Honorable Mr. Imran Ahmed Khan Niazi

Prime Minister of Islamic Republic of Pakistan Islamabad

SUBJECT: Civil Society response to Ravi Riverfront Urban Development Project

Your Excellency, LDA has prepared a PC-II for Ravi RiverFront Urban Development project. This PCII is based on a study conducted in 2013-15. The plan envisaged channelizing 46 km length of the river from Siphon up to its Confluence with Hudaira Drain, construction of 3 barrages and high quality urban waterfront development along both edges of the river along the length of Lahore City. The project was rejected in 2015 due to the constraints of funds.

The project has been reactivated and LDA is proceeding with a PC-II calling for consultants to update the development plan and prepare detailed feasibility followed by detailed design and development of procurement documents.

We as citizens of Lahore and stakeholders draw your attention to the following concerns:

1) This project is unsustainable from all fronts including an environmental, ecological and financial –its concept is against all the UN-SDG goals to which Pakistan is a signatory, and is in violation of the Lahore High Court orders in regard to the recommendations of the River Ravi Commission.

2) Channelization of the river is not an option –it is against all principles of sustainable development and ecological sustainability of a river and its environment.

3) The riverbanks are an integral part of the river ecosystem and the hydraulics of the river in which there is no defined edge should be maintained.

4) Lahore city has encroached upon the flood plain over the years altering the basic natural landscape of the river irreversibly and changing the ecology of the region coupled with using the river being used as a disposal channel for sewage and industrial waste of the city. LCS

5) LDA apparently wants to continue the practice of reclaiming the floodplain through engineering interventions to expand the city.

6) River training of the scale anticipated will be extremely costly. A minimum interference and alteration of floodplain should be considered. LDA should consider lower cost interventions with limited engineering works as opposed to very large-scale river training works at public expense in view of limited financial resources.

7) The Lahore Master Plan 2040 is yet to be completed and no project should be initiated till such time the Master Plan recommendations are in place.

8) The Punjab Floodplain Act of 2016 clearly defines the principles and policy for development of flood plain, and rules for management of flood plain. This should be followed in letter and spirit based on a well thought policy and priorities.

9) Land cost along the river embankment will be beyond the paying capacity of the population as the cost of development works will be exceptionally high. This reclaimed land will add to the appropriation by the power elites of the ‘Common patrimony’ of the citizens of Lahore and will not cater to the vast majority of the low and middle income sector.

RECOMMENDATIONS:

1) LDA’s first priority should be preparation of a Lahore Master Plan in consultation with all stakeholders. Development of such large scale proposed projects should be conceived in the context of an overall well thought strategy for development of the city that takes into account options for development that best meet the needs of the future, taking into account social equity, environment and economic feasibility.

2) The high investment and ecologically damaging interventions proposed in the pre feasibility studies must be reviewed and recommendations of an alternative approach which is sustainable both environmentally and economically be explored. Restoration of the river landscape to natural conditions should be seriously considered the alternative.

3) The river banks must be maintained in their original state and the land prone to the 1 in 10 year flooding be declared a National Park for public use and can be used for recreational purposes with low level landscaping that will not be damaged by the occasional flooding of the river. Tourism and limited compatible economic activities can be considered in this zone.

4) LDA should consider regulation of developments in this floodplain following masterplans and zoning and building regulations prepared by LDA. LCS 5) The reduced flow of water of the Ravi (due to the diversion of waters by India) primarily carries the sewage of Lahore particularly in the dry season. LDA and WASA should focus on efforts to revitalize the river water through supplying treated cleaner sewage water and cleaning up the original urban storm water nullahs which are currently carrying raw sewage. LDA should focus on cleaning up the large number of drains in the city that carry municipal and industrial sewage and rehabilitating the areas along them.

6) Water quality upstream of Lahore is good and restoration of the river landscape to natural conditions is an easy and economical alternative in this area to be part of the National Park. The establishment of wastewater treatment plants in the city by WASA will also improve the quality of water downstream.

7) A Masterplan for Eco-Revitalization of River Ravi Basin is being finalized in consultation with the government. LDA is encouraged to consider the plan and hold discussions with consultants to see how best its findings and recommendations can be incorporated into any urban development plan on the riverfront.

On behalf of citizens of Lahore,

President Lahore Conservation Society

CC:

Director General,

LDA Vice Chairman,

LDA Malik Amin Aslam,

Federal Minister & Advisor to Prime Minister on Climate Change Governor,

Punjab Chief Minister,

Punjab Finance Minister,

Punjab Minister of Environment,

Punjab Minister for Housing, Urban Development & Public Health Engineering, Punjab Chief Secretary,

Punjab Commissioner Lahore Secretary Finance,

Punjab Chairman P&D Secretary Housing,

Urban Development & Public Health Engineering,

Punjab LCS Secretary Forestry WildLife & Fisheries,

Punjab Director General Environment Protection,

Punjab CEO WWF-Pakistan, Lahore Office