While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Groups of transhumant herders known as Gujjar pass through the project area on their annual migrations to and from high mountain pastures in the northern areas of Pakistan. Gujjars manifest all the characteristics of an Indigenous People as outlined in IFC PS 7. However, project construction activities will not obstruct their seasonal movements through the project area. As such, the project will not result in adverse impacts related to PS 7: Indigenous Peoples.

The Karot project involves the development of a large scale 720 MW power generating facility, including a 95.5 m high dam and a 27 km long reservoir on the Jhelum River upstream of the existing Mangla reservoir. Multiple large hydropower projects, including the Karot project, are being proposed as a cascade on the Jhelum River between Muzaffarabad and the Mangla reservoir, with potential cumulative impacts that need to be further assessed. Karot project is located in natural and modified habitats where terrestrial and aquatic biodiversity values exist. The project footprint will encompass 16 villages, and will have direct impacts on 186 households and approximately 78 small businesses that will either be physically or economically displaced. During its peak construction period, the project will employ and accommodate a workforce of nearly 3,500 with the attendant stress that such a population influx will have on the cost of goods and services, public security and social cohesion. Given all these factors and in accordance with the IFC Policy on Environmental and Social Sustainability, the Karot project has been categorized as a Category A project because it may cause significant adverse E&S impacts that may be diverse and irreversible.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment: Prior to CSAIL and KPCL involvement, the original project design called for a 91m concrete gravity dam and an underground powerhouse, and a spillway integrated into the dam. Based on this design, an EIA was prepared in 2009 and approved in 2010 and 2011 by the concerned government authorities.



An additional extensive geological survey commissioned by CSAIL in 2013 and completed in 2014 determined that a 95.5m asphalt-concrete core rockfill dam, above-ground powerhouse, and separate spillway structure offered cost savings and presented fewer technical difficulties for construction than the original project design. To accommodate a slightly larger reservoir, the new dam is about 750m downstream of the 2009 proposed project. Based on these changes in design, a new ESIA (the national ESIA) was completed and submitted to authorities in January 2015.



In early 2015, KPCL appointed an international consultant to prepare an ESIA to meet international standards (the “international ESIA”, as disclosed with this ESRS), including environmental assessment requirements of this PS. This international ESIA is aligned with good international industry practices and commensurate with what would be expected for a project of this nature. Preparation of the international ESIA included collection of additional social and environmental baseline (noise, terrestrial and aquatic biodiversity, traffic, physical and economic displacement) and preparation of a Dam Break Analysis, Critical Habitat Assessment, Cumulative Impact Assessment, Climate Risk Assessment, and an update of the Resettlement Action Plan and Stakeholder Engagement Plan.



A Strategic Environmental Assessment (SEA sponsored by the Government of Pakistan and the International Union for the Conservation of Nature (IUCN) in 2014) divided the Jhelum River and its main tributaries into biodiversity zones based on their sensitivity to hydropower development. The SEA was a major source of biodiversity information for the international ESIA.



Potential direct adverse and positive impacts associated with the project identified in the international ESIA include:

Cumulative Impacts: The SEA determined the section of the river where the project is located was in a “Least Sensitive Zone” with respect to biodiversity. However, Karot is the first of four proposed large hydropower projects on the Jhelum River that are planned to be constructed, with CSAIL responsible for three of these, including Karot. These developments, including Karot, will have a total capacity of 3,050MW. The experience in meeting international E&S standards at Karot is expected to benefit all CSAIL projects on the Jhelum River; CSAIL’s other two projects are about one and two years behind Karot in the development process, respectively. The three projects will operate as a cascade, with the tail of each reservoir almost reaching the next dam upstream. These projects will significantly modify th
e large majority of the natural habitat found in the Jhelum River (200 km) and impact migration of the fish Tor putitoria or Golden Mahaseer (known by many common names but herein referred to as Mahaseer) and other fish from the Mangla reservoir to the upper sections of the Jhelum River. The reservoir habitat will favor lake fish over the native river fish.

Land acquisition and involuntary resettlement: acquisition of approximately 1,030 hectares of land, mostly public land and 70 percent required for the reservoir. A total of 186 households (about 1,401 people) in 16 villages will be directly affected, including 74 households in two villages (Karot and Hollar) that will be both physically and economically displaced, while an additional 78 family business and commercial structures will be physically displaced.

Impacts on biodiversity: 1) Conversion of 27 kilometers of free-flowing river to still-water lake through impoundment by the dam structure; 2) conversion of 7 to 48 kilometers of the downstream hydrologic regime for four to six months yearly from natural seasonal variation to abrupt daily changes during peaking; 3) creation of a barrier that will stop upstream and downstream migration and movement of fish and other aquatic organisms.

Community safety: creation of potential safety risks to affected communities, primarily through significantly increased truck traffic on public roads.

Construction disturbance: up to five years of disturbance typical of any major construction and civil works (e.g., air and noise emissions, wastewater, solid and hazardous waste generation and disposal, workers’ occupational health and safety risks, increases in traffic, among others).

Job creation: employment of up to 3,500 people, including about 3,000 from local communities and elsewhere in Pakistan, which will provide local and wider access to wage-based income.

Provision of renewable energy: Consistent with the World Bank country energy strategy the Karot project will help address the power shortage situation in Pakistan, and assist the country to reduce its significant reliance on expensive and imported fossil fuels.



Management Program: The international ESIA included an Environmental and Social Management Plan (ESMP—Volume IV of the ESIA) that updates and expands a similar Environmental and Social Management Plan (ESMP) in the national ESIA. These Plans summarize the organizational requirements and the management and monitoring sub-plans that will be prepared to ensure the necessary measures are taken to avoid or mitigate potential adverse effects and maximize potential benefits. Implementation of the individual E&S management sub-plans will allow the project to be constructed and operated in compliance with applicable local laws and regulations and IFC Performance Standards.



