IEE A111e11d111ent-J Kurram Tangi Dam a11d Associated Prima,y Irrigation Distribution System

USAID PAKISTAN FROM THE AMERICAN PEOPLE ~ ~

Initial Environmental Examination (IEE), Amendment No. 1 /tJ) / 2,.'j I~ ter Kurram Tangi Dam and Associated Primary Irrigation Distribution System

P . I roJect Activity D ata: D C/1/ .. tt'NA- -U- t9Cf-f>kk -~ o/6 Activity /Project Title: Kurram Tangi Dam and Associated Primary Irrigation Solicitation #:N.A. Distribution System

Contract /Award Number (if known): NIA

Geographic Location: Pakistan , 391

Originating Bureau/Office: USAID/Pak.istan, Office of Energy

Supplemental IEE: □Yes [gj No DCN and date of Original document: OAPA-12-FEB-PAK-001 7, approved February 17, 2012

Amendm ent: [giYes □ No DCN and ECD link(s) of Amendment(s) :

Programmatic IEE : □Yes [gj No Amendm ent # 1

Funding Amount: $207,000,000 Life of Project Amount: $207,000,000

Implementat ion Strui/End: 2012 to December 31, 2021

Prepared By: Imran Ahmed Date Prepared: October 9, 2019

Expiration Date (if any): December 31, 2021 Reportin g due dates (if any): ~/Aj Environm ental Media and/or Human Health Pot entially Impacted (check all that apply) : None □ Air [gj Water [gj Land [gj Biodiver sity igi Human Health [gj Other □

Recommended Threshold Determination: 8l Negative Determination -R with condition s D Deferral [gj Categorical Exclusion □ Exemption [gj Positiv e Determination □ USG Domestic NEPA action

Climate Change: □GCC/Adaption □GCtC/Mitigation ~ Climate Change Vulnerability Analysis (included)

Adaptatio n/ M itigation M easures: Included

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IEE A111e11dment-l Ku/'/'am Tangi Dam and Associated Primmy ll'l'igation Distribution System

Initial Environmental Examination (IEE), Amendment No. 1 Kurram Tangi Dam and Primary Irrigation Distribution System

I. Purpose and Scope of IEE Amendment 1

The purpose of Amendment Number 1 of the IEE OAPA-12-FEB-PAK-0017 is to:

a. Extend the Life of Project (LOP) date to December 31, 2021; b. Reduce the LOP funding from $230,000,000 to $207,000,000; c. Replace the language in IEE Section 5.0 (New Information) with updated language; and d. Add a Section 6.0, to comply with updated USAID requirements to address climate change.

In accordance with 22 CFR 216, this IEE amendment provides a review of the environmental compliance status and lessons learned from project implementation.

The IEE was prepared in accordance with 22 CFR 216 by USAID in 2012 to provide a first review of the reasonably foreseeable effects on the environment of the project and to recommend threshold decisions for additional environmental analysis (Attachment 1 ). The scope and nature of all activities included in the original IEE remain the same. All previously approved threshold dete1minations, conditions, limitations, and stipulations for revision remain in force.

II. Background

The Kurram Tangi Dam Project (KTDP) is a multipurpose water resources development project under constrnction in the Nmth Waziristan agency of the Khyber Pakhtunkhwa (KP) province. KTDP comprises power and irrigation activities on the Kurram and Kaitu river systems and will benefit around two milli9n people in five districts in northwest Pakistan. The project will bring much needed economic development and create job opportunities in the region and contribute towards poverty reduction and the development of sustainable commercial and industrial

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activities. Power produced from the series of powerhouses will supply power to the national giid, as well as support operation ofKTDP in-igation and other systems.

Kaitu Weir is the first stage ("Stage 1") of the KTDP project and involves th~ construction of a weir on the Kaitu River, a feeder tunnel, Sheratalla and Spaira Ragha inigation canals and corresponding command areas, two powerhouses, a 132 kilovolt transmission line from powerhouse IV to the Domail substation near Bannu , and a 15 kilometer access road. Additional

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activities were originally envisaged under a Stage 2, which would have supported the completion of the dam and power houses for the Khmrnm River portion of the larger KTDP project. The original IEE covered all construction under Stage 1 and portions of construction under Stage 2. However following the civilian assistance review, the Mission decided against providing funds for Stage 2. Therefore, through this amendment to the IEE, the LOP amount is being reduced from $230 million to $207 million, to only cover the costs of activities associated with Stage 1 (which are being funded by USAID, the GOP, and other sources).

