ENVIRONMENTAL IMPACT ASSESSMENT IN PAKISTAN - OVERVIEW by krw19413

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									             ENVIRONMENTAL IMPACT ASSESSMENT
                  IN PAKISTAN – OVERVIEW,
             IMPLEMENTATION AND EFFECTIVNESS




                                       Faisal Aslam




                                         June 2006




TR IT A -LWR M A S T E R T H E S I S
ISSN 1 6 51-0 64X
LWR-EX-EX-06-24
Faisal Aslam        TRITA LWR Masters Thesis 0624




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            Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


A C K N O W L E D G E M E N TS
First and Foremost I would like to express my regards to my supervisor, Berit Balfors, Researcher at Div. of Land
and Water Resources, KTH, for her continuous guidance and advice. I am grateful to her for the cooperation and
interest she gave for this work. The quality of this thesis was greatly enhanced by the gracious assistance of her.

I am also very grateful to Mr. Mir Sajjad Hussain Talpur, Researcher and Deputy Director at Pakistan EPA
(Environmental Protection Agency) for his kind support and valuable time.

I would like to thank a number of friends for their friendship and moral support throughout; Uncle Abdus Salam,
Aasu, Hasni, Yasir, Askari, Qasib and my Indian friends. Kasia Karczewska , Saad Riaz and Khalid arif ! I specially
appreciate you guy’s continuous motivation and encouragement for me to write this thesis.

Not least, perhaps, I don’t have words to say how grateful I am to Anusia, for her continuous support and kind
presence in my life and for helping me out to format this thesis. I am thankful to my family whose ever care and
love made me eligible to fulfill this task and to my brother, who has been always a great deal of inspiration in my
life.I feel myself lucky to dedicate this work to my Mother who was the loveliest lady I ever had in my life. All that I
am or ever hope to be, I owe to my angel Mother, who has been an inspiration throughout my life. She had always
supported my dreams and aspirations, and if I do say so myself. May her soul rest in heaven. (Amen)

’’Every mother is like Moses. She does not enter the Promised Land. Yet she prepares a world she will not
see’’. [Pope Paul VI]

                                                                                                                Faeesal




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Faisal Aslam        TRITA LWR Masters Thesis 0624




               iv
                 Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


TABLE           O F C O N TE N T

Acknowledgements.................................................................................................................................................. iii

Table of content ........................................................................................................................................................ v

Abstract ...................................................................................................................................................................... 1

1. INTRODUCTION ............................................................................................................................................... 1

2. THESIS OBJECTIVES........................................................................................................................................ 3

3. LITERATURE REVIEW .................................................................................................................................... 3
     3.1. Brief background and History of the National EIA system............................................................................. 3
     3.2. Legal Acts, regulations, guidelines and other provisions for EIA .................................................................... 3
     3.3. Flow Chart of EIA .......................................................................................................................................... 3
     3.4. Administrative procedures for coordinating EIA within jurisdictions ............................................................. 4
     3.5. The Major Actors in the EIA Process ............................................................................................................. 4

4. METHODOLGY .................................................................................................................................................. 4

5. ENVIRONMENTAL IMPACT ASSESSMENT AND PAKISTAN.............................................................. 4
     5.1. EIA and Development Approvals................................................................................................................... 4
     5.2. Screening ......................................................................................................................................................... 4
     5.3. Steps in the IEE/ EIA Preparation................................................................................................................. 5
         5.3.1.      Executive summary ........................................................................................................................ 5
         5.3.2.      Introduction ................................................................................................................................... 5
         5.3.3.      Description of project .................................................................................................................... 6
         5.3.4.      Description of environment (in area affected by project) ............................................................... 6
         5.3.5.      Screening of potential environmental impacts and mitigation measures......................................... 6
         5.3.6.      Environmental monitoring program and institutional requirement ................................................ 6
     5.4. Scoping............................................................................................................................................................ 6
     5.5. Review of the IEE Report............................................................................................................................... 7

6. DISCUSSION AND CONCLUSIONS .............................................................................................................. 7
     6.1. Major environmental challenges ...................................................................................................................... 8
         6.1.1. Contamination of Environment.............................................................................................................. 9
         6.1.2. Conservation of Biodiversity................................................................................................................... 9
         6.1.3. Safeguarding the productivity of natural resources ................................................................................. 9
     6.2. Level of awareness and understanding ............................................................................................................ 9
     6.3. Quality of EIA Review .................................................................................................................................. 10
     6.4. Public consultation ........................................................................................................................................ 10
     6.5. Jurisdiction of responsibility.......................................................................................................................... 10
     6.6. Implementation Problems and Effectiveness Issues ..................................................................................... 10
         6.6.1. Implementation .................................................................................................................................... 10
         6.6.2. Baseline data ......................................................................................................................................... 10
         6.6.3. Procedures ............................................................................................................................................ 10
         6.6.4. Capacity to implement .......................................................................................................................... 11
         6.6.5. Institutional Mechanisms ...................................................................................................................... 11
         6.6.6. Consultancy Services............................................................................................................................. 11
         6.6.7. Judicial Support..................................................................................................................................... 11
         6.6.8. Financial Resources............................................................................................................................... 11
     6.7. Post Monitoring & Analysis of EIA .............................................................................................................. 11

