of the Project 02 of 07
1.3.2 Objectives and Scope of ESIA 03 of 07
1.3.3 Environmental Standards and Guidelines 04 of 07
1.3.4 ESIA Methodology 04 of 07
1.3.5 Composition of the ESIA Report 06 of 07
1.3.6 ESIA Study Team 07 of 07
02 Description of the Project 01 of 10
2.1 Existing Karachi-Hyderabad Superhighway 01 of 10
2.2 The Proposed Project 02 of 10
2.2.1 Project Location 02 of 10
2.3 Project Component 02 of 10
2.3.1 Rehabilitation and Extension 02 of 10
2.3.2 New Interchanges 04 of 10
2.3.3 Service Road Formations 04 of 10
2.3.4 Service Areas 04 of 10
2.3.5 Toll Plazas 05 of 10
2.3.6 Weigh Stations 05 of 10
2.3.7 Safety Fances or Barriers 05 of 10
2.3.8 Maintenance and Operation Compounds 06 of 10
2.3.9 Ancillary Development 06 of 10
2.3.10 Motorway Facilities 06 of 10
2.4 Detail Design of the Project Component 07 of 10
2.4.1 Design Life 07 of 10
2.4.2 Geometric Design 07 of 10
2.4.3 Pavement Design 07 of 10

environmental management consultants contents


2.4.4 Structural Design 08 of 10
2.4.5 Highway Drainage Design 09 of 10
2.4.6 Hydrological Design 09 of 10
2.4.7 Electrical Wiring and Lighting 09 of 10
2.4.8 Road Signs and Markings 10 of 10
03 Legislative Cosiderations, Environmental Regulations and Guidelines 01 of 11
3.1 Introduction 01 of 11
3.2 Institutional Setup 01 of 11
3.3 National Policies and Stretagies 01 of 11
3.3.1 National Conservation Strategy 01 of 11
3.3.2 Biodiversity Action Plan 03 of 11
3.3.3 National Environmental Policy-2005 03 of 11
3.3.4 National Resettlement Policy 03 of 11
3.4 National Legislations 03 of 11
3.4.1 Pakistan Environmental Protection Act 1997 04 of 11
3.4.2 Pakistan Environmental Protection Agency Review of
(IEE/EIA) Regulations 2000 05 of 11
3.4.3 Land Acquisition Act 05 of 11
3.4.4 Antiquities Act 1975 06 of 11
3.4.5 Sindh Cultural Heritage Preservation Act 1994 06 of 11
3.4.6 The Forest Act 1927 07 of 11
3.4.7 Sindh Wildlife Protection Ordinance, 2001 07 of 11
3.5 National Environmental Guidelines 07 of 11
3.5.1 Pakistan Environmental Assessment Procedures 2000 07 of 11
3.5.2 National Environmental Quality Standards (NEQS) 08 of 11
3.6 International Guidelines 09 of 11
3.6.1 World Bank Guidelines on Environment 09 of 11
3.6.2 Obligation under International Treaties and Convention 09 of 11
3.6.3 International Convention on Biodiversity 10 of 11
3.6.4 Convention on Wetlands 10 of 11
3.6.5 IUCN Red List 10 of 11
3.6.5 KYOTO Protocol 10 of 11
04 Screening of Alternatives 01 of 04
4.1 No Project Alternatives 01 of 04



4.2 Alternate Transport Modes 01 of 04
4.2.1 Alternate Access Road 01 of 04
4.3 Improvement of Existing Carriageway 02 of 04
4.3.1 Rehabilitation of Existing Roads and Addition of Two Lanes 02 of 04
4.3.2 Construction of 8-Lane Highway 04 of 04
4.3.3 Construct a Completely New Carriageway Parallel to the Existing Road 04 of 04
4.3.4 Provision of Bypass 04 of 04
4.3.5 Advantages and Disadvantages 04 of 04
05 Environmental & Social Baseline of the Region 01 of 39
5.1 Micro and Macro Environment of the Project Area 01 of 39
5.2 Physical Environment 01 of 39
5.2.1 Ambient Air Quality 01 of 39
5.2.2 Ambient Noise Quality 04 of 39
5.2.3 Climate and Meteorology 05 of 39
5.2.4 Recent Trend in Moon Soon Pattern 09 of 39
5.2.5 Storms 11 of 39
5.2.6 Surface Water Resources 11 of 39
5.2.7 Ground Water Resources 13 of 39
5.2.8 Geography 13 of 39
5.2.9 Geology and Topography 15 of 39
5.2.10 Soil 15 of 39
5.2.11 Seismic Information 16 of 39
5.3 Biological Resources 17 of 39
5.3.1 Original Ecozones 18 of 39
5.3.2 Modified Nature of Habitat 20 of 39
5.3.3 Fauna of the Project Area 21 of 39
5.3.4 Flora of the Project Area 21 of 39
5.3.5 Sensitive or Critical Habitat 24 of 39
5.4 Traffic Study on the Proposed Karachi Hyderabad Motorway M-9 24 of 39
5.4.1 Data Analysis 24 of 39
5.5 Socioeconomic Condition in Microenvironment 25 of 39
5.5.1 Communities and their Economic Activity 25 of 39
5.5.2 Displacement and Resettlemet 25 of 39
5.5.3 Pedestrian Underpasses 25 of 39



