SCCDP Garho Initial Environmental Examination Sindh Pakistan.doc

Table of Contents Table of Contents...................................................................................................1 Executive Summary...............................................................................................2 1.0 Introduction....................................................................................................3 2.0 Purpose and Scope of the Report........................................................................3 3.0 Description of Sub-project.................................................................................4 3.1 General Features..........................................................................................5 3.2 Technical Features of Shrimp and Crab Ponds...................................................5 3.3 Technical Features of Oyster, Mussels and Seaweed Rafts..................................6 3.4 Type and Category of the Project:...................................................................6 3.5 Location of Project........................................................................................6 3.6 Objectives of Project.....................................................................................7 3.8 Size & Magnitude of Operations and Implementation Schedule...........................8 3.9 Government Approval and Leases...................................................................8 4.0 Description of Environment................................................................................8 4.1 Physical Resources........................................................................................8 4.2 Ecological Resources.....................................................................................9 4.3 Socioeconomic Profile..................................................................................10 4.4 Quality of Life ............................................................................................10 5.0 Potential Environmental Impacts & Mitigation Measures.......................................11 5.1 Environmental Impacts Due to Existing Site...................................................11 5.2 Environmental Impacts Due to Project Design.................................................12 5.3 Environmental Impacts Due to Project Construction.........................................13 5.4 Environmental Impacts Due to Project Operation............................................14 5.5 Mitigation Measures.....................................................................................15 6.0 Analysis of Alternatives...................................................................................17 7.0 Public Consultation and Disclosure....................................................................18 8.0 Conclusion and Recommendations....................................................................18 Annexure I..........................................................................................................21 Annexure II.........................................................................................................23

Executive Summary The Sindh Coastal Community Development Project (SCCDP) is being implemented by the Sindh Coastal Development Authority (SCDA) in coastal areas of Thatta and Badin through government agencies (Sindh Forest Dept., Sindh Fisheries Department, and District Governments) and non-government organizations (NRSP and IUCN). The project is funded by the Asian Development Bank. IUCN has been entrusted with the planning and implementation of community mangrove planting, and management and environmental assessment of aquaculture under the sub-component on improved coastal management. This report presents findings of an initial environmental assessment of the pilot aquaculture site for establishment of 10 shrimp/crab ponds on approximately one hectare land identified by the Sindh Fisheries Department along Ambra creek near Garho Town of the Thatta District. The initiative is being managed by the community mobilized by 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 from Garho Town. Administratively, the area falls under jurisdiction of the Sindh Forest & Wildlife Department. The selected site was declared a “Protected Forest” in 1958 under the 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 Protected Forest or Wildlife Sanctuary. The site location also reveals that the area is an un-surveyed wasteland. It seems that 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. The site itself is affected by salinity and has no potential for agriculture in future. The establishment of new ponds will have a very negligible impact on the existing water table in 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 key objectives of the project – to improve livelihoods among poor masses of the area – is susceptible to be compromised. The existing design of ponds at the present locations requires high investment which for a 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 it consistent with the project objectives. Low technology, low input and single household managed ponds are proposed as the suitable alternative to distribute project benefits widely 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 Badin through government agencies (Sindh Forest Dept., Sindh Fisheries Department, and District Governments) and non-government organizations (NRSP and IUCN) with different 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 ways sustainable 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 development and management of fisheries resources

zone

planning

and

The complex nature of the project demands effective cooperation between organizations for 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 public services in place

In the role of consultant IUCNP has been working very closely with NRSP and Sindh Forest and Fisheries departments for the implementation of SCCDP. Under the sub-component improved coastal management, IUCNP is tasked with the planning and implementation of community planting, management and environmental assessment of aquaculture in the coastal areas of the Thatta and Badin districts. IUCN Pakistan’s key roles in the ADB funded ‘Sindh Coastal Community Development Project are: 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 of mangrove by the Dept of Forestry on government owned land.

iii.

