SCCDP Garho Initial Environmental Examination Sindh Pakistan.doc

7/29/2019 SCCDP Garho Initial Environmental Examination Sindh Pakistan.doc

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Table of ContentsTable of Contents ................................................................................................... 1Executive Summary ............................................................................................... 2

1.0 Introduction .................................................................................................... 32.0 Purpose and Scope of the Report ........................................................................ 33.0 Description of Sub-project ................................................................................. 4

3.1 General Features .......................................................................................... 53.2 Technical Features of Shrimp and Crab Ponds ................................................... 5

3.3 Technical Features of Oyster, Mussels and Seaweed Rafts .................................. 63.4 Type and Category of the Project: ................................................................... 6

3.5 Location of Project ........................................................................................ 63.6 Objectives of Project ..................................................................................... 73.8 Size & Magnitude of Operations and Implementation Schedule ........................... 83.9 Government Approval and Leases ................................................................... 8

4.0 Description of Environment ................................................................................ 8

4.1 Physical Resources ........................................................................................ 84.2 Ecological Resources ..................................................................................... 94.3 Socioeconomic Profile .................................................................................. 10

4.4 Quality of Life ............................................................................................ 105.0 Potential Environmental Impacts & Mitigation Measures ....................................... 11

5.1 Environmental Impacts Due to Existing Site ................................................... 115.2 Environmental Impacts Due to Project Design ................................................. 12

5.3 Environmental Impacts Due to Project Construction ......................................... 135.4 Environmental Impacts Due to Project Operation ............................................ 145.5 Mitigation Measures ..................................................................................... 15

6.0 Analysis of Alternatives ................................................................................... 177.0 Public Consultation and Disclosure .................................................................... 188.0 Conclusion and Recommendations .................................................................... 18

Annexure I .......................................................................................................... 21Annexure II ......................................................................................................... 23


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Executive Summary

The Sindh Coastal Community Development Project (SCCDP) is being implemented bythe Sindh Coastal Development Authority (SCDA) in coastal areas of Thatta and Badin

through government agencies (Sindh Forest Dept., Sindh Fisheries Department, andDistrict Governments) and non-government organizations (NRSP and IUCN). The projectis funded by the Asian Development Bank. IUCN has been entrusted with the planningand implementation of community mangrove planting, and management and

environmental assessment of aquaculture under the sub-component on improved coastalmanagement.

This report presents findings of an initial environmental assessment of the pilotaquaculture site for establishment of 10 shrimp/crab ponds on approximately onehectare land identified by the Sindh Fisheries Department alongAmbra creek near GarhoTown of the Thatta District. The initiative is being managed by the community mobilizedby NRSP.

The site under assessment is located adjacent to Ambra creek (240 20 11.1 north

latitude and 670 35 39.6 east longitudes) at a distance of approximately 5 km fromGarho Town. Administratively, the area falls under jurisdiction of the Sindh Forest &

Wildlife Department. The selected site was declared a Protected Forest in 1958 underthe Pakistan Forest Act 1927 and, subsequently, the same area has been declared as a

Wildlife Sanctuary in 1958 under the Sindh Wildlife Protection Ordinance 1972.Under these laws the proposed aquaculture activities are prohibited within a ProtectedForest or Wildlife Sanctuary.

The site location also reveals that the area is an un-surveyed wasteland. It seems thatthe area has been claimed by the local resident Mr. Allah Dino Sholani. This claim is not

supported by the Record of Rights (Form VII) to verify actual ownership of the land.Further, the agreement signed between landowner and the Sindh Fisheries Department

does not mention survey number(s) of the proposed land.

The site itself is affected by salinity and has no potential for agriculture in future. Theestablishment of new ponds will have a very negligible impact on the existing water tablein the area. However, there is potential risk of active creek erosion due to high tides.

Since the pilot is being undertaken on the land of an influential person, one of the keyobjectives of the project to improve livelihoods among poor masses of the area issusceptible to be compromised.

The existing design of ponds at the present locations requires high investment which fora poor fisherman would be difficult to afford and replicate the existing model. Hence, it is

proposed that the site location and the project design may be reconsidered to make itconsistent with the project objectives. Low technology, low input and single householdmanaged ponds are proposed as the suitable alternative to distribute project benefitswidely and making its replication feasible.

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1.0 Introduction

The Sindh Coastal Community Development Project (SCCDP) is being implemented by

the Sindh Coastal Development Authority (SCDA) in coastal areas of Thatta and Badinthrough government agencies (Sindh Forest Dept., Sindh Fisheries Department, andDistrict Governments) and non-government organizations (NRSP and IUCN) withdifferent roles and responsibilities assigned to each of them. The objectives of the

project are:

i. Diversify household income generation options and access to service in wayssustainable to the fragile ecosystem

ii. Improve coastal zone management by stabilising environmental degradation,protecting coastal areas from accelerated erosion

iii. Strengthen institutional capabilities for coastal zone planning anddevelopment and management of fisheries resources

The complex nature of the project demands effective cooperation between organizationsfor successful implementation of the project in order to achieve the following outputs:

i. Sustainable community managed income generating mangrove stands,pond/raft fisheries, and shell fisheries established

ii. Transparent and accountable community driven mechanisms for identification,implementation and operations and maintenance of civil works and publicservices in place

In the role of consultant IUCNP has been working very closely with NRSP and SindhForest and Fisheries departments for the implementation of SCCDP.

Under the sub-component improved coastal management, IUCNP is tasked with theplanning and implementation of community planting, management and environmentalassessment of aquaculture in the coastal areas of the Thatta and Badin districts. IUCNPakistans key roles in the ADB funded Sindh Coastal Community Development Projectare:

i. To implement the Community Mangrove Planting component of the project 350 ha through local community participation.

ii. To monitor and evaluate both the 350 ha area and the planting of 3000 ha ofmangrove by the Dept of Forestry on government owned land.

iii. To monitor environmental impacts of the aquaculture related activities to beundertaken as part of the project.

