EIA Case StudyCement Plants in Kahoon Valley

EIA WorkshopDec 22, Islamabad

Hammad Naqi KhanWWF – Pakistan

Contents

• Background • Issue• Analysis of EIA Reports• Lessons learnt & the way forward

Background• Kahoon Valley

– An area rich in biodiversity, historical & socio-cultural heritage.

– habitat for a variety of wild species, birds, and reptiles.

• Population – > 50000 in 7 villages. – Employed in Army or do subsistence farming.

• Arid (Barani), but most of the land is cultivated, with good yield of crops

• Katas Fort and an old Shiva temple series. • Chumbi Surlah wildlife sanctuary

Cement Plants – The story so far…

• Government allows construction of six cement plants in 2004.

• Two of these six plants D.G. Khan Cement and Bestway CementLimited with the production capacity of 6,500 tonnes of clinker/day each commence construction without acquiring NOC from EPA.

• 6th June, 2004 - Local community meets the Secretary EPD Punjab.

• 7th July, 2004 - Impacts of illegal acquisition of agricultural land and the adverse impacts on the socio-economic conditions are shared with Federal Minister for Environment.

• 4th August, 2004 - A complaint was registered on to the environmental Tribunal under Section 21(3) (b) of Pakistan Environmental Protection Act 1997 against the illegal Industrialconstruction activities of M/S D.G. Khan Cement Company Limited.

• 23rd August, 2004 - District Environment Officer Rawalpindiprepares an internal report.

• 31st august, 2004 - Secretary Industries, Commerce & Investment addressed a letter to President’s Secretariat in response to the article written by Lt. Gen. M. Safdar in a local newspaper.

• 1st September, 2004 - Federal Secretary Environment writes to Chief Secretary, Punjab and emphasises on the threats to the biodiversity and cultural heritage from the construction of the cement plants.

• 4th September, 2004 - District Officer Environment, Gujratsubmits another report to the Minister for Environment, Punjab and highlights all the concerns regarding the environment, land acquisition, and socio-economic conditions.

Kahoon – The story so far…

• 22nd September, 2004 - WWF – P staff and other environmentalists visit the valley.

• 23rd September, 2004 – WWF raise the issue of construction of Cement plants at the proposed sites before the approval of EIA.

• 13th October, 2004 - WWF – P provide comments on EIA of D.G Khan Cement to Secretary EPD.

• 15th October, 2004 - Public hearing of D.G. Khan Cement Company Limited – Khairpur Project.

• 30th October, 2004 - Public hearing of Bestway Cement.

• EPD – Punjab issues NOCs to both D.G. Khan and BestwayCement but not according to section 12 of PEPA.

Kahoon – The story so far…

EIA Report Analysis

General:– Sketchy, superficial and non-informative. – Weak in handling of scoping, impact prediction &

determination of impact significance.Missing elements:

– Investigation of alternatives (activity, location, process, scheduling)

– Hydro-geological conditions in general and potential of the groundwater aquifer in particular.

– Quarrying of raw material i.e. limestone, clay and other additives require explosion and crushing will create noise and vibration and safety hazards in the nearby areas. No detail is given on this issue.

EIA Report Analysis (contd.)Numerous sources of air emission in a cement plant• No detail on point and fugitive, air emission sources of the

production facilities. From this information, frequency, severity and extent of these impacts can be evaluated.

• Chak Khushi and Kokhar Bala villages are located at the buffer zone of the Chumbi Surlah wildlife sanctuary and the factory will get clay from these hills and lands where tree cover of the Phulai, Ber and Santha exist.

• Wild species found in this region are • Grey partridges, See See partridges, • Jackal, Indian Fox• Porcupine, Punjab Urial• Cape Hare, Civet• Wolf Jungle Cat,

Comments on EIA Report

• Socioeconomic & gender issues:– No detailed socioeconomic survey– 900 new jobs– Limiting women ‘s movement– Restricting accessibility of women to natural resources

of the area

• Water Consumption:– Water scarce area & average water table depth varies

but not covered in the EIA – Ambiguous consumption figures (15 + 92 m3/hr)– Proposed source (Malkana village) also provides water

to 3 other villages. – Daily pumping of underground water will have

negative impact on underground water reservoir as in Khairpur village 300-350 feet is the depth of the water table.

Community Reaction

Lessons learnt and The way forward?????

• EIAs are being promoted as a project justification tool instead of a decision making tool

• Need for an independent environmental assessment agency

• Need for a strong political support for effective EIAs• Revision of EIA rules to address loopholes, flaws, etc.• Development of a list of approved consultants, EIA

practitioners etc.• Capacity & capability building of EPAs• Need for a transparent and effective post approval

project monitoring• Major policies and plans should undergo strategic

environmental assessments

Thank You!