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Faisal Aslam                                                                                                              TRITA LWR Masters Thesis 0624


7. FINAL CONCLUSIONS................................................................................................................................... 11

8. RECOMMENDATIONS .................................................................................................................................. 11
     8.1. Planned new legal EIA developments ........................................................................................................... 12
     8.2. Development of baseline data ....................................................................................................................... 12
     8.3. Capacity to implement................................................................................................................................... 12
     8.4. Effective Implementation.............................................................................................................................. 12
     8.5. Compliance ................................................................................................................................................... 12
     8.6. Institutional Mechanisms............................................................................................................................... 12
     8.7. Consultancy Services ..................................................................................................................................... 12
     8.8. Human Resource and Capacity...................................................................................................................... 13
     8.9. EIA Training and Capacity Building Programs ............................................................................................. 13
     8.10. Effectiveness of EIA ................................................................................................................................... 13
     8.11. Public Awareness......................................................................................................................................... 13
     8.12. Effective Monitoring and Management ....................................................................................................... 13
     8.13. Environmental Monitoring Committees...................................................................................................... 14
     8.14. Environmental auditing ............................................................................................................................... 14

REFERENCES....................................................................................................................................................... 15

APPENDIXES I-VI................................................................................................................................................ 17
     Appendix I ........................................................................................................................................................... 18
     Appendix II.......................................................................................................................................................... 22
     Appendix III ........................................................................................................................................................ 28
     Appendix IV ........................................................................................................................................................ 30
     Appendix V.......................................................................................................................................................... 32
     Appendix VI ........................................................................................................................................................ 34




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            Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


ABSTRACT
The study reveals that although the system is good to some extent as the powers has been transferred at district
levels but the deficiency of standardized infrastructure is major hurdle to achieve the sustainable goals. This study
evaluates environmental system in Pakistan and environmental impact assessment laws and their effectiveness in
comparison to European Union rules and regulations. The study explains the social and political system in brief to
understand the EIA system at the national level. The methodology adopted, includes through study of different
related documents (NEQS, PEPA, and International Journals etc), personal meetings and interviews. Although the
system in the country is pretty much developed but due to poor implementation and low awareness levels it is not
that much effective. Discussions on different related issues like sustainability, biodiversity, natural resources, baseline
data etc. lead to the recommendations, to make the system more reliable and supportive with minimal changes at
different levels. The Study concludes that although the system is good to some extent, but poor implementation and
non-existence of standardized monitoring system are the major setbacks.

Key words: EIA; NEQS; PEPA; Political System; Effective; Monitoring System.


1. INTRODUCTION                                                  Environmental Protection Agencies (EPA’s) for
                                                                 effective   implementation     of     the    Pakistan
Pakistan is a country of 139 million populations with            Environmental Protection Act 1997. IEE/EIA
per capita income of US $ 460. The manufacturing                 Regulations 2000 has been notified; this is mandatory
sector contributed 18.3% to GDP and 12.5% to GNP                 to both public & private sector projects. Exponents
and showed a growth of 10.2 % in 2004-05. The                    are approaching EPA’s for environmental approvals.
industrial sector consumes 12.5% of the total oil
                                                                 Planning & Development Division/Departments
consumption.
                                                                 (P&D) have been advised to ask for environmental
Current situation                                                approvals issued by respective EPA’s from
The Powers have been delegated to provincial                     proponents.




  Fig.1 Map of Pakistan [9]

                                                            1
Faisal Aslam                                                                     TRITA LWR Masters Thesis 0624.


                                                                                         Fig.2 Environmental
                                                                                         evaluations carried out in
                                                                                         the last five years.
                                                                                         (Pak. EPA 2005)