2.0 Purpose and Scope of the Report

Under the Aquaculture sub-component of the project pilot scale aquaculture activities areto be initiated in Thatta and Badin districts. The pilot activities will include establishment

of 20 shrimp/crab ponds and 20 seaweed/bivalve rafts in coastal areas. Based on the

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result of these pilots, the aquaculture activities are intended to be expanded to establish80 more ponds each to promote livelihood of households in coastal areas of Sindh.

For the establishment of pilot ponds, local communities are to be mobilized and engagedin the pilot initiatives with support form NRSP and environmental assessment andmonitoring of pilot interventions and subsequent expansion is to be carried out by IUCNPakistan so that the adverse environmental consequence are avoided or mitigated to

enhance the positive benefits of the proposed interventions.

The purpose of this report is present an initial environmental assessment of the pilot

aquaculture site for establishment of 10 shrimp/crab ponds requiring piece ofapproximately one hectare land identified by the Sindh Fisheries Department along

Ambra creek near Garho town of Thatta district. Based on this assessment,environmental impacts of proposed pilot interventions have been identified, screenedand assessed. Mitigation measures to address the potential environmental impacts havebeen proposed and a monitoring plan has been suggested for continuous monitoring ofthe proposed interventions during construction and operation phases.

An initial environment assessment of the proposed pilot aquaculture intervention was

conducted before the start of project to assess baseline situation and analyseenvironmental impacts of proposed aquaculture intervention during design, construction

and operation phases. The scope of this environmental assessment report is limited toenvironmental situation within the immediate surrounding of the identified site. Theassessment covers physical, biological and socio-economic parameters pertaining to theproposed pilot aquaculture intervention. The assessment was conducted by amultidisciplinary team of experts, as follows:

1. Ahmad Saeed, EIA Specialist / Team Leader

2. Ghulam Qadir Shah, Environment Specialist / Co-Team Leader

3. Hamid Sarfraz, Sociologist

4. Muhammad Tahir Qureshi, Coastal Ecosystem Expert

5. Rafiul Haq, NRM Specialist

6. Aquaculture/Fisheries Specialist

For the preparation of this assessment report several visits of the proposed site wereconducted to collect required information. These included joint visits with relevantfisheries officials, meetings with local NRSP staff, discussion and consultation withcommunity members. In addition, background project documents and literature wasreviewed for the preparation of this report.

3.0 Description of Sub-project

The aquaculture sub-component of Sindh Coastal Community Development Project aims

at sustainable fisheries (aquaculture) development in the coastal areas of Sindh (Thatta& Badin) specifically involving the local fishermen who rely on fishing as their familyincome. As per project document (PC-I) the proposed interventions entail developmentof shrimp and crab ponds, with further work on a pilot basis in oyster, mussel andseaweed raft cultivation. It is intended to establish mariculture pond and raft systemcomprising small, low technology ponds supported by mangrove plantings. The projectdocument envisages the following strategy for aquaculture interventions:

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3.1 General Features

i. Initial construction and operation of twenty (20) ponds and (20) pilot rafts

with expansion of 80 additional ponds and 80 rafts based on successful pilot.

ii. The proposed sites for mariculture include Keti Bundar, Shah Bundar and ZeroPoint near Ahmad Rajo. For piloting, the two proposed sites are Keti Bandar

and Shah Bandar. If these trials are successful they will be extended to Zero

Point near Ahmad Rajo.

iii. The pond and raft would involve domestic species (Annexure X of PC-I).

Endogenous species fully adapted to local environmental conditions have been

selected: (i) two prawn species, Penaeus indicus and Penaeus merguiensis;

(ii) the mud crab, Scylla serrata; (iii) a local species of oyster, Crassostrea

rivularis; (iv) the mussel, Perna viridisand; and (v) local seaweed species,

Ulva. Enteromorpha Porphyra (RRP-SCCDP).

iv. The ponds and rafts will be managed in collaboration with the Coastal

Fisheries hatcheries at Gharho and Hawks Bay and with consultants.

v. Community organizations in villages will be mobilized by NRSP to assist in the

pilot scale trails. Community members will be trained in cultivation and

harvesting techniques and in the maintenance and policing of ponds and rafts.

vi. Village selection will be based on (i) poverty levels, (ii) interest and

willingness of poor households to engage in the overall activities of the

project; and (iii) physical proximity the coast, to other interested villages and

to proposed mangrove and fish pond working areas.

vii. Harvest and marketing of the prawns and crabs will be managed carefully,

taking into consideration a good return fairly distributed to the local

communities involved in the operation.

viii. Following successful pilot scale replication, the cultivation of crabs, shrimps,

bivalves and seaweeds will be extended to the third site at Zero Point, and

also expanded at the Keti Bandar and Shah Bandar sites with eighty additional

ponds and eighty rafts, for a total of 100 ponds and 100 rafts, subject to

advance environmental planning and regulation to avoid future pollution and

environmental degradation.

ix. The aquaculture activities would be linked to protective mangrove planting.

x. The sites selected for this sub-component would not be located in ecologically

sensitive or wildlife areas (Annexure X of PC-I).

3.2 Technical Features of Shrimp and Crab Ponds

i. A series of 10 ponds (each about 20 x 50 meters in size or 0.1 ha) will be built

for pilot testing of the approaches on two of three sites. Ten ponds will be

constructed at each site, five each for crab and shrimps.

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ii. Twenty initial ponds will be sited above mean high tide level with built up

bunds (embankments) to prevent encroachment during spring tides. Seawater

supply will be by a gravity-fed system relying on the ebb and flow of the

twice-daily tide. The shrimp ponds will be seeded with post-larvae from the

Hawks Bay shrimp hatchery. The crab ponds will be seeded with young crabs

caught by local villagers in the mangrove swamps.

iii. The feed for the crab is trash fish and shrimp. The feed for shrimp is

commercial feed pellets, or a combination of urea, cow and poultry waste,

DAP (di-aminophosphate), molasses and yeast, prior to stocking the pond.

iv. Shrimp fishery will yield 1650 kg after 4 months, and crab fishery will produce

2000 kg after 4 months. There is a large local and export market for shrimps

(Rs.200-300/kg depending on season). Crabs (Rs. 80/kg) are valuable export

with a significant market, and the potential for seaweed direct exports and

local sale of extracts is high.