To monitor environmental impacts of the aquaculture related activities to be undertaken 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 are to 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 establish 80 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 engaged in the pilot initiatives with support form NRSP and environmental assessment and monitoring of pilot interventions and subsequent expansion is to be carried out by IUCN Pakistan 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 of approximately 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, screened and assessed. Mitigation measures to address the potential environmental impacts have been proposed and a monitoring plan has been suggested for continuous monitoring of the 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 analyse environmental impacts of proposed aquaculture intervention during design, construction and operation phases. The scope of this environmental assessment report is limited to environmental situation within the immediate surrounding of the identified site. The assessment covers physical, biological and socio-economic parameters pertaining to the proposed pilot aquaculture intervention. The assessment was conducted by a multidisciplinary 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 were conducted to collect required information. These included joint visits with relevant fisheries officials, meetings with local NRSP staff, discussion and consultation with community members. In addition, background project documents and literature was reviewed 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 family income. As per project document (PC-I) the proposed interventions entail development of shrimp and crab ponds, with further work on a pilot basis in oyster, mussel and seaweed raft cultivation. It is intended to establish mariculture pond and raft system comprising small, low technology ponds supported by mangrove plantings. The project document 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 Zero Point 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 managed initiatives which fall in Schedule-I of the ‘Pakistan Environmental Protection Agency (IEE and EIA) Regulations 2000’. For such project, Initial Environmental Examination is required which deals with preliminary assessment of predicted quantitative and qualitative environmental impacts of a project to know if there are any adverse impacts that may require a full scale EIA.

3.5

Location Project

of

Site for the proposed (10) pilot aquaculture ponds is located adjacent to Ambra creek (240 20’ 11.1” north latitude and 0670 35’ 39.6” east longitude) at a 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 has entered into an agreement (Annexure I) with a private landowner, Mr. Allah Dino Sholani to 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 coordinates of 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 of the Sindh Forest & Wildlife Department (Annexure II).

3.6 Objectives of Project i. ii. iii. iv.

Aquaculture based on community ponds and rafts will provide livelihood opportunities. Enhance income of the communities engaged in operation of aquaculture activities. Enable communities to better manage their natural resource base, enabling more diversified, regular and sustainable income from these sources. Develop sustainable alternatives that reduce pressure on the capture fisheries.

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 prescribed in the Sindh Coastal Community Development Project being executed by Sindh Coastal Development 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 and oyster, mussel rafts has been selected by Sindh Fisheries Department keeping in view nearness 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 Sindh Fisheries Department. The identified site is affected by salinity and has no potential for agriculture 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 the proposed 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 completed during the first year of SCCD project, however the operation phase will remain continue through out the project implementation period and beyond and would require continuous monitoring.