Ministries & Public sector organizations are repeatedly       capacity being addressed through Activity Based
reminded to seek environmental approvals for their            Capacity Development (ABCD) project under
projects.                                                     National Environmental Action Plan- Support
Public participation tried to be ensured in all EIA           Program (NEAP-SP). An amount of over 50 million
review process. Efforts are under way to enhance the          Euros has been provided for this capacity
capacities of EPA and P&D for effective                       development project [4]. Similarly for institutional
environmental review and follow-up monitoring. Print          strengthening, the restructuring of Federal EPA has
and electronic media is being used for promoting              been approved, that will provide a good human
consciousness among target groups. Pak- EPA with              resource for expansion of EPA for execution of
the active support of provincial EPA is striving to           functions. As far as financial resources are concerned,
ensure sustainable development (Fig. 2).                      the allocation for environment has been doubled in
                                                              the current budget for the year 2005-2006.
Some of the issues, for example, the issue of lack of
                                                              Political System
                                                              Pakistan is divided into four provinces (Punjab, Sindh,
 Table.1 The Districts of Pakistan [11]                       NWFP and Balochistan) and three territories
                                                              (Islamabad, FATA and Azad Kashmir) from year
 Subdivision       Number of Districts                        2001.The introduction of local governments system
                                                              divides the above stated provinces and territories into
 Balochistan                                                  districts (Table 1).
                   27
 Province                                                     Districts are further subdivided into tehsil which may
 North-West                                                   contain villages or municipalities. There are over five
                   24
 Frontier Province                                            thousand local governments in Pakistan. Since 2001,
 Punjab Province 35                                           these have been led by democratically elected local
                                                              councils, each headed by a mayor. Women have been
 Sindh Province    20                                         allotted a minimum of 33% seats in these councils
 Islamabad Capital                                            without any upper limit.District office is responsible
                   1                                          for all kind of planing and management at local level,
 Territory
                                                              for examle Human Resource Management ,Civil
 Federally                                                    Defense Finance & Planning, Works and Services,
                   7 Tribal Agencies plus 6
 Administered                                                 Health,       Education,      Literacy,     Community
                   Frontier Regions
 Tribal Area                                                  Development, Agriculture, Law and Information
                                                              Technology.
 Azad Kashmir          7
                                                              Industrial Growth
 Northern Areas        6                                      The industry imported chemicals worth Rs. 4,600
                                                              million and dyes/colors worth Rs. 5,200 million
                       120 Districts plus          7          during 1997-98 showing an increase of 400 % and 35
 Pakistan
                       Tribal Agencies                        % respectively over the last ten years. About 525 types
                                                              of chemicals are being imported in the country for use
                                                              in different processing industries. The statistics of


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            Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


1997-98 indicates that industry imported 3,000 tons of          Finally, the National Environmental Policy in 2005,
formic acid (a carcinogenic chemical), 2,052 tons               which describes integration of environment into
phenols, and 4,200 tons chromium salt and so on.                development planning through implementation of
There is also an exhaustive list of toxic chemicals,            EIA at project level and promotion of strategic
which are being produced locally by industry in                 environmental assessment (SEA) as a tool for
organized and un-organized sector. All these chemicals          integrating environment into decision-making process.
are entering into our environment every year. Their             Another significant achievement of EPA in the recent
processing generates wastes and pose potential risk to          years was incorporation of environmental concerns in
public health [5]. In such case, we have to differentiate       government policies and initiation of the process of
between NEQS (National Environmental Quality                    environmental impact assessment in the public sector
Standards) violation and environmental crime.                   development schemes. The ECNEC (Executive
                                                                Committee of the National Economic Council) in its
2. THESIS OBJECTIVES                                            meeting chaired by the Foreign Minister on 27th July
                                                                2004 has decided that “in case of development
The overall objective of this study is to understand            projects having environmental implication, an
and evaluate that how the EIA system works in a                 environmental impact assessment (EIA) report should
developing country like Pakistan. The goals were                be submitted along with the project document at the
conceived in the form of following research questions:          time of getting approval”. [4]
•   Is the environmental system in Pakistan advanced            Integrating environmental consideration in the
    enough and in proper compliance with political              planning process has also been initiated. The Planning
    system of the country?                                      and Development Division at the federal level and its
•   What is the nature and scope of environmental               corresponding       provincial   departments      have
    issues at official and public level?                        established Environment Sections or Cells for
                                                                environmental screening of the proposals. Part D has
•   What are the perceptions of the goal setting                also been introduced in the project initiation
    process and the strategies used?                            requirements of Planning Commission (PC-I), which
•   What are the efficiencies and deficiencies in the           deals with EIA. Thus, the development of policy,
    system?                                                     institutional, legal and regulatory frameworks has
                                                                created good environmental governance that can
3. LITERATURE REVIEW                                            sufficiently support the EIA system in the country.
                                                                (EPA, Pakistan 2000)
The international history of EIA dates back to the
National Environmental Policy Act of the United                 3.2. Legal Acts, regulations, guidelines and other
States of America (NEPA) in 1969(Glasson et al.                 provisions for EIA
1999). Following the US initiative, several countries
implemented EIA systems, for example Australia                  Environmental impact assessment of all development
(1974), Thailand (1975), France (1976), Philippines             projects whether public or private is a legal
(1978), Israel (1981) and Pakistan (1983). It shows that        requirement under section 12 of Pakistan
in developing countries, the Asian countries started            Environmental Protection Act of 1997, which became
taking environmental measures very early, with many             operational in year 2000 in addition to, Review of
countries having an EIA system in place by the 1980’s.          environmental impact assessment Regulations
[12]                                                            (Appendix-II). The Regulations also listed the project
                                                                categories, which require an IEE in its Project stage-I
3.1. Brief background and History of the National               and the projects for which an EIA is required are in
EIA system                                                      Project stage-II. For projects not listed in Project
                                                                stage-I and II, IEE or EIA is not required, unless the
Environmental Impact Assessment (EIA) is a rapidly              project is likely to cause an adverse environmental
growing field of work and has become a mandatory                effect and the projects for which EPA has issued
legal requirement in Pakistan. The formalized                   guidelines for construction and operation, an
arrangements for implementation of EIA system in                application for approval accompanied by an
Pakistan evolved over a period of fifteen years. It             undertaking and an affidavit that the aforesaid
started with the promulgation of Pakistan                       guidelines will be followed is required. (EPA, Pakistan
Environmental Protection Ordinance (PEPO) of 1983               1997)
(repealed in 1997).
•   EIA became mandatory for all new projects, since            3.3. Flow Chart of EIA
    1st July 1994                                                In the context of Pakistan, to show how EIA system
•   Documentation of sectoral guidelines as EIA                 works, a Flow chart of EIA methodologies in practice,
    Package is effective from 1997                              is attached. (Appendix-III)
•   Enactment of Pakistan Environmental Protection
    Act, 1997 (Appendix-I) followed by IEE/EIA
    Regulations of 2000