3.3 Technical Features of Oyster, Mussels and Seaweed Rafts

i. Cultivation of oyster, mussels and of seaweeds will be undertaken on a pilot

scale by growing them on ropes attached to simple rafts (5 x 5 meters size).

ii. The twenty initial pilot rafts will be anchored in the mangrove creeks so that

they are flushed twice a day by the ebb and flow of the tides.

iii. Seed for the mussels and oysters occurs naturally on a seasonal basis, and

will attach to the ropes.

iv. Six rafts will be sited at each site, three for mussels and oysters and three for

seaweeds, plus two extra for bivalves in the most promising location.

3.4 Type and Category of the Project:

The proposed pilot aquaculture ponds consist of small scale community managedinitiatives which fall in Schedule-I of the Pakistan Environmental Protection Agency (IEEand EIA) Regulations 2000. For such project, Initial Environmental Examination is

required which deals with preliminary assessment of predicted quantitative andqualitative environmental impacts of a project to know if there are any adverse impacts

that may require a full scale EIA.

3.5 Location ofProject

Site for the proposed(10) pilot aquacultureponds is locatedadjacent toAmbra creek(240 20 11.1 northlatitude and 0670 3539.6 east longitude) ata distance of

approximately 5

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kilometres from Garho town, falling in Union Council Garho, District Thatta (Fig 1:Location Map). In this regard, the project proponent, Sindh Fisheries Department hasentered into an agreement (Annexure I) with a private landowner, Mr. Allah Dino Sholanito get the subject land allocated for establishment of a series of 10 shrimp/crab ponds,each measuring 0.1 ha (20m x 50m), on a communal basis. However, GPS coordinatesof the identified site reveal that the site in question has been declared as protected

forest and wildlife sanctuary, and falls under the administrative and legal jurisdiction ofthe Sindh Forest & Wildlife Department (Annexure II).

3.6 Objectives of Project

i. Aquaculture based on community ponds and rafts will provide livelihood

opportunities.

ii. Enhance income of the communities engaged in operation of aquaculture

activities.

iii. Enable communities to better manage their natural resource base, enabling

more diversified, regular and sustainable income from these sources.

iv.Develop sustainable alternatives that reduce pressure on the capturefisheries.

Fig 1: Location Map of Proposed Aquaculture Site (Source: Google Earth)

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3.7 Alternatives Considered

The proposed establishment shrimp and crab pond and rafts system has been prescribedin the Sindh Coastal Community Development Project being executed by Sindh CoastalDevelopment Authority in Thatta (Keti Bundar & Shah Bundar) and Badin (Zero Point)

districts of Sindh province. The proposed site for pilot scale shrimp and crab ponds andoyster, mussel rafts has been selected by Sindh Fisheries Department keeping in viewnearness to their Garho facility and similar aquaculture activities being operated by

private parties in the area.

Apparently, alternate to the identified project site has not been considered by the SindhFisheries Department. The identified site is affected by salinity and has no potential foragriculture in future.

3.8 Size & Magnitude of Operations and Implementation Schedule

By design, the proposed pilot aquaculture ponds and rafts involve low technology and

low input community operated aquaculture activities. The total land occupied by theproposed pilot (10) ponds is 1 ha. The earthen ponds are designed to be constructed

adjacent to Ambra creek. The pilot pond and raft construction would be completedduring the first year of SCCD project, however the operation phase will remain continuethrough out the project implementation period and beyond and would require continuousmonitoring.

3.9 Government Approval and Leases

The proposed pilot aquaculture activities are being implemented as one of the sub-components of Sindh Coastal Community Development Project being executed by theGovernment of Sindh through Sindh Coastal Development Authority. As such the

propose interventions are endorsed by the government. Further, implementation andtechnical supervision of proposed aquaculture activities is being carried out by the SindhFisheries Department is responsible Sindh Government Agency.

The designed pilot project intervention would require approximately 1 ha land, which hasbeen identified by Sindh Fisheries Department and entered into an agreement with a

local private landowner, Mr. Allah Dino Sholani to get the subject land allocated for thepurpose. However, GPS coordinates of the identified site reveal that the site in questionhas been declared as protected forest and wildlife sanctuary, and falls under theadministrative and legal jurisdiction of the Sindh Forest & Wildlife Department. Thus,necessary government approval would be required. The pilot rafts are to be sited in themangrove creeks and require no land as such.

As per project document, in all the expansion to a proposed 100 aquaculture pondswould require 75 ha land government or community owned land, many hectares of

suitable government owned land has been identified as potentially available in inter-tidalzone, besides the community owned land for the proposed intervention.

4.0 Description of Environment

4.1 Physical Resources

The proposed aquaculture site lies at a distance of approximately 5 km in the west toGarho town near village Allah Dino Sholani. The proposed site is located at 24 0 20 11.1

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north latitude and 0670 35 39.6 east longitude. The general topography of the areaconsists of agricultural plains interfaced with inter-tidal creek zone. Being, adjacent tothe creek the proposed aquaculture ponds site consists of saline wasteland. As per soilanalysis report (AnnexureIII) carried out by Sindh Fisheries Department, the soil ishighly saline in nature and low in organic contents. The salinity is high at the surface anddecrease with soil depth. The PH ranges from 8.7 to 9.0. Climatically, the area can be

categorized as subtropical maritime desert. There are two distinct seasons; summer(March June) and winter (November to February). Average annual rainfall is about 221

mm and in some years virtually there is no rainfall during the monsoon season. Windsblow from the west during March to October and from north-east during November to

January. During peak monsoon season, wind speed rises to an average of 8 knots(Heokstra et al. 1997).