The ESMP includes a Resettlement Action Plan and Stakeholder Engagement Plan. The ESMP also includes indicative frameworks for use by the EPC Contractor in developi
ng detailed E&S management plans (ESMP or sub-plans) for construction and by KPCL in developing ESMP for operations. These frameworks are based upon the ESMP frameworks that are part of the CSAIL Environmental and Social Management System (ESMS), which was required by the ESAP for the IFC equity investment (Project #34062).



The primary management sub-plans that are required, and that are outlined by frameworks in the ESMP, will be the overarching Construction and Operation ESMPs. These overarching plans will require, as appropriate for the project phase, detailed plans for Traffic Management, Site Waste Management, Noise and Vibration Management, Air Quality Management, Water Quality, Spill Prevention and Response, Blasting and Explosives Management, Spoil Management, Excavation and Slope Stability Management, Sediment and Erosion Control, Site Reinstatement and Landscaping, Biodiversity Management and Action, Ecological Management, Habitat Removal and Restoration, Occupational Health and Safety, Site Security Management, Emergency Preparedness and Response, Influx Management and Worker Accommodations Management. In addition, the ESMP includes frameworks to guide development of plans and strategies for Recruitment, Retrenchment, Local Content, Community Investment, Skills Training, Gender, and Human Resources.



The EPC contract includes detailed E&S requirements consistent with CSAIL ESMS and IFC Performance Standards. The contractor is responsible for developing the Construction ESMP including detailed sub-plans, which have to be in place before major construction begins. The ESMP prepared by the EPC contractor will be reviewed and approved by KPCL (ESAP #1).



Each of the EPC contractor ESMP sub-plans (waste management, noise, etc.) will include not only technical requirements, but also requirements and procedures for monitoring performance, including EPC monitoring of subcontractor performance, and for assigning responsibilities within an established organizational structure.



KPCL is required to monitor and oversee the development and implementation of these construction contractor sub-plans as a part of the Contractor Management Plan required by the ESMP (ESAP #2). This plan will be reviewed and approved by KPCL and CSAIL management prior to adoption, and to the satisfaction of IFC. As part of the plan, KPCL is also required to establish a centralized performance tracking system to track the progress and implementation performance of all E&S plans and contractor E&S sub-plans (ESAP #2).



Organizational Structure, Monitoring Programs, and Reporting: KPCL was established in 2010 and as of mid-2015 has 50 staff to oversee all aspects of project development. KPCL has established a Social and Environmental Department with a dedicated environmental manager and a dedicated social manager supported by Pakistani senior experts and by local and international consultants. In addition, experienced resettlement experts from the China
Three Gorges Corporation employed by the project are supported by local consultants with suitable expertise. This team is responsible for obtaining environmental permits, managing land acquisition and resettlement, as well as the development of the ESIA and management plans, and will be responsible for the implementation of E&S plans and overseeing the E&S performance of the EPC contractor. Environmental. Social and Occupational Health and Safety (OHS) managers will be recruited to oversee safety performance of the EPC contractor, including subcontractors, prior to the commencement of construction works (ESAP #3). The EPC contractor will be contractually obliged to provide both E&S and OHS personnel (including social/community liaison staff) to ensure that the ESMP and associated sub-plans are fully implemented. The number of environmental, social and OHS personnel will be commensurate with what would be expected for the implementation of the Karot E&S management plans. KPCL will also retain E&S advisors having experience with international projects of comparable complexity to support project management and the EPC contractor develop and implement the E&S plans (ESAP #4).



External experts will be engaged for regular E&S performance monitoring, including monitoring of aquatic biodiversity and habitat, land acquisition and resettlement, labor, community safety as well as the capacity of Karot in managing E&S related issues. The purpose of monitoring is to assess the performance of mitigation measures and to identify the need for additional or modified mitigation measures that may be necessary to ensure the requirement of the ESMP and ESAP are met during construction and operations. To the extent possible, CSAIL will support the engagement of personnel from the concerned government line departments to participate in these monitoring efforts to build capacity in those departments to manage the impacts of the planned development of the entire Jhelum River basin.

Human Resources: The sponsor company of KPCL, CSAIL, is in the process of developing its HR policy and procedures to meet the requirements of GoP and this PS, as required by the ESAP of IFC equity investment in CSAIL (Project #34062). This policy will include, among others, a commitment to providing workers with documented information regarding their rights, freedom of association, non-discrimination, fair treatment of migrant workers, proper management of worker accommodation, non-discrimination and equal opportunity, avoidance of child or forced labor, management of workers employed by third parties/contractors, and proper management of worker health and safety. KPCL will adopt and implement the CSAIL HR policy and procedures.



At present, CSAIL is applying the CTGI HR policy to KPCL’s 50 Chinese and Pakistani employees. Workers unions in Pakistan are recognized by national labor law. Pakistan workers have viable options if they decide to form or join a workers union. CSAIL/KPCL does not and will not restrict employee freedom of association. Grievance channels are built into CSAIL/KPCL existing management practices; issues can be escalated to higher levels within the organization as and when needed. The CSAIL corporate HR Policy and procedures, will be adopted by KPCL, and will incorporate a worker/contractor grievance mechanism to allow free flow of grievances from contracted workers and staff to the relevant line managers for a mutually acceptable resolution. KPCL contractors will be held responsible for the fair and appropriate handling of contractor worker grievances and this will be subject to monitoring by KPCL. Where there is a conflict between local custom and national labor regulations that prevents satisfactory resolution of worker grievances, KPCL will convene a body made up of local leaders, government authorities and contractor representatives to address this conflict. (ESAP #5).



