Annex T: Environmental and Social Management Plan (ESMP):

1. Project Description

The leather sector in Karachi comprises of two types of manufacturing activity: wet processing factories (tanneries); and value addition units (garments making and stitching). Total exports of leather sector comprise of ~48% tanned leather and ~52% value added products. Tanneries are involved in processing the raw material partially or fully to finished leather (from raw hide or skin to finished leather, the tanning unit might process only from raw to wet blue, or from wet blue to finished leather, or from raw to finished). There are about 120 tanneries in Karachi, almost all of them located in one cluster – sector 7/A of Korangi Industrial Area.

Value addition units typically convert the finished leather into garments, gloves and other value added products. There are around 60 formal units, besides an estimated equal number working in the informal sector. Around 50% of these units are located in sector 7/A, and remaining are located in other sectors of Korangi Industrial Area and other industrial areas of Karachi. Leather industry, being the second largest foreign exchange earning industry of Pakistan, has a very strong export orientation. Thus besides meeting local regulations, it is also required to comply with the strict standards of the developed world and meeting the requirements of its overseas buyers on highly competitive international markets. In Karachi, the unique feature of leather industry is that most units (both wet processing and garments) are located in a specific sector. This gives rise to very high potential for sector specific, combined or joint services. Hence previously, Combined Effluent Treatment Plant was established in this sector. Also Conveyance System carrying Wastewater from individual tannery is an integral part of the Combined Effluent Treatment Plant. Around 12 km long open concrete drains were constructed to serve the purpose. The leather products sector in Karachi has undertaken some key development initiatives in the past. These include the setting up of Combined Effluent Treatment Plant, Cleaner Technology Project for Karachi Tanneries, and establishment of National Institute of Leather Technology.

A large size Combined Effluent Treatment Plant (CETP), to treat the effluent being generated by around 170 tanneries located in Korangi Industrial area Sector 7/A, was commissioned in August 2005. CETP has a treating capacity of 43,000 m3 wastewater per day, while currently it is treating 16,500 m3 tannery effluent and 26,500 m3 per day of domestic wastewater. The fully functional CETP has the unique distinction of being the largest environmental project of the Private Sector with participation of Government. Because of its nature, the project is being followed as a model environmental project of the industry in Pakistan. If the service quality of CETP goes down for any reason, it will have a direct implication on exportability of leather by the tanneries connected with CETP. Figure: CETP Karachi Korangi

CETP plant is based on UASB technology. Besides other advantages, this technology also produces Methane (Biogas) which can be used to generate electricity to fulfil 70 percent of the plant's need. Biogas generators are prerequisite for using the produced Methane. Availability of these generators will save 70%of the energy already being continuously provided through natural gas supplied by SSGC. Resultantly, overall O&M cost of the CETP will significantly reduce, thereby reducing the monthly amounts charged from its connected tanneries. In addition, use of biogas generators will also enable to save the environmental issues. Also Conveyance System carrying Wastewater from individual is an integral part of the Combined Effluent Treatment Plant. Around 12 km long open concrete drains were constructed to serve the purpose. The leather and leather products play a prominent role in the world’s economy, with an estimated global trade value of approximately US$134 billion in 2014 (ITC, 2016). Although the Leather sector and tanning industries have a positive effect on employment rates in Pakistan and Karachi-Korangi, their effect on the environment is a serious threat for future development.

2. Policy, legal, and administrative framework

The Government of Pakistan enacted the Pakistan Environmental Protection Act (PEPA) in 1997 which is the most recent and updated legislation on environment. It provides a framework for establishing federal and provincial Environmental Protection Agencies (EPAs), and suggestions for protection and conservation of species, habitat and biodiversity, and conservation of renewable resources.