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Faisal Aslam                                                                        TRITA LWR Masters Thesis 0624.


3.4. Administrative procedures for coordinating                  2008) is being implemented by Pak-EPA in
EIA within jurisdictions                                         collaboration with UNICEF Pakistan.
The planning and Development Division at the federal             Asian Development Bank Project (ADB): ADB
level and the Planning and Development Departments               Regional Technical Assistance Project is under way on
at the provincial level are responsible for coordinating         Resettlement Policy and practice.
with respective EPA’s. All military, trans-provincial            UNEP Governing Council: UNEAP-AP initiated a
and trans-country projects are in the jurisdiction of            regional Air Monitoring Program for South Asia
Federal EPA and rest of the projects within provincial           namely “Air Pollution and its Likely Transboundary
jurisdictions. (Appendix-V)                                      Effects for South Asia under the Male´ Declaration.
                                                                 Superior courts
3.5. The Major Actors in the EIA Process
                                                                 And some times the superior courts of Pakistan have
Federal and provincial EPA                                       also played a role in furthering the ends of
Federal EPA office is responsible for all the private            environmental protection by using their constitutional
projects in federal region and in territories. And also          jurisdiction through public interest litigation.
decision making authority at international co-
operation level. While provincial EPA’s are                      4. METHODOL O GY
responsible at provincial level and are under the direct
                                                                 Methodology used in this thesis refers to a simple set
authority of Federal EPA.
                                                                 of methods to rationale this particular study for the
Planning and Development Departments                             analysis of the principles and procedures of inquiry in
This department is responsible for Public Sector                 EIA.By defining research questions ,the problem
projects throughout the country, having their own                space was subdivided into sub spaces to make it
technical expertise. EPA does not have any role in               simple.Personal communications at Pakistan EPA
decision-making process in context of environment.               played an important role to understand the system and
Consultants                                                      problems lying within it. Data collection encompasses
                                                                 several phases, including: oral questionnaires,
Consultancy is not yet regularized and licensed, so              interviewers, stakeholder analysis and in the end
there are a lot of national and multi-national firms in          processing the data. Unofficial interviews and
the competition of EIS preparation in private sector             discussion with different consultants and stakeholders
projects. National directory gives us 38 recognized              (Environmental Protection Agency, Common Public,
consultancy firms in the fields related to the                   Consultants at the university of engineering and
environment.                                                     technology, taxila) lead to achieve the pre-defined
Universities                                                     objectives. Review of different laws and documents
Urban and Regional planning Departments at some                  produced by EPA and their comparison in
major universities are also actively participating in this       international context by review of international papers
field. Students get internships at different levels at           on EIA ,Environmental Management, SEA and
consultancy firms and at Planning and Development                Sustainable development was included in the study..
Departments
Municipalities                                                   5. ENVIRONMENTAL IMPACT
Although delegation of power has been introduced at              ASSESSMENT AND PAKISTAN
municipal levels but regarding environment it is still at
provincial levels.                                               5.1. EIA and Development Approvals
NGO’s                                                            The Executive Committee of National Economic
Number of NGO’s have encouraging role in                         Commission (ECNEC) has decided that in case of
safeguarding the environment in the country. The                 development     projects  having   environmental
First one in this field was Agha Khan Foundation with            implication, an environmental impact assessment
environmental resource centers in year 1993.                     (EIA) report should be submitted along with the
International Cooperation                                        project document at the time of getting approval.
                                                                 (EPA, Pakistan 2005)
JICA Cooperation: Mainly in water and air pollution
problems                                                         5.2. Screening
Canadian International Development Agency (CIDA):
Dealing with institutional linkages                              Pakistan Environmental Protection Agency has
                                                                 notified IEE/EIA Regulations, 2000 in which
The Royal Netherlands Government: funded the PEP-                categorizations of the project are given; whether IEE
Pak-EPA Component. PEP is a multidimensional                     or EIA is required for the proposed project.
initiative aiming to protect and conserve the
environment.                                                     The contents of the IEE/EIA report which are being
                                                                 used in the country are as under:
UNICEF Cooperation: Water Environment Sanitation
Project under country program, Action plan (2004-