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IEE A111end111ent-l K11rra111 Tangi Dam and Associated Pri111a1J' lrrigatio11 Distribution System

USAID is providing $81 million for the construction of Stagel through a government-to-government grant. USAID signed the activity agreement with the Water and Power Development Authority (WAPDA) on December 14, 2016 and later signed a fixed amount reimbursement project implementation letter (PIL) on October 3, 2017. The project is being implemented by WAPDA through a sub-conh·act with a joint venture between the Frontier Works Organization (FWO) and a private company, Descon Construction. The prdject started in late 2016 and to date the project is approximately 30 percent complete. The activity agreement and PIL will expire on.December 31, 2019, as the project was originally envisaged to be completed in three years. Due to unanticipated security restrictions, however, the construction of the project is now expected to be completed by June 2021, and finalizing reimbursements to WAPDA and closeout will be completed by December 31, 2021.

The project is located in the tribal belt of North Waziristan, which is generally mountainous, rugged, arid, and histo1ically susceptible to violence due to the interplay of conflicting tribal and extremist activities. Although law enforcement agencies actively combat terrorist activities, issues persist, necessitating extra security precautions, which have slowed project development. A security check of the project area is can-ied-out each morning before the constrnction activities can be initiated, thus reducing work hours. Night shifts are not possible due to security restrictions, and project staff and constrnction materials must move in convoys under security escort. In addition, some recent political campaigns in the Newly Merged Dish·icts (NMD) opposed the project activities, which made it difficult for WAPDA and the local government to acquire land and rights of way for various civil structures, including powerhouse-IV, the access road, and irrigation canals. The politicization of the project also led protesters to block access roads, which made it difficult for laborers and project staff to move to the project site. With the elections complete, we expect the last of these issues to be resolved by the end of the year.

The construction includes seven main components (Table 1 ). The first four components (including the weir and associated shuctures) are more than 70 percent complete and are on target for completion on or before April 2020. Feeder tunnel, access road, and p'owerhouse constrnction is the most · delayed.

• Feeder Tunnel. After completing the geotech and geological survey, FWO determined that a design change was required for the feeder tunnel support strnctures because the rock conditions differed from expectations, delaying the start of constrnction. With the design now 'finalized, FWO has started the work on the tunnel and expects to complete it by April 2021. .

• Access Road. The work on the access road was delayed due to a right of way issue mentioned above. WAPDA has involved the local government to resolve the issue and expects to reach an agreement before the end of this year and then begin constrnction, which is expected to take 10-12 months, for an expected completion date of April 2021.

• Powerhouse. FWO could not start the conshuction of the powerhouse due to a land acquisition issue that became politici zed. WAPDA has recently resolved the issue, and FWO has started excavation work at the site. The turbines and generators for the powerhouse have been built and tested, and the foundation should be ready by December

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IEE A111e11d111e11t-l Kurram Tangi Dam and Associated Primal)' Irrigation Distribution System

2019 for workers to begin installing the turbines and generators. Work on the powerhouse is on track to be completed by June 2021.

Table 1 Summary of Kaitu Weir Activities, Status, and Estimated Completion Dates

No. Item I Percent Complete Estimated Completion Date

1 Weir and CofferDam 95% December 2019

2 Silt Excluder 90% December 2019

3 Spaira Ragha Canal 70% March 2020

4 Headrace and Afterbay Spill 77% Apiil 2020

5 Feeder Channel/Tunnel 5% April 2021

6 Access Road 0% April 2021

7 Power House 15% June 2021

Ill. Review of the Environmental Compliance Status and Lessons Learned

USAID completed an environmental assessment (EA) for the KTDP as a result of the IEE's positive dete1mination. The EA contractor, MWH Americas, analyzed the physical , biological , and human resources impacted by the project and defined compliance requirement s to mitigate these effects. As discussed below, while the status of environmental monitoring and compliance is generally good, there are lessons learned that will require changes in operations and resources devoted to environmental compliance.

A. Environmental Compliance Status USAID has provided on-going suppoti for effective environmental compliance monitoring . This work has included the following:

• USAID's Architecture and Engineering (A&E) Team conducted several training sessions for management at WAPDA and its sub-contractor, as well as a training session for workers on-site regarding environment, health , and safety.