4.2 Ecological Resources

The proposed aquaculture pond site falls under the sub-category of sparse mangroveforests and forms the part of northern block of Keti Bundar mangrove forests falling

under the administrative control of Sindh Forest Department. These mangrove forestshave been declared as Protected Forests vide West Pakistan Government Notification

No. S.O.A.(X)F&A/581X-(32) dated August 29, 1958 and subsequently declared asWildlife Sanctuary vide Government of Sindh Wildlife & Forest Department NotificationNo. WL&FT(DCF-GEN-269).77 dated September 25, 1977. The Keti Bundar block startsfrom Dabbo creek to the area bordering Port Qasim Authority. The mangrove coverunder this block is recorded as 40,874 ha out of which 14,733 ha area falls under densemangroves while remaining area constitutes normal and sparse vegetation Qureshi(1985). A sizeable patch of mangrove forest exists at a distance of approximately 1kilometre from the proposed site showing semi-homogenous edaphic patterns, as the

terrain is exposed to seasonal and diurnal inundations; therefore the soil has the hardtop showing crusts at places with salt in it. The sub soil area is wet and showed presence

of waterlogged regimes. The agriculture productivity of such soil always been reportedlow; as it does not offer much air to accommodate for roots to assimilate.

The vegetation is dominated mostly by shrubs; however variations in vegetationcomposition were observed with varying microhabitats. The floristic list of the area isshown as per Annexure IV. The patches of mudflats in the terrain were observedhospitable forAvicennia sp to germinate and establish. The dominant life forms consistedhalophytes belonging to family Chenopodiaceae. The other significantly represented

members of the floristic list belonged to Poaceae, Asteraceae and Zygophylliaceae. Theareas close to the habitations were under agricultural use with wheat, rice and sugarcane

and vegetables as major crops but with compromised productivity and quality levels.

The Keti Bundar and surrounding area is reported to have some 69 species of avifaunawith a composition 25 resident species and 44 migratory species, besides 21 species ofreptiles and 2 species of amphibians, 63 species of fin fish and 24 species of shell fish.More than 15 mammalian species including both terrestrial and aquatic representativeswere also reported in the area (IFAP 2007). There are reports of dolphin citation in thearea. A drastic decline in fish catch has been observed and reported. The same pattern

was followed by Prawns and Crabs. The majority of villagers earn their livelihoods fromfishing and fish related products. Crab fattening ponds and prawn culture were found in

operation in the area by private parties with promising success and gain. The activity isreported being successfully carried out since last six years. The semi-abandoned

fisheries infrastructure also exists in the vicinity of proposed pond site.

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4.3 Socioeconomic Profile

The sub-project falls in Union Council Garho, Tehsil Ghorabari, district Thatta. The fishingsettlements of Muhammad Ali Sholani, Allahno Sholani, Amir Jat and Piryo Lashari existnear the proposed site in a homogenous unit. The village Allah Dino Sholani comprises of

39 households with a population of 237 residents (NRSP, n.d). Another adjacent village,Ali Dino Sholani consists of approximately 400 households. A community organization

(CO) formed by NRSP exists in the village Allah Dino Sholani.

The predominant occupation of the area is fishing and fishing related activities such asfish cleaning or drying and occasionally fish net repairing and weaving. Agriculture issecond major occupation of the area. Agriculture is practiced using canal irrigation. Asmall percentage of the residents are occupied as factory workers, shopkeepers, woodcutters and professional workers. A sugar mill exists in the area. The major livestock inthe area includes goats, buffaloes and cows.

All villages are older coastal settlements whose inhabitants have lived there for

generations. Ethnic composition of the villages consists of Baloch and Sindhi origin. Themain languages, Balochi and Sindhi vary according to the ethnic groups. The majority of

inhabitants in these villages are residents by birth. Some had in-migrated from otherareas of Thatta district.

The livelihoods of local communities depend mainly on fishing and use of mangroves forfuel wood, thus, well integrated into the coastal environment. Women are reportedlyemployed in fish related activities such as fish drying and cleaning and agricultural

activities. However, observation is based on the experience of field work in this area inthe past. The actual data to substantiate this assertion is unavailable since information

from female respondents could not be collected. During community consultation, it wasrevealed that the average household earning ranged from Rs.4000-5000 per month from

the fishing. The income from seasonal cultivation ranged from Rs.500-600 per month.

Since fishing is the main economic activity of the coastal communities, fishing ispracticed through the year, even during the banned period. Majority of fishermen areagainst the imposition of ban, as they do not have alternate livelihood. There is no easysolution to this problem; however, the effects of over-fishing would have severeconsequences on sustainability of fisheries. If economic alternatives such asshrimp/crab/fish farming at household level were promoted, the fishermen could use

such ponds for sustaining their livelihoods during banned period. It was important tonote that the majority of the fishermen were quite skeptical about the results of the

proposed aquaculture activities in the area, due to failure of such efforts by the FisheriesDepartment in the past.

4.4 Quality of Life

Socio-economic conditions of the villages and settlements are almost identical. In

general, the shortage of water, the absence of education, housing and health facilitiesare some of the common issues prevalent in the area. There is a great disparity between

physical infrastructures found in the villages Garho town. The types of houses or sheltersin the villages consist of mostly thatched and a few of brick made houses. No sanitationand water supply facilities exist in the villages. The canal water and hand pumps are thesources of drinking water for the local communities. The literacy ratio is extremely low.The communication facilities are relatively better developed due to nearness to the majortown and satellite telephone service.

The average household size is seven members. The diseases such as Malaria, Cholera,T.B, Renal, Skin and ENT were common in the area. The preliminary physical data do not

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show environmental pollution of great magnitude, it seems likely that the frequency ofsuch symptoms may be due to pollution as well as are the reflection of the absence ofthe civic amenities in the area. Due to ethnic and professional homogeneity, communityconflicts are less prevalent. The local Bradari (communal) system is used to resolvecommunity conflict.