5.5.4 Indiginous People 25 of 39
5.5.5 Cultural Heritage 27 of 39
5.5.6 Aesthetics and landscape 27 of 39
5.5.7 Human Health and Safety 27 of 39
5.5.8 Reservation of Cultural Heritage 28 of 39
5.6 Socioeconomic Conditions in Macroenvironment 28 of 39
5.6.1 Demography 28 of 39
5.6.2 District Malir (Karachi) 28 of 39
5.6.3 HIstory, Ethnicity/Tribes and Culture 28 of 39
5.6.4 Occupation 30 of 39
5.6.5 Betrothal and Marriages 30 of 39
5.6.6 Important Historical Places 31 of 39
5.6.7 Population Size Growth and Distribution 31 of 39
5.6.8 Household Size 31 of 39
5.6.9 Rular/Urban Distribution 32 of 39
5.6.10 Religion 32 of 39
5.6.11 Mother Tongue 32 of 39
5.6.12 Literacy Ratio 32 of 39
5.6.13 Education Attainment 32 of 39
5.7 District Thatta 32 of 39
5.7.1 Population 32 of 39
5.7.2 Administration Setup 33 of 39
5.7.3 Historical Importance 33 of 39
5.7.4 Demographic Conditions 33 of 39
5.7.5 Gender Balance 33 of 39
5.7.6 Social Infrastructure 33 of 39
5.7.7 NGOs Working in the Area 35 of 39
5.7.8 Economy 35 of 39
5.8 District Jamshoro 36 of 39
5.8.1 Location 37 of 39
5.8.2 Population of District Jamshoro 37 of 39
5.8.3 Infrastructure 38 of 39
5.8.4 Economy 38 of 39
5.8.5 Power Plants 39 of 39



06 Stakeholder Consultation 01 of 08
6.1 Identification of Stakeholder 01 of 08
6.2 Approach and Methodolgy 01 of 08
6.2.1 Scoping Meeting 01 of 08
6.2.2 Consultation Meeting 02 of 08
07 Environmental and Social Impact Assessment and Proposed Mitigation Measures 01 of 21
7.1 Screening Potential Environmental Impacts 01 of 21
7.2 Identification of Impacts during Design Phase 03 of 21
7.2.1 Topography 03 of 21
7.2.2 Formation in Built-up Area 03 of 21
7.2.3 Location of Labour Camps & Other Material 04 of 21
7.2.4 Change of Land Use 04 of 21
7.2.5 Cross Drainage and Accessory Structures 04 of 21
7.3 Identification of Impacts during Construction Phase 04 of 21
7.3.1 Air Quality 04 of 21
7.3.2 Noise and Vibration 08 of 21
7.3.3 Impacts on Water Resources 10 of 21
7.3.4 Impacts on Land Environment 11 of 21
7.3.5 Biological Environment 13 of 21
7.3.6 Impact on Traffic 14 of 21
7.3.7 Impacts on the Socio-economic of the Area 14 of 21
7.3.8 Public Health and Safety 17 of 21
7.3.9 Natural and Manmade Hazards 17 of 21
7.4 Identification of Impacts during Operation Phase 17 of 21
7.4.1 Air Quality 19 of 21
7.4.2 Noise and Vibration 19 of 21
7.4.3 Impacts on Water Resources 19 of 21
7.4.4 Impacts on Land Environment 19 of 21
7.4.5 Bilogical Environment 20 of 21
7.4.6 Traffic Conditions 20 of 21
7.4.7 Socio-economic 20 of 21
08 Environmental Management and Monitoring Plan 01 of 30
8.1 General 01 of 30
8.2 Objectives 01 of 30



