Dear Mr. Roche.
Asian Development Bank,
Manila.

You have invited me in your last email dated January 18, 2004, to attend the multi-stakeholders� workshop on the Chashma Environmental Management Plan (EMP). I have also received the revised (and abridged??) copy of the Chashma Environmental Plan (January 2004) from the Environmental Cell of Water and Development Authority (WAPDA), along with a covering letter in which I have been invited to comment upon the plan. However, there is no mention in the letter about the stakeholders� workshop that you have mentioned in your email.

I have got the chance to quickly go through the proposed plan. If I understand correctly, the history of the preparations of the Chashma Environmental Management Plan and its subsequent overlapping/mingling with the National Drainage Program (NDP) is as follows:

ｷ In November 1993, Environmental Impacts Evaluation (EIA) was conducted for the Chashma Right Bank Irrigation Project (CRBIP) Stage-I &II (The document is not yet disclosed).

ｷ January 1994, Initial Environmental Examination (IEE) was conducted for the CRBIP Stage III. It was decided on the basis of that investigation that the project did not entail significant adverse environmental impacts and thus it was deemed unnecessary to conduct Environmental Impacts Examination (EIA).

ｷ The first Chashma Environmental Management Plan was prepared and completed in March 1995. The first plan was prepared by Sir Mcdonald & Partners Ltd. And Associates. The first plan recommended the implementation of primary, secondary, compensation and enhancement measures. However, the implementation of these measures was not done due to unknown reason.

ｷ In this original plan, four compensation measures were also suggested that included reparations (the term used in the original document) for abandoned but un-irrigated rowed-kohi, reparations for temporary loss of rowed-kohi during construction, reparations for changes due to water logging caused by seepage, reparations for consequences of CRBC breaches, and reparations for flooding due to impeded cross drainage. There were also mention of socio-cultural program, watershed management, land leveling, lining of the flood carrier channels, etc. but the details are not known what was meant by those terms. (The document is not yet disclosed to us).

ｷ The August 95 ADB Mission selected only four primary mitigation measures (realistic water charges, efficient collection of water charges, reduced cropping of rice, reduced/controlled water allowances) for implementation. These measures primarily represented the thrust of legal, institutional and fiscal changes as suggested in the NDP. However, the government did not agree to the proposal.

ｷ The October 1995 ADB Mission decided to pursue the financing of the selected mitigatory measures from NDP funds. The number of measures was increased to five. However, the revised plan was also not implemented due to unknown reasons

ｷ In 1999, the Chashma Irrigation Project experienced substantial cost overrun because of delayed implementation and changes in the project design, ADB provided supplementary loan through transferring the required amount from NDP to the overall Chashma Irrigation Project. The case of supplementary financing is discussed in details in the Chashma inspection claim.

ｷ The November 2000 ADB Mission recommended the formulation of a Salinity Management Plan (SMP).

ｷ In June 2001, the Environmental Cell of WAPDA submitted the proposal for implementation of Salinity Management Plan. It was to be financed from the project costs, not from the loan proceeds of NDP.

ｷ In August 2001, AHT International GMBH Consultants reviewed the first Chashma Environmental Management Plan and recommended the same primary mitigation measures as suggested by the August 95 ADB Mission and presented new costs for the implementation of the plan. As most of the proposed primary mitigatory measures-reduction in irrigation subsidies through the so called realistic water charges and the efficient collection of water charges through transferring management responsibilities to farmers- were relevant to the NDP, it was again offered by ADB to the government to provide funds from NDP for the implementation of the revised proposed plan (the document is not yet disclosed).

ｷ In November 2001, the revised proposed Chashma Environmental Management Plan was submitted to the government of Punjab and NWFP through NDP provincial coordinators but the plan was not approved by the government.

ｷ The August 2003 ADB Mission, the case of Chashma Environmental Management Plan was again discussed between ADB and NDP authorities and it was agreed to review the document and implement the plan through NDP loan proceeds. The implementation of this newly revised plan is being envisaged in three phases starting from this year and to be completed in 2006.

ｷ Chashma Environmental Management Plan Phase- I include the implementation of irrigation management program, impact assessment of agro-chemicals and integrated pest management, investigation on drainage barriers soils and environmental management plan. The total for first phase (year 2004-5) is Rs.8.494 million.

ｷ The second phase (year 2005-6) includes sandy soil investigations program, environmental monitoring and evaluation program and environmental coordination. The total cost for phase-III is Rs.7.604 million.

ｷ The third and last phase of the Chashma Environmental Management Plan (year 2006) includes channel lining program, subsurface drainage schemes and cross-drainage priority maintenance and monitoring program. The total cost involved its implementation is Rs.8.081 million.

Don稚 need to say that the story of the chashma environmental management plan is an episode expounding secret dealings between the Government and ADB, lucrative business of consultancies, displacing local knowledge of land, water and soil from the official dominant discourse, constructing new expert (scientific) knowledge revolved around the imperatives of market and profit, etc. I will not here mention the so called policy slippages occurred in this process because the inspection panel will be now responsible to look into this matter. I will also not mention the practices of confidentiality that left little space for the engagement. Imagine, we are engaged with the Bank for the last three years and we have been only partially disclosed the last document. This is even made at the moment when the decision has already been made and this is self-evident from the letter that I have received from the Environmental Cell.

Let me also be straightforward. ADB is primarily interested to introduce fiscal and institutional changes in the irrigation sector and the Chashma project in the name of environmental management plan. These fiscal and institutional measures are only aimed to reduce irrigation subsidies and transferring the management responsibilities of ill-designed and flawed project.

Let me also inform you that the Chashma Lok Sath (Peoples Assembly), held on August 24, 2003, decided to initiate the movement for not paying water charges unless reparations were not paid to us for massive damages that we suffered due to the project.

We need certain information before articulating our formal response on your invitation to attend the stakeholders� workshop on the Chashma Environmental Management Plan. The specific queries are as follows:

ｷ What are the projected operation and maintenance (O&M) costs involved in the Chashma Irrigation Project? If possible, please provide the detailed cost break down.

ｷ What is the legal relationship between the Chashma Irrigation Project and NDP? The Chashma Environmental Management Plan is one of the sub-projects of NDP. Are the social and environmental guidelines of NDP are applicable in the Chashma Right Bank Irrigation Project or not?

ｷ A few ADB consultants are roaming around in the west side of the main canal and trying to extract information from local communities. What are their specific responsibilities? Are they funded by the GRSC grant or new grant was approved for these consultants?

ｷ When we will be able to receive the final GRSC report?

ｷ You mentioned in your email that the government did not agree to disclose the old and detailed versions of the Chashma Environmental Management. It is difficult to understand the logic that the recent (abridged) version has been disclosed while the decision was made not to disclose the old ones. We are very much interested to get the copies of all the reports mentioned above. Without such disclosure, it is impossible for us to articulate our response on the invitation to attend the workshop. I will be writing a letter to the Environmental Cell as well.

Please let me provide information on the above mentioned points so that we can articulate our formal response on the invitation to attend the workshop on Chashma Environmental Management.

Regards,

Mushtaq Gadi