5.0 Potential Environmental Impacts & Mitigation

Measures

5.1 Environmental Impacts Due to Existing Site

a. Legal Position

As indicated under para 4.2 above, the proposed site for establishment of proposed pilotaquaculture ponds along Ambra creek (240 20 11.1 north latitude and 0670 35 39.6east longitude) is part of the Protected Forest notified in 1958 under Pakistan ForestAct 1927. Administratively, the area falls under the jurisdiction of Sindh Forest & WildlifeDepartment. Subsequently, the same area has been declared as Wildlife Sanctuary in1958 under Sindh Wildlife Protection Ordinance 1972. Under these laws proposedaquaculture activities are prohibited within the areas or protected forest or WildlifeSanctuary. The site position also reveals the area to be un-surveyed wasteland. It seemsthat the area has been claimed by the local resident Mr. Allah Dino Sholani. This claim is

not supported by the Record of Rights (Form VII) to verify actual ownership of the land.Further, the agreement signed between landowner and the Sindh Fisheries Department

does not mention survey number(s) of the proposed land.

b. Groundwater

The site for establishment of proposed pilot aquaculture ponds is located on AmbraCreek near Garho town. As per design, there will be ten ponds constructed in a series onone hectare plot. The ponds will be established at the current location to take advantage

of the tides to fill ponds and later for flushing. Since the ponds are located right next toAmbra Creek, the issue of ground water contamination due to saline water is negligible.

The water table is already very high in the area which was evident from the trench dugbetween the aquaculture ponds to create a dyke for protection from high tide. Theestablishment of new ponds will have a very negligible impact on the existing water tablein the area.

There are already existing 30 to 40 aquaculture ponds in the vicinity established,owned and operated by different parties. Some ponds were established under a project

funded by Asian Development Bank in late eighties or early nineties by the SindhFisheries Department. Since several ponds are already functioning in the area, the

impact on groundwater quality due to the establishment of new ponds would be minimal.

c. Agriculture

Agriculture is one of the most prominent sources of livelihoods in the area. During thefield visit, some agriculture activity was noticed at about 500 meters from the location ofthe ponds. Despite the presence of several aquaculture ponds and high water table in

the area, agriculture is being successfully practiced at some distance from the projectlocation. Establishment of ten new pilot ponds is likely to have very minimal impact on

agriculture in the area.

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d. Structures

A few houses were noticed at a distance of about 500 meters from the proposedaquaculture ponds location. As mentioned earlier, the water table in the area is alreadyvery high due to close proximity of Ambra Creek and 40 45 aquaculture ponds.Establishment of ten new ponds might only increase water table slightly and not have

any major impact on structures in the area.

e. Erosion

Erosion of boundary walls of the existing aquaculture ponds was very evident. It wasnoticed that some of the existing ponds were abandoned mainly due to serious erosionof the embankments towards Ambra Creek whereas; many ponds were noticed erodedaway into the creek. If proper protection measures are not adopted, it is very likely thatthe pond embankments will erode away rendering the established ponds lost to thecreek permanently. Further, the coastal areas have been subject to extreme weatherphenomenon during recent times, hence potential risks of erosion and flooding may not

be underestimated.

5.2 Environmental Impacts Due to Project Design

Although the existing site is well suited for aquaculture ponds, it is not the appropriate

site keeping in view the project objectives. The proposed aquaculture pilot ponds arelocated in a series at a single location on piece land claimed by an influential person of

the village to be his private land. One of the key objectives of the Project is to improvelivelihoods among poor masses of the area. By establishing aquaculture ponds on theland of an influential person, one of the key objectives of the project is compromised.

The establishment of ten pilot aquaculture ponds in a series at one location is also not

inline with the project objectives. As per design, pilot ponds were to be established in theKeti Bundar and Shah Bundar areas taking advantage of the natural creek system. No

extensive infrastructure development was envisaged to make them less intensive andreplicable by the poor fisherfolks. The reason for using creek system as aquaculture

ponds was to develop a model which can be easily replicated by communities with littleinvestment. It is also aimed to diversify income generating opportunities for the poorfisherfolk communities. The existing design of ponds at the present locations wouldrequire investment cost too high for a poor fisherfolk to afford and replicate the existingmodel. Therefore, the current model appears very resource intensive and may not be aviable option to meet the project objectives.

In the project area, several abandoned ponds were noticed which had been constructed

by Fisheries Department under an ADB loan in mid nineties and other similar initiativesin the past. After talking to some fisheries experts and locals in the area, it wasdiscovered that the reason of failure of the previous initiatives was due to a lack of

proper planning before making the investment, mainly assessing the community needsand sustainability of the initiative. Several large ponds were constructed, and heavypumps and generators installed without taking into consideration the issues ofsustainability of the established infrastructure. Therefore, the sustainability of suchinitiatives requiring higher investment is rather questionable looking at the track recordof similar initiatives.

Even if the project manages to deliver on its outputs during the project duration, there isno guarantee of its sustainability post project closure. Although a profit sharing

mechanism between communities is to be established under the project, there is noguarantee that the influential person on whose land the ponds are proposed to be

established may honour his commitments made under the project once it closes.

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Contrary to this, if single ponds managed by poor individual households are establishedin natural creek system, the beneficiaries would be fewer and belonging to the samevillage or household making it easier for them to manage and sustain.

As per the project document, the proposed aquaculture ponds were to be piloted andexpanded in the coastal areas of Keti Bundar, Shah Bundar and Zero Point targeting thepoor fisherfolks and those who have no other sources of livelihoods except fishing. The

proposed intervention was aimed to provide primary or secondary source of income topoor communities. However, as per current design, the ponds are being piloted in an

area where people are relatively well off and have multiple sources of livelihoods such asfishing, agriculture, and trading. If the proposed interventions were piloted in Keti

Bundar, as originally conceived, where sources of livelihoods were limited to fishing only,the project may yield much higher positive benefits for the target beneficiaries throughcreation of alternate source of livelihood for them.

5.3 Environmental Impacts Due to Project Construction

Following are some of the potential impacts due to construction of aquaculture ponds:

a. Groundwater

Although, the construction of pilot ponds covers approximately one hectare land,contamination of groundwater may be a potential issue if the constructed ponds get

eroded away to create a passage for inland intrusion of creek water. Underground wateris an important source of freshwater of the local population. The IEE team was informedthat good quality water is available at 18 to 20 feet. It is therefore important thatearthen pond embankments are properly reinforced to prevent inland seawater intrusionand flooding of agriculture lands. Further, any indiscriminate dumping of waste oil fromvehicles, chemicals or any other contaminants may also result in groundwater

contamination, if not properly disposed.

b. Dust

Dust is an inherent problem in construction activities especially if excavation is required.

