DG Sindh Environmental Protection Agency

In reference to the public hearing held in KMC on 22nd July 2014 regarding Grade Separated Traffic Plan near Park Towers.

Our objections and recommendations are as follows:

1. The Environment Impact Assessment (EIA) study the presentation of which was done by the consultants should be scrapped. The entire house agreed with this recommendation. Some of the reasons are mentioned below:

a. The study misinformed the public that stake-holders were consulted. The following present in the hearing voiced that they were not consulted at all (particularly the elected representatives) or with whom post-approval consultations were held only to appease them:

i. MNA of NA 250 in whose constituency lies the project.

ii. MPA of PS 113 in whose constituency the traffic is being released (DHA).

iii. MPA of PS 112 in whose constituency the project is being implemented.

iv. FPCCI whose building is on the road next to Point and who represent all trade organisations in Pakistan.

v. Defense Housing Authority.vi. Stake holder residents like Mr Shaheen Merchant

who presented objections and alternate proposals in the hearing.

vii. Shehri who also presented their objections.b. The EIA study was totally biased and evidently in support

of the builder and the KMC plan. It was not balanced as it did not show concern on any environmental issue except that the project should be completed immediately.

c. The EIA stated that upon completion there will be noise reduction which is a ridiculous statement as evident in studies throughout the world that traffic increases when bridges and underpasses are made, resulting in increase in traffic noise.

d. They misinformed the public that they had consulted with the members of the Manadev Mandir governing body.

e. All positives were from the builders lobby and there was no study of the social impact of the project on the residents of the area.

f. Particularly ignored were the residents of Neelum Colony who live immediately adjacent to the project

2. The KMC did a presentation justifying the project. We have the following objections and suggestions:

a. It is surprising that the matter was not brought before the public. It was done without transparency and in very fast manner where approvals were given within days and weeks. Such processes in most efficient societies take enough time to make sure there are no miscarriages. The biggest argument of the poor methodology adopted to appease a builder and with questionable enticements to expedite led to a huge public outcry and the area is in a mess. KMC has been highly irresponsible and has degraded its reputation.

b. It is evident that the project was designed to support a big building called Bahria Icon Tower.

c. KMC and civic bodies should have made sure first that the infra-structure of water, roads, parking exists before giving approvals. It is surprising that because high levels of corruption are involved approvals of commercial buildings are given first and then infra-structure catches up at great public cost and inconvenience to the residents. Meanwhile the builders have made their huge bucks and are gone.

d. There were no alternatives presented to the existing plan? Why? Does not the public deserve to evaluate other options that were considered?

e. There was no visual model of the impact of the project with reference to Jahangir Kothari promenade This is surprising as at very low cost a model could have been shown. There is a legal limitation around Quaid-e-Azam Mazar of multi-story buildings so as not to encroach the visibility and beauty of the monument.

3. It is a shame that the Jahangir Kothari promenade has already been encroached upon and part of the structure destroyed.

4. Handling traffic problems without improving the metro system or public busing and only through bridges and underpasses serves to pick up the load and drop it into another crossing. As appropriately quoted it is like extinguishing fire with petrol as it encourages more traffic load also.

5. We strongly recommend that the proposals and objections from DHA, Shehri, the elected representatives, and the public be given importance which unanimously and clearly rejected the project as it stands and voiced serious suspicions on the workings of the civic agencies to the detriment of the public at large.

6. In future SEPA should play a more effective and pro-public role as compared to what has been done until now as some members of the public, including us the elected parliamentarians of the area

have voiced their concern on the pre-determined direction of the hearing.

There is a huge dugout at the site causing tremendous inconvenience to the public. A quick decision should be made to modify the existing plans incorporating other options and suggestions for traffic improvement that have been made, and to prevent further damage to the archaeological sites.

If such an expeditious process is not adopted, then at least the dugout has to be filled up immediately and the place restored until an improved model is adopted to change and facilitate the traffic flow in this area.

Signed/

Dr Arif Alvi MNA from NA 250Mr Samar Ali Khan MPA from PS 113Mr Khurrum Sherzaman MPA from PS 112Dated 28th July 2014