Marked by folly

July 26, 2020

The Ravi Riverfront Urban Development Project raises serious questions of urban planning, environmental regulation and governance

Unless the River Ravi Basin is understood holistically, the RRUDP investment efforts will result in a polluted ecosystem downstream Lahore. — Photo by Rahat Dar

The Lahore Development Authority (LDA) recently invited international firms to submit expressions of interest (EOIs) in Punjab government’s Ravi Riverfront Urban Development Project (RRUDP) which entails developing “high quality residential, institutional, commercial and recreational zones” along the Ravi, covering 102,000 acres of land and stretching over 46 kilometres.

The government has announced its intention to promulgate an ordinance establishing the Ravi Riverfront Development Authority (RRDA). So far, no details of the Authority and its powers/functions have been made public, and no draft of the proposed ordinance shared. Judging from newspaper reports, however, the authority will work to develop a new city with an investment of Rs 5 trillion made by the private sector.

Both the EOIs and the RRDA raise serious questions of urban planning, environmental regulation and governance. If these questions are not answered well, the fate of the project and all involved will be marked by folly. First, consider the urban planning dimension. In 2012, an amendment in the LDA Act gave the Authority control over the entire Lahore Division. Now overseeing five districts, the LDA became Pakistan’s first regional planning authority.

One would have thought that, given its expanded role, it would move towards a regional master plan. Instead, the authority, in 2014, adopted an Integrated Master Plan for Lahore prepared by NESPAK and approved by the Lahore District Council circa 2004 as Master Plan 2021.

Chapter 18.2.5 of Volume II of the document underlines the “need to ensure compact and consolidated form of urban expansion instead of piecemeal development which rapidly consumes rich agricultural land.” Volume II also notes that due to “physical constraints” such as the Ravi in the north and border in the east, “growth strategies for Lahore will be constrained… and the existing growth trend towards the south has to be accepted until a positive change in relationship with the neighbouring India becomes a political reality to justify expansion to the east.”

Given the explosive urban growth in the Punjab over the last two decades, one would imagine that the LDA would attempt to survey its expanded jurisdiction and prepare a new plan for the Lahore Division. This has happened, but in a rather convoluted and problematic way. Instead of carrying out studies or surveys, the LDA passed amendments to the Master Plan 2021 — in 2013, 2015 and 2016.

The 2013 amendment identified certain areas in the LMA as agricultural, residential and institutional/educational while following the south-west growth corridor for the city identified in the Master Plan. The 2015 amendment, reclassified some 17,000 acres of peri-urban farm land in eastern Lahore for residential purposes. In 2016, the LDA prescribed different land uses for Lahore as well as the secondary cities and areas in Lahore Division. Finally, in June this year, it published a notice inviting EOIs for a study for a 2050 Master Plan for Lahore Division with the scope of work including a profile of the Lahore region and the formulation of a strategic development plan for urban settlements.

Nowhere in all this is there a mention of the RRUDP. Bids submitted for Lahore Division Master Plan 2050 are to be opened on August 4. Only after they are evaluated, finalised and the contracts are signed, will work on the study actually begin. It will take some years.

Seen in this light, the decision of the LDA to request EOIs for updating the RRUDP appears arbitrary in the extreme.

The RRUDP isn’t a new idea. It’s the third iteration of a pipe-dream first conjured up by the PML-Q government in the Punjab trying to capitalise on the property boom of the early 2000s and later modified and somewhat pursued during the PML-N government of 2008-2018.

I first became acquainted with the project in my role as secretary of the River Ravi Commission (RRC), constituted by the Lahore High Court (LHC) in 2013 with the objective to “restore the natural ecology of the Ravi…” In 2014, after the recommendations of the Commission to pilot a bioremediation site along the Ravi to treat wastewater had been approved by the Environment Protection Agency (EPA), Punjab, and received the blessings of the LHC, the government announced it was pursuing the RRUDP.