It is very likely that dust will be an issue in the area during construction. However,considering that the project site is located at a distance of almost one kilometre from thehabitations, impact on the population may be minimal and temporary.

c. Noise

The movement of heavy machinery especially when it passes through the residential

areas will result in noise. Similarly operation of the machinery at the project site will be asource of noise. However, since the site is at some distance from the habitations, it may

have very minimal impact on the people living in the vicinity. Similarly the town bazaarfrom where the machinery will pass is already a very noisy place. Any additional noisedue to movement of machinery may not be a major issue. The cumulative impact of allforms of noise resulting from construction at the project site may be a source ofdisturbance to people in the area. However, through proper mitigation measures theimpact generated due to noise during construction phase may be minimized at theproject site.

d. Excavated Soil/Material:

Disposal of the excavated soil is a potential issue at the project site. The current site islocated next to other aquaculture ponds and very little space is available for the disposal

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of excavated soil. Finding of appropriate site for the disposal of excavated material willrequire careful consideration by the project proponent. Any improper disposal of the soilmay result in issues with the community in the area. No disposal should be allowed onprivate land especially aquaculture ponds or agriculture

e. Agriculture

Agriculture is one of the key sources of livelihoods of the local communities. However,given the smaller nature of construction activities, it is unlikely that the construction

activities may have a major negative impact on agriculture in the area. However, it is ofutmost importance to take proper precautionary measures to avoid any potential impactsof construction activities on agriculture in the area particularly due to setting up ofconstruction camp and its activities, disposal of waste material and parking or movementof heavy earth moving machinery.

f. Construction Camp

If the contractor decides to establish a camp for the construction of ponds, it may

potentially result in environmental and social impacts. The environmental impacts aremainly generation of wastewater and solid waste. However, considering the overallwastewater and solid waste management in Garho, the issue is of a very minimalconcern but needs to be given attention particularly when the camp is located within theagriculture field. There could be potential social issues if the contractor decides to bringexternal labour instead of using local labour. This can potentially lead to conflict if thelabour is involved in practices not acceptable in local cultural context. However, it is verylikely that the contractor will use local labour to cut cost and to avoid any potential

conflict with the local population.

g. Community Safety

It may be a potential major concern in this initiative. Heavy earthmoving machinery willbe used for excavation purposes which will cross from narrow town streets and villagelink roads to reach the construction site. Any carelessness on part of the operator or ofthe community may potentially result in an accident. It is particularly important to payattention to the safe speed limits and keep an eye out for children in the area who are

more vulnerable to such accidents.

h. Occupational Health and Safety

It may be a potential major concern in this intervention because of the use of heavyearthmoving machinery, civil works and difficult working conditions. Careless operation

of heavy machinery may potentially cause injuries to staff and labour. Similarly othercivil works such as construction of dykes / protective walls using big stones to check seaerosion may potentially be harmful for labour if proper protective gear is not provided.Although labour in Pakistan is not very fond of wearing protective gears such as helmets,it is up to the contractor to ensure that the protective gears are used by labourers to

protect them against any potential injuries. In addition, harsh summer weather when theconstruction might take place may be another potential risk for the labourers to suffer

from heatstroke. Labour intensive tasks should be avoided during day times when themercury is at its maximum.

5.4 Environmental Impacts Due to Project Operation

Some of the potential environmental impacts during the operation of aquaculture pondsare as follows:

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a. Biodiversity

The introduction of any fish species which is alien and potentially invasive is a potentialthreat to marine biodiversity in the area. Only local species should be introduced in thepilot ponds. Since mangrove plantation is proposed to address erosion issues, it isimportant that local mangrove species are used such as, Avicenia marina. Similarly if

there is any other plantation to be done in this project, only local species should be usedand other species such as Eucalypts should be avoided. Further, the use of chemicals

and fertilizers is a common practice in aquaculture activities. Excessive use of thesechemicals and fertilizers may be a source of aquatic pollution.

b. Sludge/ excavated material disposal

During the project operational phase, it is likely that desilting /excavation will berequired to restore capacity of the ponds. Any indiscriminate dumping on adjacent land,agriculture fields, adjacent ponds or sea will result in environmental and social issues.Dumped material becomes a source of dust in the area and eventually ends up in the

ponds again by wind and rain. It may create problems for farmers if dumped onagriculture land and for communities if dumped on their daily routes. Hence excavated

material is a continuous nuisance if not disposed properly.

5.5 Mitigation Measures

a. Legal Position

The validity of claim of ownership of the land needs to be validated from record ofRevenue Department and Sindh Forest & Wildlife Department. As per project document(p-119) aquaculture sites are to be sited at locations which are not ecologically sensitiveor wildlife areas.

b. Construction

Soil Erosion & Flooding: The pond embankments shall be properly compacted andreinforced to prevent erosion of soil, permanent loss of constructed ponds andconsequent flooding due to intrusion by creek water. Stone pitching would be essentialfor embankments facing the creek flow directly. Protective planting of mangrove plantsalong the embankment and creek frontage should help in providing a sustainablemeasure to prevent erosion of the creek and pond embankments.

c. Groundwater

Disposal of any chemicals, waste oil or any other contaminants should not be dumpedindiscriminately to avoid contamination of groundwater. Vehicle maintenance should beundertaken at a specified location and all waste should be collected and not disposedindiscriminately. All waste oil should be collected and given to vendors in recyclingbusiness. Similar caution should also be taken while handling other chemicals.

d. Waste Disposal

Extra care should be taken to avoid any direct or indirect impact of construction onagriculture fields in the area. No waste material should be dumped on agriculture land. If

a construction camp is to be setup, it should be at a safe distance from agriculture fieldsto avoid any impact due to construction camp activities. No heavy machinery should be

parked on agriculture land to avoid soil compaction.