The Karot ESMP requires KPCL to develop a Contractor Labor Management Plan to ensure that contractor labor practices are in line with GoP law and IFC requirements. There will be up to 3,500 workers at the peak of construction, consisting of about 3,000 Pakistani and 500 Chinese. The EPC contractor is a Chinese company, and has an HR policy and procedures applicable to its employees. Pursuant to the Contractor Labor Management Plan mentioned above, KPCL will review the EPC contractor HR policies and procedures to verify that they meet CSAIL requirements. CSAIL/KPCL will work closely with the EPC contractor to promote local access to project employment in both the construction and operational phases of the Karot project. Top priority in hiring will be given to those members of local communities affected by project development. Early indications suggest that the necessary technical skills required for the project construction program may be scarce in the communities closest to the project site. However, it is expected that the majority (85%) of its co
nstruction workforce will be made up of Pakistan nationals with a target of 30% of these individuals to be sourced from the local area. During operations the workforce will be made up of greater than 70% Pakistan nationals.



The minimum age for construction work under international standards and Pakistan and China labor laws is 18 years. Individual ID cards are used for age screening both for CSAIL/KPCL employees and non-employee workers. CSAIL/KPCL do not make use of child or forced labor. Contractors are required to strictly follow the national labor law and hire only employees older than 18 year of age for construction works.



Construction of work camps to accommodate up to 3,500 workers are in the early planning stage. The main work camp will be located immediately adjacent to the main construction site at Karot while satellite work camps will be located immediately adjacent to other major project components. The Contractor Management Plan to be developed under the Karot ESMP requires worker accommodations to meet the guidelines provided in “Workers'' Accommodation: Processes and Standards” developed jointly by IFC/EBRD. KPCL will inspect those camps regularly during the entire period of operations (including interaction with local communities). Monitoring results will be reported to KPCL and EPC contractor management, and any shortcomings will be required to be remedied within established timeframes.



Occupational Health and Safety (OHS): The ESMP requires and outlines the requirements of a comprehensive OHS plan that will apply to all site workers. The OHS Plan will identify task-specific risks, define safety protocols to follow for each task, and describe limitations and equipment needs, including personal protective equipment. It will also describe training requirements needed for each task, with special attention for workers exposed to particularly hazardous environments, including those working at heights, in excavations or confined spaces, with chemicals or electricity, and with heavy equipment and machinery. It will also include requirements specific to underground workspaces and workers. Throughout construction, the EPC contractor will maintain training records and track performance, including work hours, safety incidents that lead to time away from the job (“lost-time” incidents), and serious accidents and fatalities. For serious injuries and fatalities, the Plan will require a root cause evaluation. The EPC contractor will report to KPCL on OHS performance, including the metrics listed here, on a regular basis, with immediate reports in case of serious accidents and fatalities. KPCL will monitor and oversee contractor OHS performance, in part by periodic inspections. During operation, KPCL will develop and implement an equivalent operations phase OHS plan.

Pollution Prevention and Control: Construction activities will include excavation, blasting, drilling, quarrying, aggregate crushing, concrete batching, spoil use and disposal, disposal, concrete laying, brickwork, cabling, erection of structures and equipment. Activities will also include accommodating and feeding up to 3,500 workers as well as transporting, storing, and using fuel, chemicals, paint, and other materials and operating a landfill for project wastes. Operations activities will be at much smaller scale with less risk and potential impact. The subsections that follow describe principal measures included in the ESMP and various management sub-plans to address impacts from these activities.



Air pollution: The ESIA indicates that there are no major sources of air pollution in the vicinity of the project. Measured concentrations of carbon monoxide, nitrogen dioxide, sulfur dioxide and PM10 (particulate matter with a diameter up to 10 microns) in ambient air were found to meet Pakistan National Environmental Quality Standards (NEQS), with PM10 the only pollutant that approached the standard.



The primary sources of air emissions during construction will be the concrete batching plant, operation of vehicles and machinery, and fugitive dust from vehicle use and spoil management. There will be no major sources of air emissions during operation, with even greenhouse gas emissions from the relatively small amount of vegetation to be inundated considered to be minor.



Project construction will emit about 228,000 tons of CO2-equivalent (tCO2-eq) greenhouse gases over the five years of construction (excluding concrete-related emissions). Based on Pakistan’s average mix of energy generation sources and fuels, the project will avoid about 1,600,000 tCO2-eq per year throughout its operating life. An Air Quality Management Plan will include measures to mitigate atmospheric pollution, the most important being the regular sprinkling of unpaved roads and work areas, covering or vegetating long-exposed earthen surfaces, covering dusty truck loads, and systematically maintaining vehicles and construction equipment.



Noise and Vibration: The project area is largely rural and relatively quiet, with the primary sources of noise being road traffic and the river itself. Many on-site construction activities will generate noise, particularly drilling and blasting, excavation, rock-crushing at the concrete plant, truck loading and unloading, operation of generators and other engines, and truck traffic. The primary sources of on-site noise that could reach nearby communities would be blasting and truck traffic on site roads to spoil disposal sites near the communities of Hollar proper and Tulla, which is an isolated part of Hollar. The only important off-site source of noise would be trucks bringing materials, especially aggregate, through local communities, primarily the village of Beor. The EPC contractor will develop and implement a Noise and V
ibration Control Plan to ensure noise levels are kept within the standards of the IFC General EHS Guidelines. This plan will require scheduling blasting and haul traffic (see traffic section below) to avoid sensitive times, providing advice to local communities on project scheduling, providing and enforcing driver training (again, see traffic), selecting and maintaining vehicles and equipment to minimize noise, and other measures to ensure standards are met. The plan also require regular monitoring at off-site locations as well as on-demand monitoring in response to complaints, with additional mitigation as needed to meet standards and avoid nuisance.