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             Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.



                                                                                                                            Fig.3 EIA working layout


       EIA and PAKISTAN
        EIA
        Proposal
         Define Proposal

        SCREENING : initial Environmental Evaluation


        No EIA                                                     EIA
       required                                                 required

       Public, scientific community               SCOOPING Define issues, Make                  Pre-feasibility studies
       & decision makers participate                Major revision to proposal

                                                       PREDICTION & MITIGATION                    Feasibility studies
       Public informed & consulted                     identify impacts, proposed
                                                          mitigation measures

                                                            Prepare draft EIS
        Review of EIS by regulatory                                                         Detailed design & preparation
        Authority and public
                                                            Prepare final EIS

                                                 MANAGEMENT & MONITORING                           Implementation
                                                 Implement EMP plant including
                                                 monitoring Provide feedback for
                                                           future EIAs
                                                                                               Operation &management
                                                       AUDIT Assess EIA process                                   7



                                                                                        SECTORIAL GUIDELINES
5.3. Steps in the IEE/ EIA Preparation
                                                                                        •        Major thermal power stations
At the earliest possible time, developers should
                                                                                        •        Major chemical and manufacturing plants
consult with the Responsible Authority to confirm the
categorization of the project, and to ensure that they                                  •        Municipal waste disposal
are aware of the procedures that apply. Exponents                                       •        New township development
may have already engaged consultants at this time, and
should be aware that the proper specification of the                                    •        Oil and gas exploration and production
consultant’s task will only become clear as the work on                                 •        Major roads
the IEE and other scoping activity is undertaken.                                       •        Water supply projects
Exponents and their consultants should visit the site,
talk with local people about their values and the                                       •        Sewerage schemes
proposals, collect available data, and consult with                                     •        Industrial estates
other Departments and Stakeholders. (Fig. 3)
                                                                                        •        Format of the IEE/EIA as Prescribed in EIA
                                                                                                 Package is called EPA Regulations 2000
EIA PACKAGE                                                                                      (Appendix-II)
The Pakistan Environment Protection Agency in                                           5.3.1.         Executive summary
collaboration with other key stakeholders prepared an
                                                                                        Provide an executive summary where the IEE is more
“EIA Package” Which includes:
                                                                                        than 30 pages long.
General Guidelines & Sectoral Guidelines
                                                                                        5.3.2.         Introduction
                                                                                        This section should include the following:
GENERAL GUIDELINES
                                                                                        •        Purpose of the report, including identification of
•   Policy and procedures for making EIA’s, review                                               the project and the Exponents
    and approval of environmental assessments
                                                                                        •        A brief description of the nature, size, and
•   Guidelines for the preparation and review of                                                 location of the project, and other pertinent
    environmental Reports                                                                        background information.
•   Guidelines for public consultation                                                  •        Extent of the IEE study, scope of the study,
•   Guidelines for sensitive and critical areas                                                  magnitude of effort, persons performing the
•   Pakistan environmental legislation and NEQS                                                  study



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Faisal Aslam                                                                           TRITA LWR Masters Thesis 0624.