8.2.1 Key Environmental and Social Components 01 of 30
8.3 Environmental Management System 02 of 30
8.3.1 Functions of Environmental Management System 02 of 30
8.3.2 Organization Structure 03 of 30
8.3.3 Roles and Responsibilities 03 of 30
8.3.4 Specific Implementation Responsibilities 07 of 30
8.4 Environmental Management Program 08 of 30
8.5 Training, Awareness and Competence 08 of 30
8.6 Communication 09 of 30
8.7 EMMP Documentation 09 of 30
8.8 Operational Control 10 of 30
8.9 Environmental Management Procedures 10 of 30
8.9.1 Measures to Improve Environmental Awareness 10 of 30
8.9.2 Specific Process to meet Environmental Requirements 10 of 30
8.9.3 Water Quality Management 11 of 30
8.9.4 Refuse Management 11 of 30
8.9.5 Wastewater Management 11 of 30
8.9.6 Materials Management Plan 12 of 30
8.9.7 Worker’s Health and Safety 13 of 30
8.9.8 Emergency Preparedness and Response 13 of 30
8.10 Environmental Management Plan 13 of 30
8.11 Environmental Monitoring 26 of 30
8.11.1 Objectives 26 of 30
8.11.2 Monitoring Roles, Responsibilities and Schedules 26 of 30
8.11.3 Monitoring Parameters 27 of 30
8.11.4 Reporting Structures and Outcomes 27 of 30
09 Conclusion 01 of 02
9.1 Findings 01 of 02
9.2 Conclusion 02 of 02

ANNEXURES
Annex-I National Resettlement Policy, 2005
Annex-II A Pakistan Environmental Protection Act 1997
Annex-II B Pakistan Environmental Protection Agency, EIA / IEE Regulations 2000



Annex-III National Environmental Qualtiy Standards (NEQS)
Annex-IV IUCN Red List
Annex-V List of Stakeholders


envIronmental and SocIal Impact aSSeSSment for KarachI hyderabad motorway (m-9) project

01 IntroductIon
allied facilities. The project is to be carried out under
1.1- General Public-Private Partnership (PPP) arrangement on Build-
The Karachi-Hyderabad 136 km section of N-5 Super Operate-Transfer (BOT) basis.
Highwaywas constructed as a part of the First Highway
Understanding the existing environmental and socio-
Project with the assistance of World Bank during 1964 – 68
economic characteristics of the region is a prelude to
and idealized in 1991 as part of the Fourth IBRD Highway
evaluate the likely impacts (positive/ negative) that can
Project.The project corridor serves as the main spine for
occur from the proposed project. For this Binapuri
traffic movement between Karachi and Hyderabad as it
Pakistan Pvt. Ltd. has appointed M/s Environmental
provides the shortest route between these two major
Management Consultants to conduct Environmental and
urban centers. According to the Traffic study March 2012,
Social Impact Assessment of proposed Karachi-
more than 98% of traffic both passenger and goods
Hyderabad M-9 Projectin compliance with the mandatory
vehicles used Karachi- Hyderabad M-9 to travel from
requirements of Section 12 of Pakistan Environmental
Karachi towards Punjab, Northern areas and lower Sindh
Protection Act (PEPA) 1997 and Pakistan Environmental
region especially desert areas of Sindh.
Protection Agency Review of EIA/IEE Regulations 2000.
In order to accelerate the process of expansion of
motorways the Government has invited the private sector
to participate in expansion of Motorway Network, on the 1.2- Overview of the
basis of build, operate and transfer (BOT) arrangement. Project
The GOP believes that the technical, managerial and
financial resources of the private sector can make a useful 1.2.1- Project Location
addition to its own efforts in this regard. The proposed 134.35 Km Karachi- Hyderabad M-9 project
The National Highway Authority selected M/s Binapuri will likely to starts off at Km 13+000 (Project Chainage
Pakistan Pvt. Ltd. (BPL)for the construction of existing 4- 0+000) of the NHA positioned under the
lane Karachi-Hyderabad Superhighway as 6-lane, access flyover/interchange provided for the Lyari Express way
controlled and world class Motorway (M-9) along with its on the Lyari River and ends at 149+000 (Project Chainage