Nuisance and damage from vibration caused by blasting will also be addressed in the Noise and Vibration Control Plan. Buildings and other community assets (e.g., the nearby shrine) considered to be at risk will be surveyed by a qualified engineer prior to construction to document their condition and identify any specific vulnerabilities. In addition, all blasts will be monitored at sensitive locations. In response to complaints, instances where vibration criteria limits are exceeded, or where damage could occur, buildings will be re-surveyed and addressed as appropriate (strengthening, compensation, etc.)



Water: There are no industrial sources of pollutants to the upstream Jhelum River, and significant municipal sources are far enough upstream as not to be of concern at the site. Consequently, water quality in the river meets Pakistan National Environmental Quality Standards (NEQS), except that naturally occurring suspended solids cause the water to be highly turbid. The primary sources of potential impact to water quality will be sanitary sewage from up to 3,500 workers on the various construction sites and in the worker accommodations, and erosion of soil and earthen material caused by run-off and erosion. An adequately-sized wastewater treatment plant (WWTP) will serve the main work camp and accommodations, with effluent required to meet national standards. Portable toilets will serve all construction sites, and collected waste will be treated in the WWTP. In addition, concrete wash-water will be treated prior to discharge or used in damping roads for dust control. The EPC contractor Water Quality Management Plan will include operating requirements for the WWTP, including requirements to discharge treated effluent only when river flows are relatively high, not during low-flow periods between hydro peaking discharges in winter. The Plan will require the use of specific and general Good International Industry Practice (GIIP) for drainage and erosion control. Other management plans, including those for spoil management, erosion control, and site reinstatement, will also have important mitigation measures for controlling erosion during and after construction. The plan will require regular monitoring of effluent and receiving water quality and frequent inspections of erosion control practi
ces and their effectiveness.



Potential risks to surface water during the operation phase will also be controlled by a Water Quality Management Plan. Sanitary sewage from the few hundred workers would present a risk to water quality, and this will be treated to meet NEQS prior to discharge. In addition, intakes will not be at significant depth, so lower temperature water will not be drawn from the reservoir and then discharged to the river. Failure of a spoil management facility could lead to massive erosion to the river, and this risk will be managed by the Spoil Management Plan, as well as elements of the Sedimentation and Erosion Control Plan and the Site Reinstatement and Landscaping Plan. Water generated by tunneling activities will pass through settling ponds to reduce turbidity prior to discharge to the river, as will water from concrete plants, which will also be neutralized if needed.



Spoil: Excavations and tunneling operations will generate large amounts of spoil, over 14,000,000 cubic meters (m3). Excavations will generate over 99 percent of the spoil, with most from spillway, powerhouse, and tailrace excavations. Most of the material will not be suitable for use as dam rockfill by virtue of its properties or time of generation, but nearly 5,000,000m3 are expected to be reused in spillway, headrace, and powerhouse construction.



Spoil that cannot be used will be managed in four areas with a total area of over 77 hectares, three on the left bank of the river on the territory of Hollar village and one in the river itself, on and immediately upstream of the dam face. These piles will range from 80 to 95m high when complete. Spoil to be reused in construction will be stored at one of the four disposal sites and then transported to the sites of use. The steep terrain through most of the project area has limited the number of potential sites, and these four sites were selected primarily because they offer fairly large areas with gentler slopes that allow large amounts of spoil to be stored.



Management of the spoil can present a variety of risks, including loading and unloading (noise and dust), transport (noise, safety, and dust emissions), slope instability and failure (water quality and biodiversity), erosion, and washout (water quality and biodiversity). The EPC contractor will develop and implement a Spoil Management Plan that will include design and operating requirements for the disposal sites. These will include requirements for land-clearing and site preparation, lift and bench heights, slopes (no more than 2:1), drainage and safe passage of water under, on top of, and around the spoil, the final configuration, and reinstatement with topsoil and vegetation. If feasible, the EPC contractor will prepare the top surfaces of one or more piles for agricultural use. The Plan will also include requirements for final site restoration, which will provide for long-term stability, and this in turn will require a rigorous mo
nitoring program by KPCL, to last indefinitely after construction is complete.



Solid Waste: The ESIA identified a variety of hazardous and non-hazardous wastes that will be generated during construction. Hazardous wastes include used and spilled oils, fuels, and lubricants, paint and chemicals, contaminated media from spills, batteries, fluorescent bulbs, and medical waste. Non-hazardous wastes include domestic “household” waste from the offices, kitchens, and worker accommodations, packaging and pallet waste, iron and other metal scrap, broken concrete, tires, glass, and others. There are no landfills for some distance from the site, so the EPC contractor will develop a 30,000m2 landfill within the area of one of the spoil disposal sites. The landfill will have a compacted clay base, plastic liner, and leachate collection system, and will be under the supervision of full-time staff. Details of wastes that will be accepted, in particular how some hazardous wastes may be handled, are yet to be determined, but will be detailed in the Waste Management Plan. In addition, ultimate closure of the landfill will be described in the Plan.



Materials management: The ESIA requires that materials be handled so as to minimize the risk of pollution, waste, and risk to workers. This will include recycling and reusing materials where possible, and segregation of wastes by type prior to recycling, reuse, or disposal. Fuel and other hazardous materials will be stored over impermeable surfaces with at least 110 percent containment capacity, and cleanup kits will be kept near storage and use areas. Fueling will take place only in designated areas with an impermeable surface. Workers who handle fuels and other hazardous materials will be trained in emergency response in case of spills and trained in cleanup procedures.