The guidelines on solid waste disposal and landfill establishments identify and explain issues that should be addressed for a proposal for solid waste disposal and establishment of landfill facility for municipal and hazardous waste. It is important to focus on key issues for specific proposals. The matter identified in these guidelines provides guidance, for setting up of solid waste disposal and landfill facility in Pakistan. It is recognized that there are five stages in the process of developing solid waste and landfill facility and following factors should be considered at each of these stages: i. The need to have a solid waste disposal and landfill facility ii. Selection of an appropriate site for solid waste disposal and landfill facility iii. Installation, commissioning and operation of solid waste disposal and landfill facility iv. Monitoring and reporting of solid waste disposal and landfill facility v. Closure of landfill facility Landfills are disposal sites that can be established successfully if they are well sited, well designed and operated properly. They have the potential to cause environmental harm if not sited, designed and operated properly. Although some legislation is in place, rather implementation is a challenge due to lack of resources and/or lack of knowledge and proper technology available within Pakistan. The Leather Product Environmental Footprint Category Rules (Leather PEFCR) officially approved by the Environmental Footprint Steering Committee. The establishment of the Leather PEFCR represents a major milestone in coming to a harmonised methodology for the calculation of the environmental footprint of leather made from hides and skins of animals slaughtered for the production of meat. This will bring also to the Pakistani leather sector a tool to reduce environmental footprint from the leather processing.

3. Environmental and social risks and mitigation measures

This section describes relevant environmental and social risks identified during the project preparation period (PPG). ESMP should serve as an active tool, additional risks that are identified during the project implementation will be included as they are identified.

E&S risks Mitigating Measure

Technical details of the mitigation technology,

process, equipment, design and operating

procedures

Location

Timeline, including

frequency, start and end date

Responsibility

Cost of Mitigation (If Substantial; to be covered by the GEF grant or non-UNIDO

co-financing)

Risks identified during the PIF

preparation and verified during the

project preparation(PPG)

Main environmental risk is that the situation with solid waste and solid waste management will not improve and will remain same

Engagement of relevant partners (public and private industry)

The project will prepare various options to address the problem and improve situation. Capacity building will be implemented to raise awareness. Activity 3.1.1 – Project will prepare realistic options (feasibility plan) for different solid waste fractions

Karachi, Korangi 7A Y1 Q 2 – Y1Q4 Project team; solid waste expert

GEF grant output 3.1

Improper implementation of solid waste management (collection; utilization; treatment)

Utilization of existing/proven technology and methods Training personnel on safety and operations Waste management

Proposed solid waste management options will take into consideration local conditions (such as volume of waste, market and other factors). Proven technologies in other regions will be considered and adopted for the site. Collection facilies – there are many examples available within region, and proposal will be harmonized also with e.g. province etc. There will be training on safety and also development of tailor prepared programme for industrial safety trainings.

Karachi, Korangi 7A Y1Q2 – Y3Q3 Project team, experts and training experts

GEF grant output 2.2 and 3.1 UNIDO’s training courses available (www.leatherpanel.org)

E&S risks Mitigating Measure

Technical details of the mitigation technology,

process, equipment, design and operating

procedures

Location

Timeline, including

frequency, start and end date

Responsibility

Cost of Mitigation (If Substantial; to be covered by the GEF grant or non-UNIDO

co-financing) Infrastructure developed is vulnarable to climate change risks

Sufficient due diligence to be undertaken and technical analysis for the project

Mitigation will involve carefully defining scope and design project details for collection sites and proposed options for solid waste utilization.

Karachi, Korangi 7A Y1Q3 – Y3Q4 Project team, technical experts

Output 3.1

Low participation rates of females in project implementation

Gender is mainstreamed throughout the project design

This project will pursue thorough and gender responsive communication and ensure stakeholder involvement at all levels, with special regard to involving women and men, as well as civil society and non-governmental organizations promoting gender equality. This shall mitigate social and gender related risks, promote gender equality, create a culture of mutual acceptance, and maximize the potential contribution of the project to improving gender equality in the energy field. Proposed technologies to re-utilise waste and by-products from the leather processing should provide also working opportunities for men-women

Karachi, Korangi 7A Y1Q2-Y3Q4 Project team, PTA S.S. ES;