Table 1.1- Project Brief
Project Name Environmental & Social Impact Assessment for the proposed
M-9 Karachi to Hyderabad.
Project Construction Cost 18,235,000,000 PKR
Contact Person Ooi Chin Giap (Azlan)
PD / Acting Head – Pak, No.84 St-3 Sector HH Phase-IV, DHA Lahore.
ESIA Consultants Environmental Management Consultants (EMC)
Syed NadeemArif
Office # 503, Anum Estate Building, Main Shahrae Faisal, Karachi.
Tel: 021-34311466, Fax: 021-34311467,
E-mail: nadeem@emc.com.pk, mail@emc.com.pk

envIronmental management conSultantS 1 of 7
SectIon 1


136+000) in the closeness of the clover leaf interchange company which is listed in the main boardof Bursa
which is present on the Hyderabad Bypass. Malaysia managed by a team of professional, devoted,
qualified andexperienced personnel supported by the
1.2.2- Scope of the Project resources of the company. The Proponent is conceited to
The scope of project is but not limited to: have completed more than 1,000 kilometers of roads
andhighway, bridges, interchanges, waterworks and
n Strengthen the existing road infrastructure, projects related to land reclamation.The projects related to
Building completed comprise commercial buildings,
n Construct existing 4- lane Karachi-Hyderabad
educational institutions, hotels, hospitals, government
Superhighway as 6-lane, access controlled in order to
complexes and residential projects.
provide world class Motorway (M-9) along with its
associated facilities

n Design and construct bridges, culverts, 1.3- Environmental and
andunderpasses where necessary, Social Impact Assessment
n Provide helpline services, services area and other
of the Proposed Project
motorway facilities.
1.3.1- Justification
1.2.3- Profile of the Proponent &Categorization of Project
Binapuri Pakistan Pvt. Ltd. (BPL)is a renowned The Pakistan Environmental Protection Act 1997
construction company on the Main Board ofBursa empowers the EPA as the principal authority for
Malaysia Berhad, with 35 years of work experience in civil environmental management in Pakistan. It has also
and building constructionboth locally and internationally. established the requirement of environmental assessment
The diverse work has been done by the proponent that of any project in place prior to commencement of
comprises business activities, investment holdings, civil work.Section 12 of Pakistan Environmental Protection Act
and building engineering management, 1997 states that:
propertydevelopment, highway concessionaire, quarry “No proponent of a project shall commence construction
operations, manufacturing ofconstruction materials, or operation unless he has filed with the Government
polyurethane system house, utilities and Agency designated by Federal Environmental Protection
hospitalitymanagement. Agency or Provincial Environmental Protection Agencies,
The proponent is certified with MS ISO 9001:2000, as the case may be, or, where the project is likely to cause
OHSAS 18001, MS 1722 Certifications and has won many adverse environmental effects an environmental impact
award laudable of mention including the Prominent assessment, and has obtained from Government Agency
Player Award2005: Malaysian Construction Industry approval in respect thereof.”
Excellence Awards 2005 (MCIEA 2005), theContractor EIA study is carried out in compliance with the
Award 2007: Grade G7 (MCIEA 2007) and the mandatory requirements of Section 12 of Pakistan
International AchievementAward (MCIEA 2008) Environmental Protection Act (PEPA) 1997. This legal
awarded by the Construction Industry Development provision requires an initial environmental examination
Board ofMalaysia.BinaPuri commenced to expand (IEE) or an environmental impact assessment (EIA) to be
globally in 1995 as well as it has various operations offices carried out and the report submitted to the relevant
in Thailand,United Arab Emirates, Saudi Arabia, Agency or Department, which has been delegated the
Pakistan, Indonesia and Brunei Darussalam. authority for review and approval of EIA/IEE findings.
Nowadays BinaPuri is a remarkable construction