5.3.3.   Description of project                                  •   Socioeconomic values
Provision of sufficient details to give a brief but clear        •   Public health
picture of the following (include only applicable
items):                                                          •   Recreational resources and development
•    Type and category of project.                               •   Aesthetic values
•    Objectives of project.                                      •   Archaeological or historic treasures
•    Alternatives considered, and reasons for their              •   Cultural values
     rejection.                                                  5.3.5.   Screening of potential environmental impacts
•    Location (use maps and photographs showing                  and mitigation measures
     general location, specific location, and project site       Using the Sectoral guidelines, which contain a
     layout. Include land uses on the site and                   checklist of environmental parameters for different
     surroundings, details of population centers and             sectors, screen out “no significant impacts” from
     nearby dwellings, road access, topographic and              those with adverse impact by reviewing each relevant
     vegetation features of the site, and other sensitive        parameter according to the following factors.
     land uses such as national parks, wild life reserves        Mitigation measures, where appropriate, should also
     or archaeological sites.)                                   be recommended:
•    Size or magnitude of the operation, including               •   Environmental problems due to project location;
     capital cost, and associated activities.
                                                                 •   Environmental problems related to design;
•    Proposed schedule for implementation.
                                                                 •   Environmental problems associated with the
•    Description of the project, including drawings                  construction stage;
     showing project layout, components of the
                                                                 •   Environmental problems resulting from project
     project, etc. This information should be of the
                                                                     operations;
     same extent as is included in feasibility reports, in
     order to give a clear picture of the project, its           •   Potential environmental enhancement measures;
     context and its operations.                                     and
•    Government approvals and leases required by the             •   Additional considerations.
     project.                                                    5.3.6.    Environmental monitoring program and
5.3.4.   Description of environment (in area affected by         institutional requirement
project)                                                         This section of the report must describe the
In area affected by project, provision of sufficient             management plan and monitoring surveillance
information is needed to give a brief but clear picture          programs, including periodic progress reports to be
of the existing environmental resources including the            established and continued by the proponent following
following:                                                       granting of Environmental Approval. The Responsible
Physical resources: topography, soils, climate,                  Authority must be assured that all necessary
surface water, groundwater, geology /seismology.                 environmental protection measures are carried out in
                                                                 future as planned. The program must be accompanied
Ecological resources: fisheries, aquatic biology,                by the details of the institutional capacity of the
wildlife, forests, rare or endangered species.                   proponent, including staff training and equipment,
Human and economic development: where                            which will be provided to ensure implementation and
necessary, but not limited to:                                   operations.
•    Population     and      communities—numbers,
     locations (summarize information in map form),              5.4. Scoping
     composition, employment                                     While the basis of determining the scope of an IEE or
•    Industries, including known major development               EIA in Pakistan derives from the Sectoral Guidelines
     proposals                                                   provided and the checklists of likely impacts and
                                                                 mitigation measures contained in the Sectoral
•    Infrastructure—including water supply, sewerage,
                                                                 Guidelines. Exponents and reviewers are cautioned
     flood control/drainage, etc.
                                                                 against adopting a mechanistic approach to the
•    Institutions                                                scoping process. No technique can replace the
•    Transportation—roads, rail, harbours, airports,             thoughtful consideration of the proposal, it’s citing,
     navigable rivers                                            and the physical and cultural environment in which it
                                                                 is proposed.
•    Land use planning—including dedicated use areas
                                                                 Scoping is a vital early step, which identifies the issues
•    Power sources and transmission;                             that are likely to be important during the
• Agricultural and mineral development.                          environmental assessment, and eliminates those that
                                                                 are not. In this way, time and money are not wasted
Quality of life values (including, but not limited to):
                                                                 on unnecessary investigations. Scoping is a process of


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             Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