3.9 Government Approval and Leases The proposed pilot aquaculture activities are being implemented as one of the subcomponents of Sindh Coastal Community Development Project being executed by the Government of Sindh through Sindh Coastal Development Authority. As such the propose interventions are endorsed by the government. Further, implementation and technical supervision of proposed aquaculture activities is being carried out by the Sindh Fisheries Department is responsible Sindh Government Agency. The designed pilot project intervention would require approximately 1 ha land, which has been 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 the purpose. However, GPS coordinates of 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 of the Sindh Forest & Wildlife Department. Thus, necessary government approval would be required. The pilot rafts are to be sited in the mangrove creeks and require no land as such. As per project document, in all the expansion to a proposed 100 aquaculture ponds would require 75 ha land government or community owned land, many hectares of suitable government owned land has been identified as potentially available in inter-tidal zone, 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 to Garho 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 area consists of agricultural plains interfaced with inter-tidal creek zone. Being, adjacent to the creek the proposed aquaculture ponds site consists of saline wasteland. As per soil analysis report (Annexure–III) carried out by Sindh Fisheries Department, the soil is highly saline in nature and low in organic contents. The salinity is high at the surface and decrease 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. Winds blow 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 mangrove forests and forms the part of northern block of Keti Bundar mangrove forests falling under the administrative control of Sindh Forest Department. These mangrove forests have 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 as Wildlife Sanctuary vide Government of Sindh Wildlife & Forest Department Notification No. WL&FT(DCF-GEN-269).77 dated September 25, 1977. The Keti Bundar block starts from Dabbo creek to the area bordering Port Qasim Authority. The mangrove cover under this block is recorded as 40,874 ha out of which 14,733 ha area falls under dense mangroves while remaining area constitutes normal and sparse vegetation Qureshi (1985). A sizeable patch of mangrove forest exists at a distance of approximately 1 kilometre from the proposed site showing semi-homogenous edaphic patterns, as the terrain is exposed to seasonal and diurnal inundations; therefore the soil has the hard top 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 reported low; as it does not offer much air to accommodate for roots to assimilate. The vegetation is dominated mostly by shrubs; however variations in vegetation composition were observed with varying microhabitats. The floristic list of the area is shown as per Annexure IV. The patches of mudflats in the terrain were observed hospitable for Avicennia sp to germinate and establish. The dominant life forms consisted halophytes belonging to family Chenopodiaceae. The other significantly represented members of the floristic list belonged to Poaceae, Asteraceae and Zygophylliaceae. The areas 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 avifauna with a composition 25 resident species and 44 migratory species, besides 21 species of reptiles 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 representatives were also reported in the area (IFAP 2007). There are reports of dolphin citation in the area. 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 from fishing 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 is reported 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 fishing settlements of Muhammad Ali Sholani, Allahno Sholani, Amir Jat and Piryo Lashari exist near 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 as fish cleaning or drying and occasionally fish net repairing and weaving. Agriculture is second major occupation of the area. Agriculture is practiced using canal irrigation. A small percentage of the residents are occupied as factory workers, shopkeepers, wood cutters and professional workers. A sugar mill exists in the area. The major livestock in the 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. The main 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 other areas of Thatta district. The livelihoods of local communities depend mainly on fishing and use of mangroves for fuel wood, thus, well integrated into the coastal environment. Women are reportedly employed 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 in the past. The actual data to substantiate this assertion is unavailable since information from female respondents could not be collected. During community consultation, it was revealed 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 is practiced through the year, even during the banned period. Majority of fishermen are against the imposition of ban, as they do not have alternate livelihood. There is no easy solution to this problem; however, the effects of over-fishing would have severe consequences on sustainability of fisheries. If economic alternatives such as shrimp/crab/fish farming at household level were promoted, the fishermen could use such ponds for sustaining their livelihoods during banned period. It was important to note 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 Fisheries Department 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 facilities are 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 shelters in the villages consist of mostly thatched and a few of brick made houses. No sanitation and water supply facilities exist in the villages. The canal water and hand pumps are the sources 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 major town 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 of such symptoms may be due to pollution as well as are the reflection of the absence of the civic amenities in the area. Due to ethnic and professional homogeneity, community conflicts are less prevalent. The local Bradari (communal) system is used to resolve community conflict.