SectIon 1


The Pakistan Environmental Protection Agency (Review
1.3.2- Objectives & Scope of ESIA
of EIA/IEE) Regulations 2000 defines the categories of
The objective of ESIA is to foresee the potential
projects requiring an Initial Environmental Examination
environmental problems that would arise out of the
(IEE) or Environmental Impact Assessment (EIA) in
proposed development activity and address them in the
Schedules I & II respectively. According to Clause 4 of the
planning and design stage of the project. The ESIA
Pakistan Environmental Protection Agency (Review of
process should then allow for the communication of this
IEE and EIA) Regulations, 2000, “a proponent of a project
information to:
falling in any category specified in Schedule II shall file an
EIA with the Federal Agency.” Schedule II of the n The project proponent
regulations includes “all projects situated in
environmentally sensitive areas” and “any project likely n The regulatory agency (ies); and,
to cause an adverse environmental effect.” n All stakeholders and interest groups.
Under the Pakistan Environmental Protection Agency ESIA integrates the environmental concerns in the
(Review of IEE and EIA)Regulations 2000; development activities right from the time of initiating the
“Federal or provincial highways or major roads (except preparation of feasibility report. In doing so, it enables the
maintenance or rebuilding or reconstruction of existing integration of environmental concerns and mitigation
roads) with total cost of Rupees 50 Millionand above” is measures in project development. ESIA can often prevent
in Schedule II, List of projects requiring an Environmental future liabilities or expensive alterations in project design.
Impact Assessment” The purpose of this EIA study is to evaluate the activities
As per the EPA Guidelines, the present Project is classified associated with the construction and operation of
as “Schedule II” that requires an EIA study and approval proposed Karachi- Hyderabad Motorway project.
from the concerned authority, prior to the construction. Environmental assessments made here are in conformity
with the requirements of Pakistan Environmental
Accordingly detailed Environmental and Social Impact Protection Act 1997 as well as other national and
Assessment has carried out to address the regulatory international environmental guidelines where national
requirements as well as to make it acceptable to: guidelines are not available.
n BinaPuriPakistan Pvt Ltd who are the proponents The scope of this study is to assess the environmental and
social impacts that could occur as a result of construction
n BOT entrepreneur investing in its establishment and
and operations of the proposed project. Following are
operation; and
some of the main objectives of this EIA study:
n EPA Sindh against the requirement of Pakistan
Environmental Protection Act 1997. n To determine and document the state of the
environment of the project area to establish a baseline
n The ESIA study has accordingly been designed to in order to assess the impact of implementation of the
focus on making certain that: proposed project;
n If there is a negative impact, it should be mitigated as n To collect and assess existing environmental and
much as possible through specified design and social profile of entire project area and incorporate it
construction procedures, and in report for future use by client;
n Any remaining short term or long term negative n To identify all environmental sensitivities including
impact is identified clearly and made known to all flora, wildlife and avifauna of the project area, if there
those likely to be affected. is any;

SectIon 1


n To identify national heritage sites, archaeological Environmental Assessment of new projects and
sites and ecologically important areas in the project
n Pakistan National Environmental Quality Standards
zone of influence;
(NEQS) gaseous including Vehicular exhaust
n To identify and assess all the major and minor emissions; noise emissions and liquid effluents.
environmental & socio-economic aspects and Scoping to explain all stakeholders of the need of the
impacts due to construction and operation of the project and the likely environmental as well as social
office building project specifically in the project area impact has already been held as the necessary first step of
and generally on its surrounding in accordance with process of EIA .The views and concerns expressed by the
national and international environmental legislations stakeholders have been recorded and they will be duly
and guidelines. responded in the EIA.
n To provide assistance to the proponent for planning,
designing and implementing the project in a way that 1.3.4- ESIA Methodology
would eliminate or minimize the negative impact on EMC adopted the following procedures for making
the biophysical and socio-economic environment assessment of impact of different activities during the
and maximizing the benefits to all parties in the most construction and operational phases on micro
cost effective manner; environment and macro environment of the project
activity areas:
n To provide opportunity to the public for
understanding the project and its impact on the
community and their environment in the context of A. Understanding of the Proposed
sustainable development. Operation
n To develop a detailed environmental management This step involved collecting information from on the
plan (EMP) for the sustainable implementation propose project activities and understanding the activities
mechanism of mitigation measures identified during to identify potential impacts from them.
the study along with monitoring plan.
B. Review of Legislation and
1.3.3- Environmental Guidelines
Standards and Guidelines
National legislation, international agreements,
Issues related to Environment and control all over environmental guidelines, and best industry practices
Pakistan are governed by Pakistan Environmental were reviewed to set environmental standards that
Protection Act (PEPA) 1997.Guidelines and procedures BinaPuriwill be required to follow during different stages
for preparing EIA reports have been published by Federal of the project.
EPA in the form of “ Pakistan Environmental Assessment
Package”.
C. Secondary Data Collection
Before commencement of Projects the requirements of
All available published and unpublished information
Govt. of Pakistan that need to be met are as follows:
pertaining to the micro and macro environment of the
n Legal requirements in Pakistan for Environmental Project was obtained and reviewed. It included the earlier
Assessment for new projects under the environmental studies and environmental baselines
Environmental Protection Agency Sindh conducted the consultants for development activities in
M-9 Motorway project. All data sources were reviewed to
n Pakistan EPA Guidelines and Procedures (2000) for
collect information relevant to physical, biological and

SectIon 1


socio-economic condition of the macroenvironment and F. Impact Identification and
microenvironment of project site.
Assessment
Potential impacts which may arise from proposed
D. Scoping Sessions with Relevant activities were identified. These included effects on
Stakeholders physical, biological, socio-economic environment;
Meetings were held with all project related stakeholders archaeology and culture. Impacts were identified in
to have expert opinion and get a better understanding on particular on the biological habitats and assessed on the
project area, its physical, biological features, as well as basis of field data collected from area, secondary data,
social and economic issues. The stakeholders gave expert opinion, and monitoring results ofprojects in
valuable suggestions and input which were very useful proposed project area.
while carrying out the impact assessment.
G. Recommendations to Mitigate
E. Field Data Collection Impacts
EMC teamvisited the project area in the months of Keeping in view the baseline data collected and impacts
May2012. During the site visit, primary information on identified mitigation measures have been recommended
the physical, biological and socio-economic conditions of to minimize, reduce, eliminate, or compensate for the
the project area were collected.