Community Health and Safety: The most significant impact of the project on the health and safety of local communities will be the increased flow of construction traffic to and from the project dam site where the bulk of construction activities will take place. Two routes are available for the transport of construction materials, heavy equipment and machinery over the 60 km distance from National Highway 5 (linking the Port of Karachi with the capital Islamabad) to the dam site and upper reservoir. Along these routes are a number of market towns that represent “pinch points” to the flow of vehicular traffic and risks to pedestrians. The high volume of vehicle movements in and around the dam site during construction of civil works – the ESIA estimates an average of 400 vehicular movements per day increasing to more than 1,000 movements per day during the six month peak construction period – pose risks and nuisance (e.g., noise, light and dust, and safety). The residents of Hollar will be affected mostly by any general traffic crossing the Jhelum River near the project site from the west to the east bank. In addition, large numbers of trucks bringing rock and aggregate to the site will pass through Beor, a village close to the project site. Construction site access roads are currently being surveyed and selected by the EPC contractor. Avoidance or minimization of impacts on local communities are included in the selection criteria. Mitigation measures to safeguard communities affected by access road development and use will be incorporated into the EPC contractor Construction Traffic Management Plan (CTMP).



KPCL and the EPC contractor will collaborate with the National Highway Authority to improve the access roads to, and within, the project site and provide adequate barriers to protect village land and housing from traffic nuisance. The CTMP will include provisions for road maintenance and repair, driver training, vehicle maintenance, enforcement of speed limits, abnormal load escort and prohibited operating times to ensure the safety of those residents living near to, and using, project access routes.



Health Care: The ESIA notes that existing health care services in the project area do not meet current demand. The influx of construction workers and project-induced migration during the construction period may put further stress on the availability and quality of health care services for the local population. The EPC contractor will establish an onsite medical clinic for workers and may consider supporting emergency medical services for the project area population. KPCL will also explore the possibility of providing support to more enduring local health care capacity through its Community Investment Program, in consultation with the relevant authorities.



Dam Safety: The ESIA has considered community exposure risks and impacts of principal infrastructure and equipment. The salient design aspects affecting dam safety with respect
to the application of international standards have been reviewed and the implications of dam failure with respect to the safety of downstream communities and economic loss have been considered. The focus of this assessment has been on the safety of the dam and spillway as water-retaining structures with the potential to cause harm to downstream communities through water release causing damage and inundation as a result of structural failure. KPCL commissioned a Dam Break Analysis which is presented as an appendix to the international ESIA. The analysis examined existing studies and data regarding seismicity and large floods.



The Dam Break Analysis concluded that potential downstream risks and impacts from extraordinary flood events beyond the current design standards and from dam failure due to seismicity are not considered to be significant for the size of the Karot project. This is because the narrow gorge has little or no floodplain and there is no significant infrastructure or populated areas between the dam and the downstream Mangla reservoir. Appropriate measures are outlined in the project Emergency Preparedness and Response Plan to identify with certainty downstream infrastructure and people at risk and to put in place appropriate warning systems and other measures to address flood events, rapid water level rises during peaking power production and potential dam failures (ESAP #6).



Hazardous Materials Management and Emergency Response: KPCL will put in place appropriate safeguards to protect surrounding communities from hazards related to the handling and use of explosives during construction, and the storage, transport and disposal of hazardous materials and wastes, and an early warning system for downstream inhabitants to signal unplanned releases from temporary and permanent water diversion structures. The ESMP outlines requirements for an Emergency Preparedness and Response Plan that identifies the roles and responsibilities of KPCL, the EPC contractor and the relevant local authorities to manage accidents and emergency situations, including dam breaks, natural disasters, earthquakes, explosions, severe traffic accidents, spills, landslides, etc., in a manner that prevents or mitigates harm to the surrounding population and the environment.

Security Personnel: KPCL will engage a government-certified private security company to manage security, in addition to implementing standard site security arrangements such as perimeter fencing, controlled access, and road checkpoints. Government security may also be provided to maintain the security of the project area as a whole. Both private and government security personnel will be armed. Given the potentially volatile security situation in this region, as part of the Construction ESMP, KPCL and the EPC Contractor will develop a Site Security Management Plan and Procedures consistent with PS 4 requirements and the CSAIL Site Security Management Plan Framework to ensure that
employees, subcontractors, and the project physical assets, including explosives, are secure and protected. The project Site Security Plan will also identify and assess any potential risks that its own and/or government-managed security arrangements may pose to those within and outside the project site, including residents of the nearest villagers. As a general rule, the KPCL security response will be guided by principles of proportionality, avoidance of confrontation, use of a preventive and defensive approach commensurate to the nature and extent of the threat, and respect for human life and basic human rights. KPCL will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will arrange adequate training for them in the use of force and fire arms, and will impose a Code of Conduct for workers to prevent conflicts with nearby communities. KPCL and its EPC contractor will engage with government authorities and security personnel to agree on their respective roles in relation to the project and principles of engagement with surrounding communities to ensure compliance with PS 4. Any allegations against security personnel by workers or community members will be properly investigated via either the worker grievance mechanism discussed under PS 2 or the community grievance mechanism discussed under the stakeholder engagement section at the end of this document.



KPCL has responsibility in the Contractor Management Plant for EPC contractor compliance with requirements for construction safety, traffic management, dust suppression, solid waste disposal, wastewater disposal, worker accommodations and public safety and project site security through regular monitoring of construction sites and liaison with community representatives and local government authorities.

Baseline: Habitats and flora, mammals, birds, herpetofauna (reptiles and amphibians), fish and aquatic macro-invertebrates were the subjects of specific biodiversity studies in the project area of influence (AoI). Supplemental pre-construction seasonal aquatic baseline studies will be conducted in the coming months (see below).