5.0

Potential Measures

Environmental

Impacts

&

Mitigation

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 pilot aquaculture ponds along Ambra creek (240 20’ 11.1” north latitude and 0670 35’ 39.6” east longitude) is part of the “Protected Forest” notified in 1958 under Pakistan Forest Act 1927. Administratively, the area falls under the jurisdiction of Sindh Forest & Wildlife Department. Subsequently, the same area has been declared as Wildlife Sanctuary in 1958 under Sindh Wildlife Protection Ordinance 1972. Under these laws proposed aquaculture activities are prohibited within the areas or protected forest or Wildlife Sanctuary. The site position also reveals the area to be un-surveyed wasteland. It seems that 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 Ambra Creek near Garho town. As per design, there will be ten ponds constructed in a series on one 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 to Ambra 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 dug between the aquaculture ponds to create a dyke for protection from high tide. The establishment of new ponds will have a very negligible impact on the existing water table in 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 Sindh Fisheries 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 the field visit, some agriculture activity was noticed at about 500 meters from the location of the 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 project location. 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 proposed aquaculture ponds location. As mentioned earlier, the water table in the area is already very 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 was noticed that some of the existing ponds were abandoned mainly due to serious erosion of the embankments towards Ambra Creek whereas; many ponds were noticed eroded away into the creek. If proper protection measures are not adopted, it is very likely that the pond embankments will erode away rendering the established ponds lost to the creek permanently. Further, the coastal areas have been subject to extreme weather phenomenon 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 are located 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 improve livelihoods among poor masses of the area. By establishing aquaculture ponds on the land 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 the Keti Bundar and Shah Bundar areas taking advantage of the natural creek system. No extensive infrastructure development was envisaged to make them less intensive and replicable 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 little investment. It is also aimed to diversify income generating opportunities for the poor fisherfolk communities. The existing design of ponds at the present locations would require investment cost too high for a poor fisherfolk to afford and replicate the existing model. Therefore, the current model appears very resource intensive and may not be a viable 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 initiatives in the past. After talking to some fisheries experts and locals in the area, it was discovered 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 needs and sustainability of the initiative. Several large ponds were constructed, and heavy pumps and generators installed without taking into consideration the issues of sustainability of the established infrastructure. Therefore, the sustainability of such initiatives requiring higher investment is rather questionable looking at the track record of similar initiatives. Even if the project manages to deliver on its outputs during the project duration, there is no guarantee of its sustainability post project closure. Although a profit sharing mechanism between communities is to be established under the project, there is no guarantee 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 established in natural creek system, the beneficiaries would be fewer and belonging to the same village or household making it easier for them to manage and sustain. As per the project document, the proposed aquaculture ponds were to be piloted and expanded in the coastal areas of Keti Bundar, Shah Bundar and Zero Point targeting the poor 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 to poor 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 as fishing, 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 through creation 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 water is an important source of freshwater of the local population. The IEE team was informed that good quality water is available at 18 to 20 feet. It is therefore important that earthen pond embankments are properly reinforced to prevent inland seawater intrusion and flooding of agriculture lands. Further, any indiscriminate dumping of waste oil from vehicles, 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 the habitations, 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 a source 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 bazaar from where the machinery will pass is already a very noisy place. Any additional noise due to movement of machinery may not be a major issue. The cumulative impact of all forms of noise resulting from construction at the project site may be a source of disturbance to people in the area. However, through proper mitigation measures the impact generated due to noise during construction phase may be minimized at the project site. d. Excavated Soil/Material: Disposal of the excavated soil is a potential issue at the project site. The current site is located 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 will require careful consideration by the project proponent. Any improper disposal of the soil may result in issues with the community in the area. No disposal should be allowed on private 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 of utmost importance to take proper precautionary measures to avoid any potential impacts of construction activities on agriculture in the area particularly due to setting up of construction camp and its activities, disposal of waste material and parking or movement of 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 are mainly generation of wastewater and solid waste. However, considering the overall wastewater and solid waste management in Garho, the issue is of a very minimal concern but needs to be given attention particularly when the camp is located within the agriculture field. There could be potential social issues if the contractor decides to bring external labour instead of using local labour. This can potentially lead to conflict if the labour is involved in practices not acceptable in local cultural context. However, it is very likely 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 will be used for excavation purposes which will cross from narrow town streets and village link roads to reach the construction site. Any carelessness on part of the operator or of the community may potentially result in an accident. It is particularly important to pay attention 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 heavy earthmoving machinery, civil works and difficult working conditions. Careless operation of heavy machinery may potentially cause injuries to staff and labour. Similarly other civil works such as construction of dykes / protective walls using big stones to check sea erosion 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 the construction 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 the mercury is at its maximum.