SectIon 1


potential environmental and social impacts on the project format, prescribed by the Environmental Protection Act
zone of influence. Mitigation measures recommended (PEPA) 1997, and Pakistan EPA guidelines and
here are based on past experience, best industry practices, procedures (2000) for the Environmental Assessment of
legislative requirements and professional judgment. New Projects. The Report has been presented in the
following sections:
H. Environmental Management
Plan (EMP) Chapter 01- Introduction
Environmental management plan (EMP) was developed Provides an introduction and background of the project
for effective implementation of the recommended and justification of ESIA.
mitigation measures. EMP includes controls to minimize
the identified impacts, and monitoring programme to Chapter 02- Description of Project
monitor residual impacts, if any, during the operation.
Describes the project, its objective; its type and category;
The EMP has laid down procedures to be followed during
location of the facilities and project details while in
the Karachi-Hyderabad Motorway (M-9) construction,
operation along with proposed schedule for
operation and associated activities and has identified roles
implementation.
and responsibilities for all concerned personnel during
the operation, including post project monitoring and
reporting. Chapter 03- Governing legislation
and Statutory Requirements
I. Documentation, Review & Provide an overview of Policy and Legislation along with
Conclusion International Guidelines relevant to operation of Karachi
Hyderabad M-9.
This is the final step in the environmental assessment. The
document is based on reports produced by EMC Team of
experts and compiled by Project Coordinator and office Chapter 04- Screening of
staff, duly overseen by Team Leader and Project Alternatives
Manager. The Report was reviewed by Team leader for Provides evaluation of different alternatives to arrive at
screening/assessment of potential environmental impacts the best possible option for the project.
and put forward recommendations of mitigation
measures and the Environmental Monitoring and
Chapter 05- Environmental &
Management Plan.
Socio-economic Baseline
The Report has been prepared according to the Policy and
This section describes the existing environmental and
Procedures for Filing, Review and Approval of
Socio-economic baseline situation of the macro and micro
Environmental Assessments 2000 and relevant guidelines
environments of the proposed project area.
of the PEPA 1997. This report includes the findings of the
assessment of the project impacts, and the mitigation
measures to be adopted during the execution of the Chapter 06- Stakeholder
proposed activities. Consultation
Describes the consultations process performed for the
1.3.5- Composition of ESIA ESIA of Karachi Hyderabad M-9 project and gives the
Report concerns of stakeholders during consultation process.
The ESIA report has been structured on the standard

SectIon 1


Chapter 07- Screening of
anticipated Impacts and Proposed
Mitigations
Describes the potential environmental and social impacts
on different features of the micro and macro environment,
and using the general guidelines presents a screening of
potential environmental impacts at the designing,
construction and operation stages. The screening includes
the residual impact as a result of adoption of mitigation
measures that may be needed for minimizing the impact.

Chapter 08-Environmental
Management and Monitoring Plan
Presents the environmental management that has been
incorporated in the design, construction and operation of
Karachi Hyderabad M-9.

Chapter 9-Conclusion
Summarizes the report and presents its conclusions.

1.3.6- ESIA Study Team
The study was assigned to Environmental Management
Consultant. EMC organized the following team to carry
out the study:

Table 1.2: EIA Study Team
S.No. Name Position
1 Mr. Syed NadeemArif Project Manager
2 Mr. SaquibEjazHussain Dy. Project Manager / EIA Expert
3 Dr. MirzaArshad Ali Beg Team Leader / Principal Expert
4 Dr. Muhammad Mansha Expert on Air
5 Dr. IqbalHashmi Expert on Water Resources
6 Dr. Mansoor Imam Expert on Waste Management
7 Dr. Syed Ali Ghalib/Mr. Razaque Expert on Fauna/Ornithologist
8 Ms. SamitaNadeem Environmental Engineer
9 Dr. ViqarHussain Expert on Geology
10 Dr. Saddar-ud-din Expert on Flora
11 Ms. Tasneem Bhatti Expert on Social Issues
12 Ms. Noor Fatima Environmentalist
13 Ms. Sarah Sidiki Environmentalist