interaction between the interested public, government         (iv) Identify the issues of concern (cross-reference
agencies and the proponent. Scoping refers to the             with checklists in Sectoral Guidelines).
process of identifying, as early as possible:                 (v) Evaluate the concerns from both a technical and
Scoping can be used to:                                       subjective perspective, seeking to assign a priority to
•   Consider reasonable and practical alternatives.           important issues.
                                                              (vi) Amend the outline to incorporate the agreed
•   Inform potentially affected people of the proposal
                                                              suggestions.
    and alternatives.
                                                              (vii) Develop a strategy for addressing and resolving
•   Identify the possible effects on the environment          each key issue, including information requirements
    of the proposal and alternatives.                         and terms of reference for further studies.
•   Understand the values held by individuals and             (viii) Provide feedback on the way the comments have
    groups about the quality of the environment that          been incorporated.
    might be affected by the proposal and the
                                                              (These steps are only indicative, and should be tailored
    alternatives.
                                                              to meet the requirements of the particular situation.)
•   Evaluate the possible environmental effects and           It should be remembered that environmental
    concerns expressed to determine whether, and              assessment is a flexible process. There is no fixed list
    how, to investigate them further.                         of issues to be examined in any particular
•   Define the boundaries of any required further             environmental assessment; instead, careful scoping is
    assessment in time, space and subject matter.             essential to determine the key issues for each particular
•   Determine the analytical methods and                      proposal. When prioritizing issues, consideration
    consultation procedures needed in any further             should be given to their potential sternness, direct,
    assessment.                                               indirect, secondary or cumulative impacts, and
                                                              whether the impacts are continuous or intermittent,
•   Organize, focus and communicate the potential             temporary or permanent, reversible or irreversible.
    impacts and concerns, to assist further analysis
    and decision-making.                                      5.5. Review of the IEE Report
•    Establish the Terms of Reference to be used as           Economic, social and ecological change is inherent to
     the basis of the ongoing assessment.                     development. Whilst development aims to bring about
Issues such as the geographical area are to be                positive change it can lead to conflicts. Environmental
considered, the time frame for impact analysis, the           impact assessment (EIA) in its simplest form is a
methodologies to be used, sources of existing                 planning tool that is now generally regarded as an
information and information gaps should all be                integral component of sound decision-making. As a
addressed. While scoping is seen as a distinct activity       planning tool it has both information gathering and
early in the environmental assessment process, review         decision making component which provides the
of the scope is a continuous activity that proceeds           decision maker with an objective basis for granting or
throughout the detailed environmental studies, the            denying approval for a proposed development project.
decision-making, detailed design, implementation and
monitoring. Unforeseen issues may arise at any of             6. DISCUSSION AND
these stages, and will require further consideration.
                                                              CONCLUSIONS
(i) A typical list of steps for scoping is:
                                                              Introducing EIA culture in a country like Pakistan was
•   Prepare an outline of the scope, with headings
                                                              a hard and challenging task particularly when the
    such as:
                                                              environmental institutions were weak and awareness
•   Objectives and description of the proposal                level was low. It is quite encouraging that now the
•   The context and setting of the proposal                   EIA process has started to begin in the country in an
                                                              organized manner. However there is still a need for
•   Constraints                                               improvement and overcoming the practical
•   Alternatives                                              constraints. There are limited capacities and
                                                              capabilities of many agencies responsible for
•   Issues
                                                              protecting environment in relation to the evaluation of
•   Public involvement (in scope), and                        the    Initial   Environmental       Examination      or
• Timetable                                                   Environmental Impact Assessment. There have been
                                                              almost no training programs for the persons
(ii) Further develop the outline of the scope through         responsible for the evaluation of IEE/EIA reports.
discussion with key stakeholders, assembling available
information, and identifying information gaps.                A commonly held view is that EIA system is much
                                                              less developed in Pakistan than in many other
(iii) Make the outline and supporting information             countries. As a generalization this may be true in terms
available to those whose views are to be obtained.            of its implementation effectiveness but as far as
                                                              implementation mechanisms are concerned, a good

                                                          7
Faisal Aslam                                                                              TRITA LWR Masters Thesis 0624.


                               IEE            EIA          NOC Issued          In Process      Table 2. EPA
   Year        Agency
                          Received          Received       IEE       EIA   IEE          EIA    performance statistics
                                                                                               (Pak. EPA 2005)
           Pak-EPA        01           01              01        01        -        -
           EPA-Punjab     01           -               01        -         -        -
           SEPA           14           03              14        03        -        -
    2000   BEPA           01           01              01        01        -        -
           EPA-NWFP       14           01              14        01        -        -
           SUB
                          31           06              31        06        -        -
           TOTAL
           Pak-EPA        03           -               03        -         -        -
           EPA-Punjab     04           01              04        01        -        -
           SEPA           15           03              15        03        -        -
    2001
           BEPA           06           01              06        01        -        -
           EPA-NWFP       15           01              15        01        -        -
           Sub Total      43           06              43        06        -        -
           Pak-EPA        -            -               -         -         02       -
           EPA-Punjab     07           -               05        -         -        -
           SEPA           12           11              12        10        -        -
    2002
           BEPA           02           -               02        -         -        -
           EPA-NWFP       02           -               02        -         -        -
           Sub Total      23           11              21        10        02       -
           Pak-EPA        -            01              -         01        -        -
           EPA-Punjab     11           04              10        03        01       01
           SEPA           19           07              19        07        -        -
    2003
           BEPA           02           -               02        -         -        -
           EPA-NWFP       02           -               02        -         -        -
           Sub Total      34           12              33        11        01       01
           Pak-EPA        01           02              01        01        -        01
           EPA-Punjab     14           15              11        10        03       05
           SEPA           27           06              27        02        -        04
    2004
           BEPA           10           01              09        -         -        -
           EPA-NWFP       06           05              -         -         -        -
           Sub Total      58           29              48        13        03       10
   GRAND TOTAL            189          64              176       46        06       11


legal and regulatory framework has been developed                the correct steps of the project cycle and hence the
along with institutional setting for implementation of           progressive findings of the IEE/EIA study are not
EIA system at federal and provincial levels. The                 considered while decision-making process is initiated by
system is at an early stage and the data of last five            the CDWP.
years, indicates an increase in the number of EIA
reports submitted to EPA from 6 in year 2000 to 29 in            6.1. Major environmental challenges
year 2004 and IEE from 31 in year 2000 to 189 in year
2004. (Table 2)                                                  The key challenges of EIA process management and
                                                                 practice are to make the system more effective, more
Provincial Development Working parties (PDWP) and                practical especially in dealing with strategic
Central Development Working Party (CDWP) are the                 environmental assessment, more efficient and
forums for approving public projects. Environmental              transparent, and more accountable. (United Nations
assessment process is not presently fully integrated with        University, 2004)