• The project acquired noise and dust meters, and in tum the A&E Team trained the Environmental Focal Person (EFP) to use this equipment. The A&E Team then followed up with the EFP during site visits and ensured that the EFP properly monitored noise and dust levels, as well as air quality parameters, such as total volatile organic c6mpounds, fotmaldehyde, humidity, and temperature.

• The A&E Team has been providing regular guidance to project staff oru the implementation of the resettlement action plan. The A&E Team gave a h·aining in May i2019 for the EFP on resettlement action plan indicator reporting. The A&E Team monitors the resettlement action plan to ensure its effective implementation and assists the project to develop quarterly reporting on progress of resettlement action plan indicators. According to the monitoring reports, resettlement action plan-recommended processes are usually followed and land acquisitions issues are dealt with accordingly. As per the latest resettlement action plan monitoring report , most of the land acquisition issues are resolved specifically at the powerhouse IV site and feeder tunnel, and the work on each site is progressing. There are a

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IEE Ame11d111e11t-l Kurram Ta11gi Dam and Associated Primm y Jniga tion Distrih11tio11 System

few right of way issues pending for the access road where the local administration is working together with WAPDA and FWO to settle with the local tribes.

• The A&E Team is monitoring implementation of the gender action plan. The female members of the A&E Team and project staff engage with the local tribes to discuss gender considerations and develop women-managed activities, such as kitchen gardening (home gardening), chltivation of frnit trees, and provision of sewing machin Js. The A&E Team gave a training ses'sion to project staff on gender issues.

• USAID prepared Environmental Mitigation and Management Plans (EMMPs) as a part of an environmental data form for the 26 critical actions (Attachment 7). As of September 2019, a total of 18 c1itical actions are complete and closed, while eight actions are in the implementation stage. The pending actions relate to activities for which the KP government is now responsible after the merger of the FATA with KP province .

B. Lessons Learned There are some lessons learned from the activity thus far that necessitate (1) some changes in the activities of the A&E Team, and (2) an increase in the work and resomces devoted to environmental compliance by WAPDA and FWO.

1) WAPDA did not have an Environmental Monitoring Cell as required by the EA. While WAPDA did have an EFP, their work has not met USAID standards. This resulted in a number of issues: o . The environmental compliance monitoring was of uneven quality. In the quarterly

progress reports, WAPDA provided only a very brief section on the environmental compliance status.

o FWO prepared a waste management plan for the project (Attachment 8) that did not follow the EA's requir ements.

o WAPDA's supervision consultants, Mott McDonald Pakistan , prepared a limited scope environmental compliance report in April 2019 (Attachment 9) that did not adequately describe environmental conditions in the constrnction camps and the prnject site. For example, waste management at construction camps and water, air, and noise quality at the project site were not properly monitored and reported.

2) USAID's A&E Team needs to follow an improved oversight and reporting procedure working together with WAPDA's Enviro nmental Monitoring Cell to ensure issues comp lying with the EA, like those above, are identified in a timely manner.

C. PIL Amendment As part of the amend ment to the PIL , WAPDA needs to dedicate additiona l staff and resources to improve environmental complianc e monitoring. In particular , the following will be added to the PIL amendment:

• WAPDA must fmmali ze an environmental moni toring unit at the Kaitu Weir site to ensure environmental and socia l compliance from supervision and construction standpo ints. This unit must have sufficient staff and other resource s consisten t with EA -requirements.

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IEE A111e11dme11t-l Kurram Tangi Dam and Associated Prima,y Irrigation Distribution System

• WAPDA and FWO must provide quarterly environmental compliance reports consistent with EA requirements.

In addition, USAID will update the Stage 1 EMMPs to reflect that the FATA has been merged into KP province as the Newly Merged Districts. This has resulted in a change of the entities responsible for implementation of the EMMPs. The updated EMMPs will subsequently become part of the PIL amendment.

IV. Amendments to OAPA-12-FEB-PAK-0017

A. LOP Date: LOP date is extended from December 31, 2017 to December 31, 2021

B. LOP Funding: LOP funding is reduced from $230 million to $207 million to match PC-1 costs for Stage-1

C. Section 5.0 Section 5.0 New Inf01mation is deleted and replaced with:

"5.0 Revisions In accordance with 22 CFR 216.3( a)(9), if a project is revised or new info1mation becomes available, including during preparation of an Environment Data Form , which indicates that a proposed action might be "major" and its effects "significant," the Activity Manager will review and revise the dete1mination and submit the revised determination through the MEO to the BEO/OAPA for approval. If warranted, an environmental assessment will be launched and a scoping statement and environmental assessment report will be prepared. The scoping and EA process will follow and comply with 22 CFR 216 .3(a)(4)."