5.4 Environmental Impacts Due to Project Operation Some of the potential environmental impacts during the operation of aquaculture ponds are as follows:

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a. Biodiversity The introduction of any fish species which is alien and potentially invasive is a potential threat to marine biodiversity in the area. Only local species should be introduced in the pilot ponds. Since mangrove plantation is proposed to address erosion issues, it is important 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 used and 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 these chemicals 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 be required 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 on agriculture 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 of Revenue Department and Sindh Forest & Wildlife Department. As per project document (p-119) aquaculture sites are to be sited at locations which are not ecologically sensitive or wildlife areas. b. Construction Soil Erosion & Flooding: The pond embankments shall be properly compacted and reinforced to prevent erosion of soil, permanent loss of constructed ponds and consequent flooding due to intrusion by creek water. Stone pitching would be essential for embankments facing the creek flow directly. Protective planting of mangrove plants along the embankment and creek frontage should help in providing a sustainable measure to prevent erosion of the creek and pond embankments. c. Groundwater Disposal of any chemicals, waste oil or any other contaminants should not be dumped indiscriminately to avoid contamination of groundwater. Vehicle maintenance should be undertaken at a specified location and all waste should be collected and not disposed indiscriminately. All waste oil should be collected and given to vendors in recycling business. 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 on agriculture 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 fields to 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 project operation to restore capacity of the ponds, the disposal of the sludge/ excavated material should be properly undertaken. Dumping of the waste materials on adjacent land, 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 be undertaken 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 during construction or operation, the waste materials should be transported in covered vehicles especially if the route is through town areas and frequently used roads. Transportation should preferably be undertaken during night to avoid inconvenience to people and road users. If the temporary storage is necessary at the site, the waste should be sprinkled with water to suppress dust. f. Noise Pollution Noise is not a major issue during construction since the project site is at some distance from the settled area. However, the movement of machinery through Garho Town or through habitation may create a temporary noise issue. It is recommended that the heavy machinery and dumper trucks should use any bypass roads to avoid town centre or village habitations during day and night time. In case, if bypass option is not available, the town administration and local communities should be consulted to suggest times for maximum movement of heavy traffic. g. Construction camp If the contractor decides to setup a camp, it should be located close to the construction site. The site should be provided by the community after taking due permissions from the owner. After the construction is complete, the camp should be properly dismantled and the site rehabilitated. Any structures constructed should be demolished if the owner does not want them. Solid waste should be collected and dumped at the municipal dumping area. Wastewater from the camp should not be indiscriminately discharged out in the open. As far as possible, the contractor shall prefer engagement of local community members as labourers to avoid chances of social conflict and provide employment to the local people. The contractor should ensure that the labour employed does not create any problems for the community. . h. Community Safety If possible, a bypass should be used for the movement of heavy earthmoving machinery and town streets should be avoided to the maximum possible extent. However, if bypass is not available, extreme care should be taken while moving earth moving machinery through town streets or village habitations. The safe speed limits should be strictly enforced during movement of machinery or such movement should preferably be carried out 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 machinery’s movement. The machinery should have proper lights and reflectors. The project area should be strictly prohibited for the movement of people who are not working for the project, especially children. The ponds should have safety markings especially warning tape around the site to keep unauthorized people away and also to forewarn people of potential 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 project contractor to ensure that the staff wears protective gears. A first aid box should be available at the project site to deal with emergencies. The camp office and construction site 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 introduced in the pond. Only recommended local species of crab and shrimp should be tried in the pond. The excessive use of chemicals and fertilizer should be avoided to prevent aquatic pollution.

6.0 Analysis of Alternatives a. No Project Option It is a good project and it should definitely be implemented. Improving livelihoods through providing better alternatives such as aquaculture is one of the best ways of alleviating poverty of the fisherfolks in the area. However, the project should be implemented in line with the project objectives and ensuring sustainability of the initiative. 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 of poor households and make their replication feasible. The current design requires considerably high investment for excavation and other infrastructure developments which may be beyond the reach of poor and heavily indebted coastal fisherfolks. The project objectives envisage that any initiative undertaken should be easily replicable in other 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 to distribute 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 at diversified locations. c. Site Alternatives Although the site chosen for the project is suitable for aquaculture, it is not consistent with 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 Bundar areas 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 in Keti Bundar and Shah Bundar. Further, the area falls under administrative and legal jurisdiction of the Sindh Forest & Wildlife Department and would require such approval from the government.