From the terrestrial perspective, the region is known to comprise the highest plant diversity and proportion of endemic plant species in Pakistan. A total of 195 plant species were recorded in the AoI during field surveys in March/April 2015. No globally/nationally threatened, protected, or endemic species were recorded. During the same surveys, 30 mammal species were recorded. The species of conservation value and/or protected are the Indian pangolin (Manis crassicaudata), smooth-coated otter (Lutrogale perspicillata), common leopard (Panthera pardus) and Eurasian otter (Lutra lutra). Over 94 bird species were recorded in the AoI, including the IUCN Red-listed Critically Endangered white-rumped vulture (Gyps bengalensis) and Endangered Egyptian vulture (Neophron percnopterus). At least 32 species of herpetofauna were recorded, none of which are listed as threatened or endangered.



Of the 17+ fish species recorded, several species of conservation value are documented in the Karot Project area. These include the Golden mahaseer (Tor putitora – IUCN Red-listed Endangered), which migrates from the Mangla reservoir through Karot project area to upper tributaries for spawning; the snow trout (Schizothorax plagiostomus-IUCN Not Evaluated), a migratory fish moving from the upper Jhelum and Neelum to lower Jhelum and Mangla reservoir and back (this species is widely distributed all over the Himalayas); and the common carp (Cyprinus carpio), an exotic species that was introduced into the Mangla reservoir in the 1970s. All three species are also important food sources for local villagers. It is noted, that the Kashmir catfish (Glyptothorax kashmirensis -IUCN Red-Listed Critically Endangered) was not found in the region during fish surveys and is not expected to occur there due to the habitat types present (according to leading fish experts in Pakistan); this species has been documented upstream of the dam. Further field studiesare planned in coming months to confirm these initial findings with focus on confirming the possible presence and abundance of the Golden mahaseer and the presence of the Kashmir catfish.



Habitat Types: Although the terrestrial habitat contains several threatened species, based on current information none trigger PS 6 Critical Habitat thresholds since they and their habitat are widespread throughout Pakistan and the Himalayas. As mentioned in PS1, CSAIL and KPCL will undertake further studies (including migration of Golden mahaseer and Kashmir catfish and its habitat) (ESAP #8) to support development of a basin-wide management plan, which will necessitate a better understanding of cumulative impacts
of development of the hydropower cascade.



The Karot roject is located on the border of the proposed Murree-Kotli Sattian-Kahuta National Park along the western bank of the river in Punjab Province. This newly identified park has yet to be gazetted by the Punjab government and is not subject to active management by the relevant authorities, nor has it been listed in the World Database of Protected Areas. The park has reportedly been established to protect forest habitat but none of this habitat will be impacted by the project within what is understood to be the national park boundaries. The terrestrial ecosystem along this stretch of the Jhelum River is mostly natural habitat (94%) per IFC PS6, the remainder is modified habitat.



The aquatic habitat considered for the ESIA consisted of 27 km upstream of the dam (which will become the reservoir) and 48 km downstream to the upstream edge of the Mangla reservoir, for a total of 75 km. The area above the Karot project dam is currently natural habitat (27 km) while below is mostly modified habitat (48 km) since the reservoir resulting from the Mangla project reaches up to 7 km from the planned Karot project dam site in the high water season and recedes to 48 km from the dam site during the low water season.



Construction Impacts: No globally or nationally threatened species or endemic plant species were recorded in the project AoI. Construction impacts without mitigation are likely to be of moderate or minor magnitude. As the plant species are considered to be of low conservation value, the effect is considered to be adverse minor or negligible and not significant.



The construction works will result in impacts on the habitats and populations of 17+ fish species, especially the migratory Golden mahaseer. These impacts will result from construction of the dam and associated project components (intake, headrace and diversion tunnels, powerhouse, tailrace, spillway; reconstruction of bridges in the upper part of the reservoir; construction of a new bridge, and soil disposal sites). Upstream of the dam site will not be affected by construction except at the spillway and diversion tunnel sites. The dam site segment of the river will be permanently lost and will present a physical barrier to fish movements and migration upstream and downstream. Because the conservation status of the Golden mahaseer is Endangered, the impact of the project is likely to be moderate to major in significance.



Downstream of the dam and spillway up to the Mangla reservoir there will be temporary disturbances to downstream water flow volume and variability; temporary disturbance of river bed due to construction work on installing in-channel structures resulting in a reduction in water quality due to a temporary increase in suspended sediments; reductions in water quality downstream of the dam from potential release of contaminants into the river as well as localized water quality issues due to discharges fro
m construction facilities. Temporary adverse impacts on water quality are likely to result from use of soil disposal sites and construction of bridges. An increase in suspended solids and potential chemical contamination owing to accidental release of contaminants into the river during these activities could occur. These impacts may result in a temporary loss of habitat with avoidance and/or fish and macro-invertebrate mortality.



Commissioning and Operational Impacts: The vegetation in the footprint of the new reservoir will be flooded. This permanent impact will involve the loss of relatively large areas of dense scrub (205.86ha), scattered scrub (54.96ha), bare rocks (127.77ha) and open broad-leaved scrub forest (degraded dry sub-tropical broad-leaved scrub forest, 28.18ha). These habitats, within which terrestrial species in the project AoI occur, are widespread and common in Pakistan. Some loss of terrestrial riparian habitat along the river within the Murree-Kotli Sattian-Kahuta National Park will be affected because of the existence of the reservoir. The impact magnitude because of habitat loss under the reservoir footprint is considered moderate and the effect adverse minor and not significant.



The new 2.8km road will lead to increased vehicle movements increasing disturbance, noise, dust and increased risk of road kills/injury. Riverine species (otters and amphibians) will be affected adversely by changes in the environmental flows and flushing of sediments downstream of the dam, and obstruction of movements along the river because of the dam. However, the creation of the reservoir will be beneficial to otters, water birds, and amphibians, with adverse minor and not significant to other species.