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When an excavation is undertaken for construction purposes and later during the projectoperation to restore capacity of the ponds, the disposal of the sludge/ excavatedmaterial should be properly undertaken. Dumping of the waste materials on adjacentland, agriculture fields, and aquaculture ponds or in the sea should be strictly avoided.The disposal of solid waste produced during pond construction and operation should beundertaken in consultation with local authorities and owners of the land, if the site is a

private land.

e. Air Pollution

To minimize air pollution due to dust emission or transport of waste materials duringconstruction or operation, the waste materials should be transported in covered vehiclesespecially if the route is through town areas and frequently used roads. Transportationshould preferably be undertaken during night to avoid inconvenience to people and roadusers. If the temporary storage is necessary at the site, the waste should be sprinkledwith water to suppress dust.

f. Noise Pollution

Noise is not a major issue during construction since the project site is at some distancefrom the settled area. However, the movement of machinery through Garho Town orthrough habitation may create a temporary noise issue. It is recommended that theheavy machinery and dumper trucks should use any bypass roads to avoid town centreor village habitations during day and night time. In case, if bypass option is notavailable, the town administration and local communities should be consulted to suggesttimes for maximum movement of heavy traffic.

g. Construction camp

If the contractor decides to setup a camp, it should be located close to the constructionsite. The site should be provided by the community after taking due permissions fromthe owner. After the construction is complete, the camp should be properly dismantledand the site rehabilitated. Any structures constructed should be demolished if the ownerdoes not want them. Solid waste should be collected and dumped at the municipaldumping area. Wastewater from the camp should not be indiscriminately discharged out

in the open. As far as possible, the contractor shall prefer engagement of localcommunity members as labourers to avoid chances of social conflict and provide

employment to the local people. The contractor should ensure that the labour employeddoes not create any problems for the community. .

h. Community Safety

If possible, a bypass should be used for the movement of heavy earthmoving machineryand town streets should be avoided to the maximum possible extent. However, if bypassis not available, extreme care should be taken while moving earth moving machinerythrough town streets or village habitations. The safe speed limits should be strictly

enforced during movement of machinery or such movement should preferably be carriedout at night time when the streets are empty. Any movement during the day should be

done carefully with the help of some staff to clear and warn people of machinerysmovement. The machinery should have proper lights and reflectors. The project areashould be strictly prohibited for the movement of people who are not working for theproject, especially children. The ponds should have safety markings especially warningtape around the site to keep unauthorized people away and also to forewarn people ofpotential risks that lie at the construction site.

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i. Occupational Health and Safety

The staff and labour should be provided protective gears. It is the duty of the projectcontractor to ensure that the staff wears protective gears. A first aid box should beavailable at the project site to deal with emergencies. The camp office and constructionsite should be properly guarded to avoid threats associated with unauthorized use of

stored equipment, chemicals and machinery.

j. Biodiversity

To prevent biodiversity loss, no exotic or alien and invasive species should be introducedin the pond. Only recommended local species of crab and shrimp should be tried in thepond. The excessive use of chemicals and fertilizer should be avoided to prevent aquaticpollution.

6.0 Analysis of Alternatives

a. No Project Option

It is a good project and it should definitely be implemented. Improving livelihoodsthrough providing better alternatives such as aquaculture is one of the best ways ofalleviating poverty of the fisherfolks in the area. However, the project should beimplemented in line with the project objectives and ensuring sustainability of theinitiative.

b. Design Alternatives

The existing design of ten ponds in series is not consistent with the project objectives.

The existing design needs reconsideration to make pilot interventions within the reach ofpoor households and make their replication feasible. The current design requiresconsiderably high investment for excavation and other infrastructure developmentswhich may be beyond the reach of poor and heavily indebted coastal fisherfolks. Theproject objectives envisage that any initiative undertaken should be easily replicable inother parts of the coastal area which is an issue in the current design.

Therefore, the inherent flaws in the current design should be carefully reviewed before

implementation. Ideally, individual household based ponds would be a useful option todistribute project benefits widely, take advantage of natural creek system, introduce low

input technology that requires minimal investment and is sustainable, and target those

areas where there are no other livelihood alternatives is available except fishing. Also,such a strategy may provide an opportunity to test and compare the results atdiversified locations.

c. Site Alternatives

Although the site chosen for the project is suitable for aquaculture, it is not consistentwith the criteria and locations specified in the project document (PC-I) for pilot testing of

aquaculture activities. The project document proposes Keti Bundar and Shah Bundarareas for initial pilot testing of aquaculture activities for the reasons mentioned under the

preceding para. Many potential alternate sites exist within the natural creek system inKeti Bundar and Shah Bundar. Further, the area falls under administrative and legal

jurisdiction of the Sindh Forest & Wildlife Department and would require such approvalfrom the government.

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d. Input Alternatives

The current design for establishment of aquaculture ponds would require considerablyhigh investment which will be beyond reach of a poor fisherfolk which are the targetbeneficiaries of the project. Therefore, following the design which requires less input costby taking the advantage of natural creek system may yield better profit margins.

7.0 Public Consultation and Disclosure

Public consultation was carried out with the purpose to receive and record stakeholders

views related to objectives and other aspects of the proposed aquaculture ponds,including the issues of sustainability, integration of social and environmental concernsand quality of life. It was also intended to reflect expectations, fears, apprehensions andgeneral views of the people of the area and that through this consultation process;comments can be received, issues can be prioritized and changes can be made

whatsoever appropriate during the project implementation.

Public consultation focused on primary and most directly relevant stakeholders,

particularly the local communities, involved with the project. Formal and informalinstitutional consultation was made with Sindh Fisheries Department, local NRSP officials,

Community Organisations (COs), private entrepreneurs, fish traders, and adjoiningcommunity members. Consultation process was completed by adopting an interactiveand participatory method; to ensure equal opportunity of expression to each and everyparticipant and record their perceptions about the proposed intervention. Majority of theconsultations took place in and around the project site and the details of the discussionof consultation were incorporated in the report.