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d. Input Alternatives The current design for establishment of aquaculture ponds would require considerably high investment which will be beyond reach of a poor fisherfolk which are the target beneficiaries of the project. Therefore, following the design which requires less input cost by 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 concerns and quality of life. It was also intended to reflect expectations, fears, apprehensions and general 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 informal institutional consultation was made with Sindh Fisheries Department, local NRSP officials, Community Organisations (COs), private entrepreneurs, fish traders, and adjoining community members. Consultation process was completed by adopting an interactive and participatory method; to ensure equal opportunity of expression to each and every participant and record their perceptions about the proposed intervention. Majority of the consultations took place in and around the project site and the details of the discussion of 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 an understandable and culturally appropriate way. Views of female participants could not be recorded due to socio-cultural reasons. However, supportive views of female community members for the proposed interventions were relied from discussion with female social workers of NRSP. Generally the attitude of local communities was very positive towards the proposed interventions in the area. The community members expected that this project would improve the general economic conditions and livelihoods of the local people by creating employment opportunities during the different phases of the project construction and operation. However, some of the adjacent households feared privacy issues if staff/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 Project is aimed at diversifying income generation opportunities for coastal fisher folk communities. 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 piloting through 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 mitigation measures to prevent environmental damage. An initial environmental assessment of site selected at Ambra Creek by Sindh Fisheries Department for establishment of 10 pilot shrimp 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 proposed activity involving approximately one (1) ha of infertile land. However, the assessment has revealed major concerns related to the site and design of proposed intervention. In terms of environmental concerns, the proposed site falls within the boundaries of ‘protected forests’ and ‘wildlife sanctuary’. In terms of design, it is inappropriate to meet the project objectives and transfer project benefits to the target beneficiaries. Being cost and infrastructure intensive, the proposed design appears to be beyond the reach of poor fishing households making its replication by target beneficiaries questionable. The site and design in question needs to be reconsidered to make it consistent with the project objectives. Low technology, low input and single household managed 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 1 Blepharis sindica Stocks ex T. And.

Family Acanthaceae

2

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 asper Fig.

Asteraceae

7

Avicennia marina (Forssk.) Vierh

Avicenniaceae

8

Heliotopium ophioglossum Boiss

Boraginaceae

9

Capparis decidua (Forsk.) Edgew

Capparidaceae

1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 2 1 2 2 2 3 2 4 2 5 2 6 2 7 2 8 2 9 3

Arthrocnemum macrostachyum (Moric.) C.Koch

Chenopodiaceae

Arthrocnemum indicum (Willd.) Moq

Chenopodiaceae

Atriplex stocksii Boiss

Chenopodiaceae

Chenopodium album L

Chenopodiaceae

Salsola imbricata Forsk

Chenopodiaceae

Suaeda fruticosa Forsk. ex J.F.Gmelin

Chenopodiaceae

Suaeda monoica Forsk. ex J.F.Gmelin

Chenopodiaceae

Convolvulus arvensis L

Convolvulaceae

Cressa cretica L.

Convolvulaceae

Cyperus bulbosus Vahl

Cyperaceae

Euphorbia serpens Kunth

Euphorbiaceae

Alhagi maurorum Medic

Fabaceae

Acacia nilotica Delile

Mimosaceae

Prosopis juliflora Swartz

Mimosaceae

Commicarpus boissieri (Heimerl) Cufod

Nyctaginaceae

Aeluropus lagopoides (L.) Trin. ex Thw

Poaceae

Chloris barbata Sw

Poaceae

Cynodon dactylon (L.) Pers.

Poaceae

Desmostachya bipinnata (L.) Stapf

Poaceae

Paspalum vaginatum Swartz..

Poaceae

Pennisetum purpureum Schum.

Poaceae

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0 3 1 3 2 3 3 3 4 3 5 3 6 3 7

Phragmites karka (Retz.) Trin. ex Steud.

Poaceae

Sporobolus virginicus (L.) Kunth

Poaceae

Salvadora persica L

Salvadoraceae

Tamarix indica Willd.

Tamaricaceae

Typha angustata Bory & Chaub

Typhaceae

Fagonia indica Burm.f.

Zygophyllaceae

Zygophyllum simplex L.

Zygophyllaceae

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