The main impacts of the project operation on biodiversity will be loss of flowing riverine habitat, downstream change in flow regimes from natural flows species evolved to, and placement of a barrier to several fish species’ migrations to their spawning grounds. The impact magnitude on Golden mahaseer was deemed to be moderate to major in significance. A relatively small amount of terrestrial riparian habitat, up to 53 ha, along the river within the Murree-Kotli Sattian-Kahuta National Park will be lost or affected by construction.



Biodiversity Management and Action Plan (BMAP): To mitigate the impacts of Karot project, KPCL will implement the following actions: 1) maintain migration connectivity across the Karot project dam to allow migration past the dam barrier (by engineering means or by periodically capturing and moving fish around the dam by vehicle) 2) support a hatchery for high conservation value fish species; 3) protect river habitat below the dam by gradually implementing peaking flows so as to avoid sudden flow spikes; 4) enhance and protect the river habitat within the nullahs (tributaries) within the project area; 5) enhance and protect downstream fish habitat and refuge pools in collaboration with local authorities;
and 6) initiate capacity-building for local Fisheries and Wildlife Department for aquatic biodiversity management. The project will also support protection of the Murree-Kotli Sattian-Kahuta National Park in partnership with WWF-Pakistan. As noted above, the project will collect additional information on the affected fish species by conducting monthly Golden mahaseer surveys (and possibly tagging) to document migration patterns (and maturity stages, where practical), commissioning intensive September-October 2015 surveys for the Kashmir catfish and its habitat and undertaking long-term post-construction monitoring of fish, river habitat, water quality and invasive species by qualified experts.



To address cumulative impacts of the Karot project and other CSAIL hydropower projects on the Jhelum River, CSAIL will develop a Basin-wide Biodiversity Action Plan (BBAP). Actions will include: 1) developing a comprehensive model of the Jhelum River Basin from the Kohala project to the Mangla reservoir including physical and environmental characteristics; 2) applying the Downstream Respond to Imposed Flow Transformation (DRIFT) aquatic ecosystem / environmental flow model to all CSAIL projects to predict impacts of the projects on project economics and aquatic ecosystem integrity; 3) conducting a Cumulative Impact Assessment (CIA) for the Jhelum/Neelum Basin;4) collaborate with the on-going efforts in the Poonch River to develop a joint Biodiversity Action Plan (BAP) to address biodiversity offsets impacts; 5) exploring the potential of locating the proposed Mahl hydropower project above the confluence of the Mahl Nullah tributary and Jhelum River, so as to allow for the continued migration of Golden mahaseer to the Mahl Nullah ; 6) collaborating with local authority Fisheries and Wildlife Departments for management of the entire Mahl Nullah basin; and 7) supporting the development of fish hatcheries for high conservation species requiring gravel-bottomed, fast-flowing, well-oxygenated rivers.

Two mosques and three gravesites in Karot village are situated in the area where the bulk of project civil works will be constructed. Two other mosques are situated in the project reservoir area. These will be relocated to sites identified by the affected village residents during the implementation of the project Resettlement Action Plan (described in the PS 5 section above). Project community liaison staff will consult with the affected residents and mullahs (mosque custodians and prayer leaders) to ensure the selection of appropriate sites for the mosques and graves, and to ensure that the proper ritual procedures are followed in their relocation.



A religious shrine to a Muslim saint Pir Masoom Shah, located close Karot village, will not be directly affected by project activities, nor will a number of material cultural assets on the road leading to Karot including a masonry wall possibly dating from the 18th Century. Anecdotal evidence suggests that there are no other significant material cultural assets in the project area. Nonetheless, the EPC contractor will be required under the ESMP to adopt a Chance Finds Procedure that will require work stoppage and investigation in the event that material of cultural significance is unearthed during construction.

Inhabitants of the project area have been apprised of the Karot HPP Project since 2009 when a number of scoping meetings were convened with communities in and around Karot by a team of consultants undertaking the original project environmental assessment, prior to CSAIL and KPCL involvement in the project. The main concerns and expectations of affected persons at that time were: reasonable compensation for losses of their assets, such as land, houses, and shops; and prompt and transparent payment of cash compensation so that they could resettle at the places of their own choice.

After KPCL became involved and modified the design, a series of consultation activities were subsequently carried out in June and July 2014 as part of the national ESIA. These activities consisted of scoping consultations and consultations during the ESIA. Meetings were held in the villages of Karot, Gora, Samsu, Soan, Brohi, Hollar, Muslimabad and Ain Pana. In total, 91 people attended these meetings. During this same period, project personnel and the national ESIA consultants met with concerned government departments, line agencies and a number of civil society organizations to apprise them of the project scope and potential impacts

After KPCL submission of the national ESIA in January 2015, the local EPAs organized two public hearings, in Hollar and Karot respectively, within days of each other. The EPAs advertised the ESIA hearings in both local and national newspapers. The consultations were primarily intended to discuss the findings of the ESIA but much of the presentation and discussion focused on land and resettlement issues. Local administration and line ministries were represented as well as the public. Just over 30 participants registered their attendance in Karot and over 135 were at the Hollar meeting. Apart from general support for the project, among the common issues raised in these meetings were: opportunities for employment with the project; parity of regulated compensation rates established by the local governments for land and fixed assets; sufficient compensation to enable affected households to relocate to areas of their choice; and improvement of social services, including public security during project construction;

As noted in the discussion of PS 5 above, to ensure consistency with IFC requirements, KPCL has since early 2015 engaged independent third parties to facilitate the valuation of land and standing assets between government authorities and the PAHs. This facilitation has involved discussions with all PAHs to: 1) familiarize them with project impacts; 2) ensure a comprehensive valuation of all land and standing assets; 3) ensure an understanding of the additional benefits that KPCL will provide (to achieve full compliance with IFC requirements) including targeted benefits for those PAHs considered vulnerable; 4) explain the process and timetable for displacement and compensation payments; 5) explain the procedure that KPCL has established to receive and resolve grievances related to valuation and compensation payments; and 6) to ensure the participation of female household members in all of these discussions.