Output 2.2

Project developments involve alteration, damage or removal of any critical physical or cultural heritage

Screening Public consultation

Although the project site is industrial site, and no major cultural heritage is expected, project development team screens early for the existence of physical/cultural

Karachi Korangi 7A Y1Q1-Y1Q3 National Project Director

Output 3.1

E&S risks Mitigating Measure

Technical details of the mitigation technology,

process, equipment, design and operating

procedures

Location

Timeline, including

frequency, start and end date

Responsibility

Cost of Mitigation (If Substantial; to be covered by the GEF grant or non-UNIDO

co-financing) resources. The screening phase should identify the extent and complexity of potential cultural heritage impacts in the project’s area of influence. If the screening indicates potential adverse impacts, further analysis will be necessary to ascertain the nature and scale of these impacts and proposed mitigation measures. The breadth, depth and type of analysis should be proportionate to the nature and scale of the proposed project’s potential adverse impacts on cultural heritage resources. Should they be identified, a decision will be made to either relocate the project to a different site or stop any further project development.

Property ownership Due diligence As proper ownership of technology for solid waste management is crucial for sustainability of the project (collection site, collection vehicles and equipment),. The project will prepare and elaborate on business model for solid waste management site. The NPC will investigated issues of changes in property use and ownership and impacts these may have on the community/

Karachi Korangi 7A Y2Q1-Y3Q4 National Project Director

Output 3.1 Activity 3.1.4

E&S risks Mitigating Measure

Technical details of the mitigation technology,

process, equipment, design and operating

procedures

Location

Timeline, including

frequency, start and end date

Responsibility

Cost of Mitigation (If Substantial; to be covered by the GEF grant or non-UNIDO

co-financing) stakeholders. Specific attention will be paid to potential property acquisition, expropriation and/or restrictions on use, resulting in the temporary or permanent loss of use of property for economic activities.

Additional risks identified during the

project implementation

4. Environmental and social sustainability monitoring

E&S risks Parameters to be measured

Monitoring methods and procedures used

(e.g. sampling)

Timing/Frequency of measurement Detection limit

Definition of thresholds

Sampling/monitor

ing location

Responsibility

Risks identified during the PIF

preparation and verified during the

project preparation(PPG)

Main environmental risk is that the situation with solid waste and solid waste management will not improve and will remain same

Emissions and use of appropriate technology

Surveys, impact assessment, reports

Continuos 0 NEQS not achieved

Project site PTA S.Z ES

Improper implementation of solid waste management (collection; utilization; treatment)

Proper due diligence utilization of proven technologies. Training of personnel

Feasibility reports, missions reports, Training reports and logs of report (on-line training)

Q1-Q20 Continuos

2-5 More than 350

Number of technologies proposed&implemented Number of trained personnel

Project site Project team

Infrastructure developed is vulnerable to climate change risks

Type of hazards, their frequency

Risk assessment screening

Q1 –Q12 Single measurement

More than 5% Probability of negative impacts due to climate hazards on infrastructure to be developed

Karachi Korangi Project team

Low participation rates of females in project implementation

Social diversity and gender balance

Survey Q1-Q36 Annually

<30% Percentage of female participants – in capacity building and productive activities

Project site NPD

Project developments involve alteration, damage or removal of any critical physical or cultural heritage

Proximity to sensitive and valuable ecosystem; Archeological and/or historical sites

screening Single measurements prior to site selection (e.g. collection points)

Site specific No encroachment or destruction of critical physical or cultural heritage

Demonstration site

NPD

E&S risks Parameters to be measured

Monitoring methods and procedures used

(e.g. sampling)