SectIon 1

ENvIRONmENTal aND SOCIal ImPaCT aSSESSmENT FOR KaRaCHI HyDERabaD mOTORway (m-9)PROJECT

02 DESCRIPTION OF THE PROJECT
cities i.e. Karachi and Hyderabad and feeds into the main
2.1- Existing Karachi- North – South Links i.e. National Highway N-55 (Indus
Hyderabad Super Highw ay Highway) and the National Highway N-5 (Grand Trunk
The existing 136 km Karachi-Hyderabad section of N-5 Road).
(popularly known as Super Highway) connects the port The Karachi-Hyderabad section was constructed as a part
city of Karachi with the North of Pakistan. This section of of the First Highway Project with the assistance of World
the highway is amongst the most densely trafficked in the Bank during 1964 – 68 and dualized in 1991 as part of the
entire country, the existing highway is serving heavy Fourth IBRD Highway Project. Toll is being collected
traffic volume with large portion of truck traffic. The route from Highway users by the NHA.
is also the shortest possible distance between the two

Figure 2.1: The existing Karachi- Hyderabad Section of National Highway N-5

ENvIRONmENTal maNagEmENT CONSulTaNTS 1 OF 10
SECTION 2

ENvIRONmENTal aND SOCIal ImPaCT aSSESSmENT FOR KaRaCHI HyDERabaD mOTORway (m-9) PROJECT

Chainage 136+000) in the proximity of the clover leaf
2.2- The Proposed Project interchange on the Hyderabad Bypass.
The National Highway Authority intends to construct
existing 4-lane Karachi-Hyderabad Superhighway as 6-
lane, access controlled, world class Motorway (M-9) along 2.3- Project Component
with its allied facilities. The project is to be carried out The key engineering features of the Project, for
under Public-Private Partnership (PPP) arrangement on construction of a world-class motorway, include but not
Build-Operate-Transfer (BOT) basis. limited to the following:

Table 2.1-Silent Features of the Project
Project Name Environmental & Social Impact Assessment for the proposed M-9 Karachi to Hyderabad.
Project Cost 13,235,000,000 PKR
Interchanges Seven (7)
Service Area Two (2)
Facilities at Service Area:
l Restaurants and Food Courts
l Toilets
l CNG/LPG Filling Stations with Tuck Shop
l Diesel/Petrol Filling Stations with Tuck Shop
l Tyre Shop and Mini Workshop
l Trauma Centre
l Mosque
l Parking Area
l Truckers Workshop
l AamSarai and Dhaba (with Trucks/Buses Parking)
l Customer service centers where motorists can inquire about products, services,
road information, weather etc.
l Internal Roads, Sewerage, Water Supply and Electrification
Toll Plazas Two New 16-lane Toll Plazas with Electronic Toll and Traffic Management (ETTM) system
Weigh Stations Seven (7) weigh stations
Motorway Facilities l Electronic Toll Collection
l Emergency Call Service
l Centralized Operation Centre
l Traffic Counting Stations/ Weigh in Motion (WIM) system
l Variable Message Signs
l Emergency Assistance System

2.2.1- Project Location 2.3.1- Rehabilitation&
The project starts off at Km 13+000 (Project Chainage Extensions
0+000) of the NHA reference under the The proposed project involves rehabilitation of the
flyover/interchange provided for the Lyari Expressway existing 134.35 Km (Length reduced by 1.65 Km at
on the Lyari River and ends at Km 149+000 (Project Hyderabad end, terminating before Hyderabad

SECTION 2


Figure 2.2: Proposed Project Location

SECTION 2


Interchange) of 4-lane carriageway both north-bound and n CH 0+000 to CH 15+000 Both Sides of Motorway
south-bound and construction of an additional new lane 2. Semi-Urban, rural (Shoulder – 1.0m (Earthen),
on the inner side of the Highway (wherever technically Carriageway -6m (TST),
feasible) with 3.0 m outer shoulder and 1.0 m inner
shoulder. Lane width is to be taken as 3.65 m. Both Shoulder – 1.0m (Earthen)
rehabilitation and widening bound carriageways will be n CH 15+000 to CH 19+800 Both Sides of Motorway
divided by a New Jersey Barrier.
n CH 22+000 to CH 34+000 Both Sides of Motorway
Extensions are to be made to all the existing bridge
structures and culverts. Four (4) bridges have an n CH 36+875 to CH 46+875 Both Sides of Motorway
additional extension on either side accommodating
n CH 51+600 to CH 58+600 Both Sides of Motorway
service roads to allow local traffic to negotiate land locked
areas between canals. n CH 61+350 to CH 83+600 Both Sides of Motorway