In addition to the public meetings, focus group discussions and individual consultations undertaken by the company and its consultants within the Project area to date, KPCL commissioned its international ESIA consultants to update the previous Stakeholder Engagement Plan (SEP – the updated SEP is disclosed as Volume VII of the ESIA) summarizing all previous stakeholder engagement, outlining the process of stakeholder identification and the Company commitment to ongoing stakeholder engagement throughout the life of the project, providing information on the project grievance redress procedures and defining responsibilities for implementation, documentation, monitoring and reporting.

As outlined in the updated SEP, KPCL will establish a formal procedure to enable project stakeholders to lodge grievances related to construction and operations activities throughout the life of the project and obtain resolution of those grievances. The KPCL Community Liaison Officers (CLOs) – working under the supervision of the company Environmental, Health and Safety Department – will document grievances lodged by stakeholders directly or through a network of village representatives, and they will collaborate with the EPC contractor and KPCL management to identify the means for addressing and preventing recurrence of events or behavior that give rise to such grievances in the future. CLOs will be responsible for engaging all groups among the Project stakeholders, including women and households considered vulnerable. The CLOs will disclose regular summary reports of grievances raised by stakeholders and the status of their resolution.

Among the upcoming formal stakeholder events, KPCL will convene a formal public meeting on the project RAP and Livelihood Restoration Program following its public disclosure to ensure widespread understanding of the entitlements and responsibilities of those directly affected by the project. The company CLOs will be responsible for ensuring that all households affected by displacement are apprised of the status of the RAP and Livelihood Restoration Program on a monthly, quarterly and annual basis.

http://www.karotpower.com/index.php?action=Environment
The Environmental and Social Impact Assessment (the “International ESIA”) were prepared by a third party disclosed at the website mentioned above is comprised of seven volumes:
Volume I: Non-technical Summary (NTS) of the international ESIA report
Volume II: International ESIA Main Report
Volume III: Technical Appendices/Supporting Documents
Volume IV: Environmental and Social Management Plan (ESMP)
Volume V: NTS of the Resettlement Action Plan
Volume VI: Resettlement Action Plan (RAP)
Volume VII: Stakeholder Engagement Plan (SEP)

Additional CSAIL’s corporate and specific project-level E&S documents can be accessed at the following:

KPCL Islamabad:
Name and Title of the contact person: M. Naeem Akhtar
Address: House No.5, St.72, F-8/3, Islamabad
Telephone: +92 51 2287188
Email: mailto:mnaiem05@gmail.com

Stakeholder engagement undertaken by the Company since 2014 has enabled the continuous participation of affected communities in consultations regarding Project activities. The results of this engagement provide ample evidence of informed consultation with, and participation of, affected communities. Key concerns raised by the communities, which are being addressed by the Company, include the nature and timing of compensation amounts, equalization of compensation rates between the two different administrative units, provision of residential plots and basic infrastructure for physically displaced households, and employment. Based on IFC's documentation review, field visits, interaction with affected households and their leaders, meetings with the social experts implementing the land acquisition and resettlement process and with district and regional officials, the IFC team confirms that the community is broadly supportive of the Project.

Title	Anticipated completion Date
KPCL will review and confirm that the Karot EPC Contractor’s Construction E&S Management Plan (CESMP) is consistent with the requirements of the Karot project ESIA ESMP and the CSAIL E&S Management System.	12/15/2015
KPCL will provide for IFC review and approval a Contractor Management Plan, inclusive of KPCL’s plan for monitoring the EPC Contractor’s environmental, social, health, safety and social management (ESHS) performance, and also inclusive of a centralized performance tracking system to monitor all ESHS components of the Contractor Construction Management Plan.	11/30/2015
KPCL will appoint a team of qualified full-time professionals to oversee the EPC Contractor’s implementation of Occupational Health and Safety (OHS), environmental, and social requirements of the ESMP as required by the Contractor Management Plan.	11/15/2015
KPCL will appoint Owner’s E&S Advisors to support KPCL and its EPC contractor in planning and implementing actions to meet IFC PSs and international standards.	11/15/2015
KPCL will require its EPC contractor and subcontractors to incorporate into all labor contracts a provision for appropriate dispute resolution to address potential conflict between national labor regulations and local customary practice.	10/31/2015
KPCL will: 1) undertake an assessment of the risks to lives and property from anticipated and unanticipated downstream releases during the construction and operation of the Project; and 2) design, establish, operate and maintain an early warning system commensurate with the level of risk identified in the assessment.	05/30/2015
KPCL will prepare supplemental RAP template to document additional land acquisition and displacement, including land acquired for the transmission line, is consistent with IFC’s PS 5 requirements, and mitigation approaches are consistent with the RAP.	12/30/2015
KPCL will appoint qualified consultants to implement the TOR for intensive surveys for the Kashmir Catfish and Golden mahaseer and their habitats in the reservoir area and the downstream Jhelum River, and will submit a report on the effort for IFC review and approval.	12/30/2015
KPCL will support CSAIL’s efforts to assess and address cumulative impacts of the Karot project and other CSAIL hydropower projects on the Jhelum River, as required by the Karot project ESIA and the Basin-wide Biodiversity Action Plan.	12/30/2016