Timing/Frequency of measurement Detection limit

Definition of thresholds

Sampling/monitor

ing location

Responsibility

Property ownership

Type of property ownership

Due diligence Single measurement N/A Compliance with all rules and regulation

NEP PM, NPD

Additional risks identified during

the project implementation

5. Capacity development

In order to achieve these goals skills development and capacity building is a key factor. The project team will use proven and efficient methodology implemented over last years in various other projects. One of the core competencies of UNIDO is technology transfer. Although not an educational institution in of itself, UNIDO recognizes and fully embraces education and its multiple formats as a necessary and significant means to build technical capacity of it counterparts. Although starting e-Learning services may be launched by using the existing knowledge base but converted into electronic formats, this does not suit current requirements for efficiency. Learning content development within the leather value chain is an on-going challenge as it requires multidisciplinary team and resources. Due to the size of the leather sector to a date there are only few examples of e-Learning content development. Based on the Expert Group meeting focusing on the e-Learning in June 2016 in Mwanza/Tanzania, e-Learning and blended training is not used widely within the leather sector and institutions involved in the training have no or only little knowledge with use of on-line training. Lack of available learning content and training courses resulted in the development of on-line training courses and learning content (learning tools) which can be used by training institutions including industrial companies to train students either in face to face training with use of developed learning tools, for the self-learning or blended training. UNIDO has started to build range of courses and learning content development (LCD) for the leather value chain:

i) Introduction to treatment of tannery effluents (5 modules) ii) How to deal with hydrogen sulphide gas (module & test & certificate) iii) First Aid (8 modules) iv) Sustainable leather processing (Learning content under development) v) Leather testing vi) Working at height vii) Footwear pattern engineering (25 modules & 20 self-tests)

Figure 1 UNIDO’s animated training tools – modular approach

First Aid at the

Workplace Modular approach

Introduction to the

Treatment of Tannery Effluents

Leather Testing

Working at

Height

Sustainable Leather

Manufacture

How to deal with

Hydrogen Sulphide

Gas

Content development is prepared in a modular approach, with a possibility to use required training material and training tools. UNIDO’s & IULTCS e-learning course on “How to deal with Hydrogen Sulphide Gas” is self-study, easy to use, and contains an animated visual training tool. The course complements UNIDO´s Safety Handbook on “How to Deal with Hydrogen Sulphide Gas in Tanneries and Effluent Treatment Plants”, which is also available to download after enrolling in the course.

Figure 2 Steps of on-line H2S course

Figure: Training cycle

6. Communication

As part of the GEF Annual Monitoring Report (AMR), UNIDO will annually communicate implementation progress on issues that involve ongoing risk to or impacts on the project stakeholders, and on issues that the consultation process or grievance mechanism has identified as of concern to those stakeholders. The ESMP will be disclosed on the UNIDO public website, under the following link: https://open.unido.org/index.html

The environmental and social risks, proposed mitigation actions and monitoring arrangements will be included in the annual reporting of UNIDO to GEF as part of the project AMR. Furthermore, reporting on the compliance with the ESMP will be made during the project steering committee meetings.

A stakeholder engagement plan is presented below will be developed and implemented within the project.

Consultation Purpose Participants Lead/Chair Reporting Schedule Initial Project Start up:

Project Overview Project Organization Project Schedule Social and Env

Impacts ESMP

PTA SZ; MoCC PTA SZ and/or Mocc

Inception phase report

Y1 Q1

Public consultation & site visit

Adjusting of mitigation measures, if necessary;

Impact of replacing and updating activities;

Comments and suggestions

PTA SZ; MoCC; national and/or international experts

PTA SZ and/or Mocc

Progress reports, PIRs, MTR

Y1 Q2-Y2 Q2

Public consultation & site visit

Effectiveness of mitigation measures;

Impacts of project implementation;

Comments and suggestions.

PTA SZ; MoCC; national and/or international experts

PTA SZ and/or Mocc

Progress reports, PIRs, final evaluation

Y2 Q3-Y3 Q4

Expert workshop or press conference

Comments and suggestions on impacts;

public opinions

Not foreseen individually but special sessions can be integrated to various workshops planned during the project

Addressing Community Concerns

Consultation on Grievance Procedure

PTA SZ; MoCC; national and/or international experts

PTA SZ and/or Mocc

Progress reports, PIRs

Continuous