2.3.2- New Interchanges 2.3.4- Service Areas
As shown in figure 2.1 Seven (7) new interchanges are to Minimum two main Service Areas of M-2 (Lahore-
be provided to support populations, towns, industrial Islamabad Motorway) Service Areastandard, with
zones and other isolated pockets enabling them to minimum following facilities, are to be established as part
commute on the motorway after fencing of the Right of of the Project:
Way (“ROW”). Although at some locations, volume of
traffic does not justify an interchange, the isolation of road
a) Restaurants and Food Courts
side developments and populations warrants
connectivity as there is no other route available for b) Toilets
transport. Interchanges within the closed system to have
c) CNG/LPG Filling Stations with Tuck Shop
entry and exit 2-lane Toll Plazas. The locations for the new
interchanges are as follows: d) Diesel/Petrol Filling Stations with Tuck Shop

Table 2.2: Location of New Interchanges
Sr.No. Chainage (Km) Name of Interchange
1 Ch 14+985 Malir Road
2 Ch 23+112 Damba Goth
3 Ch 45+596 Lucky Cement
4 Ch 55+760 Nooriabad
5 Ch 66+936 Tooriabad
6 Ch 80+952 ThanoBullah Khan
7 Ch 113+440 Borari Sand

2.3.3- Service Road Formations e) Tyre Shop and Mini Workshop
Two kinds of service road formations are to be
incorporated with minimum provisions as follows: f) Trauma Centre

1. Urban (Shoulder – 1.5m (DST), Carriageway – 7.0m g) Mosque
(Asphalt), Shoulder – 1.5m (DST) h) Parking Area

SECTION 2


i) Truckers Workshop impact and.
j) AamSarai and Dhaba (with Trucks/Buses Parking) n Parking and toilet facilities shall be provided as per
k) Customer service centers where motorists can inquire parameters stipulated in Para above.
about products, services, road information, weather etc. In the case of closed toll systems, the ticket issuing
procedures shall be such that.
l) Internal Roads, Sewerage, Water Supply and
Electrification n The opportunity for fraud is reduced to a minimum.
The CH 60+790 (North Bound & South Bound) is a n The information provided on the ticket conforms to
proposed location for Service Areas. Access and egresses the operation standard and.
to each service (and rest) areas will be conformed to
AASHTO Guidelines in terms of Geometric layout and n Data can be retrieved regarding the entry and exit
position in relation to adjacent intersection. points of all traffic using facility, by time of day and
by vehicle type.
2.3.5- Toll Plazas
2.3.6- Weigh Stations
Two New 16-lane Toll Plazas with Electronic Toll and
Seven (7) weigh stations are to be provided strategically to
Traffic Management (ETTM) system and other state-of-
cover movement of heavy traffic minimize overloading at
the-art facilities are to be provided on the main
least on the following locations:
carriageway at entry point on the Karachi End and the
Hyderabad End on the following Project Chainages, n CH 15+500 (North Bound)
respectively. These new Toll Plazas shall replace the
existing Toll Plazas: n CH 30+750 (South Bound)

n CH 16+000 n CH 40+850 (South Bound)

n CH 131+900 n CH 40+850 (North Bound)

Toll Collection Areas n CH 71+850 (South Bound)

Toll collection areas shall be designed to ensure that an n CH 71+850 (North Bound)
adequate number of toll booths are provided at each toll
n CH 132+900(South Bound)
collection point so as to ensure that the operational
standards with regards to delays to road users are
2.3.7- Safety Fences or Barriers
adhered to.
Chain link fence with all necessary arrangements will be
The toll collection area will be of Rigid Pavement. The provided on both sides of defined ROW.The form, layout
layout of the toll collection area and its approaches shall and vertical profile of such fences/barriers shall conform
be designed in such a manner as to provide safe to the requirements of United Kingdom, Department of
conditions for both road users and toll collection staff. Transport Standards TD 19/85 or other similar approved
This shall include but not limited to. international standard.
n The provision of adequate advance warning signs
and road markings. a. All the edge of the carriageway.

n Lighting at times of darkness. n On the embankment 6m or more in height or where
there is a road, railway, water hazard or other feature
n Protection of staff from vehicle emissions and vehicle at or near the flood of the slope.

SECTION 2

ESIA Draft Report M-9 Motorway Project

ESIA Draft Report M-9 Motorway Project

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