Formal and informal community consultations were held with the relevant communities

and other relevant stakeholders more than three times at and near the project site.During community consultations the information about project and the proposed

aquaculture interventions was shared with the community members in anunderstandable and culturally appropriate way. Views of female participants could not berecorded due to socio-cultural reasons. However, supportive views of female communitymembers for the proposed interventions were relied from discussion with female socialworkers of NRSP.

Generally the attitude of local communities was very positive towards the proposedinterventions in the area. The community members expected that this project would

improve the general economic conditions and livelihoods of the local people by creatingemployment opportunities during the different phases of the project construction and

operation. However, some of the adjacent households feared privacy issues ifstaff/labour for pond establishment and operation was hired from outside the

community.

8.0 Conclusion and Recommendations

Promotion of aquaculture activities under Sindh Coastal Community Development Projectis aimed at diversifying income generation opportunities for coastal fisher folkcommunities. Under the project, a total of 100 each shrimp and crab ponds and rafts of

oyster mussels and seaweeds are planned to be established in coastal areas of Keti

Bundar, Shah Bundar and Zero Point near Ahmad Rajo based on successful initial pilotingthrough construction and operation of twenty (20) each ponds and rafts.

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As mandated under the project, IUCN Pakistan is responsible for environmental baseline,monitoring, and advisory on crab and prawn pond environmental impacts and mitigationmeasures to prevent environmental damage. An initial environmental assessment of siteselected at Ambra Creek by Sindh Fisheries Department for establishment of 10 pilotshrimp and crab ponds was carried by IUCN team of experts before the start of project.

The assessment has revealed that the proposed site, although suitable for aquaculture,is inconsistent with criteria specified and locations recommended for piloting in the

project document i.e. Keti Bundar and Shah Bundar. Except active creek erosion,screening process has not identified any other major negative environmental issues

related to operation of the proposed intervention, due to smaller sale of proposedactivity involving approximately one (1) ha of infertile land.

However, the assessment has revealed major concerns related to the site and design ofproposed intervention. In terms of environmental concerns, the proposed site falls withinthe boundaries of protected forests and wildlife sanctuary. In terms of design, it isinappropriate to meet the project objectives and transfer project benefits to the targetbeneficiaries. Being cost and infrastructure intensive, the proposed design appears to be

beyond the reach of poor fishing households making its replication by target beneficiariesquestionable. The site and design in question needs to be reconsidered to make it

consistent with the project objectives. Low technology, low input and single householdmanaged ponds are proposed as the suitable alternative to distribute project benefits

widely and making its replication feasible.

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9.0 References

Heokstra, D. A., N. Mahmood., G. R. Shah, W.A. Shah., M. A. Domki., and Q. M. Ali. 1997.

Diagnostic study Indus delta mangrove ecosystem, main sub-system

characteristics, problems, potentials, proposed interventions and pilot sites,

Subproject, RRIDM (World Bank/GoS funded). 76 pp.

IFAP 2007. Detailed Ecological Assessment of Fauna including Limnology Studies at Keti Bundar.

NRSP, n.d. Situational Analysis and Profile of village Allah Dino Sholani (un-published)

Qureshi, M. T. 1985. Working Plan of Coastal Forests (1985 -86 to 2004 05) Sindh Forest

Department.

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Annexure I

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Annexure II

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Annexure III

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Annexure IV

Detail Floristic list of the area adjacent to Ambra creek:# Taxon Family1

Blepharis sindica Stocks ex T. And. Acanthaceae2 Achyranthes aspera L Amaranthaceae

3 Pentatropis nivalis (J.F.Gmel.) Field &J.R.I.Wood Asclepiadaceae

4 Conyza aegyptiaca Ait. Asteraceae

5 Launaea procumbens (Roxb.) Amin Asteraceae

6 Sonchus asperFig. Asteraceae

7 Avicennia marina (Forssk.) Vierh Avicenniaceae

8 Heliotopium ophioglossum Boiss Boraginaceae

9 Capparis decidua (Forsk.) Edgew Capparidaceae

1

0Arthrocnemum macrostachyum (Moric.) C.Koch Chenopodiaceae

1

1Arthrocnemum indicum (Willd.) Moq Chenopodiaceae

1

2Atriplex stocksii Boiss Chenopodiaceae

1

3Chenopodium album L Chenopodiaceae

1

4Salsola imbricata Forsk Chenopodiaceae

1

5Suaeda fruticosa Forsk. ex J.F.Gmelin Chenopodiaceae

1

6Suaeda monoica Forsk. ex J.F.Gmelin Chenopodiaceae

1

7

Convolvulus arvensis L Convolvulaceae

1

8

Cressa cretica L. Convolvulaceae

1

9

Cyperus bulbosus Vahl Cyperaceae

2

0

Euphorbia serpens Kunth Euphorbiaceae

2

1

Alhagi maurorum Medic Fabaceae

2

2

Acacia nilotica Delile Mimosaceae

23

Prosopis juliflora Swartz Mimosaceae

2

4

Commicarpus boissieri (Heimerl) Cufod Nyctaginaceae

2

5Aeluropus lagopoides (L.) Trin. ex Thw Poaceae

2

6Chloris barbata Sw Poaceae

2

7Cynodon dactylon (L.) Pers. Poaceae

2

8

Desmostachya bipinnata (L.) Stapf Poaceae

2

9

Paspalum vaginatum Swartz.. Poaceae

3 Pennisetum purpureum Schum. Poaceae

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0

3

1Phragmites karka (Retz.) Trin. ex Steud. Poaceae

3

2Sporobolus virginicus (L.) Kunth Poaceae

3

3

Salvadora persica L Salvadoraceae

3

4

Tamarix indica Willd. Tamaricaceae

3

5

Typha angustata Bory & Chaub Typhaceae

3

6

Fagonia indica Burm.f. Zygophyllaceae

3

7

Zygophyllum simplexL. Zygophyllaceae

Documents

SCCDP Garho Initial Environmental Examination Sindh Pakistan.doc