D. Add Section 6.0 Climate Change Integration Following Section 5.0 a new section is added as follows:

"Section 6.0 Climate Change Integration:

Changes in the climate can potentially have a significant impact on infrastrncture viability and operation, as well as on the smrnunding communities.

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As an integral part of the environmental assessment, USAI D' s EA contractor, MWH, conducted an analysis to estimate the potential impacts of climate change on tempera tme, precipitation , and stonn frequency and intensity over the lifetime of the KTDP.

MWH reviewed the existing body of research and historical precipitation and temp erahll'e data for the Kun-am Tangi region, and used global circulation models for the long term forecast of precipitation and temperature under climate change. This analysis provides the carbon impacts of the project, and a discussion on socio-economic impacts due to climate change. The referred analysis is available in the Supplem ental Report on Climate Change, which is included in the suite of docum~nts of EA for KTDP."

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IEE A111e11d111e111-J K11rra111 Ta11gi Dam and Associated Primal)' lrrigalio11 Distributio11 System

Attachments: 1. IEE with tracking No. OAPA-12-FEB-PAK-0017 2. Environmental Monitoring Report - Pre Construction Phase 3. Environmental Monitoring Report - Construction Phase 4. Resettlement Action Plan Monitoring Report 5. Gender Action Plan Monitoring Report 6. 26 Critica l Action Monitoring Repo1t 7. Waste Management Plan prepared by FWO 8. Environmental Compliance Monitoring Report prepared by Mott McDonald Pakistan

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IEE Amendment-I Kurram Tangi Dam and Associated Primm y Irrigation Distribution System

Initial Environmental Examination (IEE), Amendment No. 1 Kurram Tangi Dam and Primary Irrigation Distribution System

CLEARANCE/ APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE:

ENR Office Director: _ /44-+-_ _ ___..2:"-------- D~te: _,_/~{) /2~ 12)_..7~[)_._/ Cf+---~ i

Alexander Lane

Midsscio1~ Env1

1·ronme~tal OLffidcer: J4; A: ~ .~ t

an 1mate ntegrat1on ea ~ z1z Date: _ I o-1-/i_t o-1-/_2,_o_t ...;_q_

r 1

Regional Environmental Advisor: --- ---=C=le=ar=e=d=-o=n=--=em=ai=-1 _ _ Date: September 27, 2019 Central, South Asia, and OAP A Andrei Barannik

OPM Office Director: ---~--.:c ~ -=-~-=====:::'.::=:::··~•.:i_S)_ ___ Date: (A) , \.\\ Gyta,d j

Deputy Mission Director: _ __ --......_::c,._J.L..~--\1='-\,-~-"-"----'-~-- - -- Date: _ ...:....{ u-1-) ...:....l ,---1-_1 _'1 __ ~ Ac.~r -~e,~f GoeW' Cla~n I I

APPROVAL: ( - I \ Mission Director: _ __ ...... _ _ ---'-',-, - ------1\jr+--- -- --- Date: I u I \ e,! I ~

/ J ulie Koenen

CONCURRENCE:

Bureau Environmental Officer - OAPA ~~ Da~e: (f.2&/ .rz6JF{ , ~ her Payne ·

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Distribution: 1). Project files, 2). Mission IEE Data base, 3). OAA, 4). RLO

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USAID As im Aziz <aaziz@usaid.gov> FROM THE AMERICAN PEOPLE

Urgent: IEE Amendment 1 of KTDP - Kaitu Weir

Andrei Barannik <abarannik@usaid.gov> Fri, Sep 27, 2019 at 7:42 AM To: Asim Aziz <aaziz@usaid.gov> Cc: Alexander Lane <alane@usaid.gov>,

"Ward, Sherry (USAID/Pak/PRM)" <SWard@usaid.gov>,

Dear Asim -

Reviewed - looks OK - I clear - pis send clean Mission approved copy in Word and pdf t o Chris Payne, BEO/OAPA for his review and concurrence .

W /r & ALL stay safe , Andrei

P.S. Any earthquake impacts reported in KRTD?! [Quoted text hidden]

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