The Ravi is the smallest and most polluted of the Indus tributaries. Part of the untreated effluent from Sialkot and Faisalabad and all of the untreated effluent of Lahore and Gujranwala drain into it. And since the waters of the Ravi were allocated to India by the Indus Waters Treaty, there is hardly any flow, except during monsoon, that can be used to dilute the pollutants. The liquid poison injected into the river has devastated its ecosystem. The RRUDP documents filed by the LDA during proceedings of the RRC case stated that “attaining environmental sustainability of the Ravi as a major feature in Lahore’s landscape is a key challenge to the project.” The Punjab government engaged the international consulting firm Meinhardt to study the feasibility of the project.

From an environmentalist’s point of view, the RRUDP, updated or otherwise, doesn’t make any sense. Even if the LDA could raise the billions of dollars necessary to undertake the project, the entire effort goes literally to waste when one considers that the Ravi still receives half or all the liquid effluent of Sialkot, Gujranwala and Faisalabad.

Because it required land near Babu Sabu which the RRC and the WASA had indicated was available for the pilot bioremediation plant, the government asked for the work of the RRC to be stopped.

Between 2014 and now no private investor has shown interest in the RRUDP – PPP mode or otherwise. What has changed between 2014 and now that the LDA should seek international consultants to “update” the feasibility study Meinhardt has already been paid handsomely for? How does the LDA propose to raise Rs 5 trillion from the private sector when there isn’t that much clean money lying about in today’s Covid-hit economy?

From an environmentalist’s point of view, the RRUDP, updated or otherwise, doesn’t make any sense. Even if the LDA could raise the billions of dollars necessary to undertake the project, the entire effort goes literally to waste when one considers that the Ravi still receives half or all of the liquid effluent of Sialkot, Gujranwala and Faisalabad. The trillions spent cleaning the Ravi benefit only those who live along its banks. Unless the River Ravi Basin is understood holistically, the RRUDP investment efforts will still result in a polluted ecosystem downstream Lahore.

Investment in the end-of-pipe water treatment envisaged by the RRUDP may improve the quality of effluent discharged into the Ravi at Lahore, but it won’t do anything about the effluent carried in the stormwater drains that snake through the city.

I’ve been a legal advisor to a team of Asian Development Bank (ADB) funded consultants in a recently concluded three-year study on Revitalizing the Ecosystem of the River Ravi Basin (RRB), prepared and submitted to the Government of Punjab in June. The local and international experts who worked on this study proposed an understanding of the RRB by dividing and visioning it in three categories: upstream Lahore, where a vibrant river ecosystem still thrives and should be protected; downstream Lahore, where the river, contaminated by e-coli, arsenic and cadmium, and riverbed brutally mined for sand by the construction industry, are still within the realm of protection and revitalisation; and urban drains and streams, which can be the basis of relatively inexpensive urban regeneration through a mix of innovative bioremediation techniques.

River restorations take time. More time than our political cycle. Combined effluent treatment would still be required at some points, just on account of the sheer volumes and composition of wastewater discharged especially by Lahore and Faisalabad, but this approach definitely looks at the problem of wastewater pollution in the Basin holistically and with an element of accountability for polluters.

Indicative BOD (mg/L) load map for River Ravi Basin (ADB 2020). — Image: Supplied

So why would the LDA, when the government of Punjab was considering a holistic study of the revitalisation of the RRB, seek to go ahead with a costly update of an already costly feasibility study of the RRUDP that does not effectively tackle wastewater pollution in the Basin? It’s not as if the LDA and the government are different entities: the chairman of LDA is the chief minister of Punjab.

From a governance point of view, what’s the need to establish a Ravi Riverfront Authority? The LDA already has responsibility for regional urban planning. If the government doesn’t think the LDA has the capacity to carry out the RRUDP, then who does it have in mind to man the RRA? And why send an ordinance for the governor to sign when the government has numbers in the Punjab Assembly? Why promulgate an ordinance now, only to have it scrutinised by the Assembly, if it is to last beyond 90 days?

In a July 16 meeting chaired by the Planning and Development Board chairman, which I attended, the LDA DG stated that the EOIs for updating the RRUDP had been opened by the LDA on July 14, and that the LDA would hand the procurement and its control on the RRUDP update over to the RRA once it was established. Why not let the RRA undertake it on its own?

There are far too many questions the feasibility update and the establishment of a riverfront authority raise. The people of Lahore deserve to know the answers.

The writer is an  environmental lawyer and tweets @rafay_alam

Marked by folly