                                                             8
            Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


With respect to natural environment, there are also             technologies, and by appropriate funding’’. (Glasson, J
many challenges, which are encountered during                   1999)
assessment of environmental impacts of activities of            Projects of oil and gas exploration, construction of
proposed projects in various sectors. Some of them              power generating plants (hydro, thermal and nuclear)
are project specific and some are general. The major            are increasing to meet the energy and power demand
challenges are three:                                           of other sectors. Activities of such projects often
•   Protecting human and environmental health from              result in a change in the surrounding environment that
    contamination of environment                                may directly or indirectly affect the ecology. Plant and
                                                                animal communities may be directly affected by
•   Conservation of biodiversity,
                                                                changes in their environment through variations in
• Safeguarding the productivity of natural resources            water, air and soil/sediment quality; disturbance by
All three are briefly discussed below.                          noise, extraneous light and changes in vegetation
                                                                cover. Such changes may directly affect the ecology:
6.1.1. Contamination of Environment                             for example, habitat, food and nutrient supplies,
The human and environmental health is always at risk            breeding areas and migration routes. If not properly
of contamination from chemicals (solid, liquid and              controlled, a potential long-term effect is loss of
gas) present or generated in the air, water (surface and        habitat, which affects both fauna and flora, and may
ground) and land (soil). The industrial growth requires         induce changes in species composition leading to
lot of chemicals for use and in turn generates many             change in ecology. This is a great challenge for the
chemicals in the environment. This refers to the                developers and their environmental managers as loss
release of chemicals (trace amounts of toxic or                 of biodiversity is also natural resource depletion. The
biologically reactive substances) from operations and           deforestation or removing vegetation cover for
the subsequent contamination of the surrounding                 clearing land for development also contributes to loss
environment in any or their entire forms, liquid, solid         of biodiversity due to loss of habitat.
and gas. The chemical contamination causes land
degradation and water quality deterioration in one way          6.1.3. Safeguarding the productivity of natural resources
or the other, spillage, leakage or leaching or emitting,        The natural resource base is the primary source of raw
etc. (Coleen T, 2006)                                           material needed for all kinds of physical development
                                                                necessary for economic growth in terms of provision
A recent survey of 150 industrial units in five
                                                                of goods and services. Therefore, safeguarding the
potentially toxic groups completed by EPA in the
                                                                natural resource base is of utmost importance.
three provinces, reported extreme deviation from the
levels prescribed in the National Environmental                  This is another challenge for EIA system to integrate
Quality Standards. Another survey carried out by                the means and ways of safeguarding the productivity
Federal Environmental Protection Agency showed                  of natural resources in the development projects both
that tanneries located in Kasur and Sialkot are                 in public and private sectors.
discharging effluent with chrome concentration
ranging between 182-222 mg/lit against standards of 1           6.2. Level of awareness and understanding
mg/lit and Chemical Oxygen Demand (COD) ranging                 Most government departments are not aware of the
between 5002-7320 mg/lit. A chromium salt                       legal requirement that development projects need to
producing unit near Rawalpindi is reportedly                    go through an IEE or EIA process. The result is that
discharging chromium rich effluent in a water stream            government departments, such as development
causing severe implications for residents of the                authorities support the projects without checking for
adjacent areas [4].                                             compliance with the EIA regulations. Particularly
Therefore, protecting human and environmental                   projects approved at Departmental Development
health from the impacts of chemical contamination is            Working Party (DDWP) level within the budgetary
one of the major challenges of EIA.                             limit of 0.5 million Euro, which are not submitted to
6.1.2. Conservation of Biodiversity                             Planning and Development Divisions (P &Ds).
                                                                Normally, a representative from that particular section
The Conservation of biodiversity is a particular                of P&D which is related to that department attends
confront of EIA because the country is in a process of          the meeting of DDWP who is not or least concerned
rapid industrial growth, which is demanding a                   about the environmental impacts of the projects.
corresponding growth in the energy sector. It states as:
                                                                It is not always that project with big budgetary
                                                                expenditures have environmental impacts, sometimes
’’The objectives of the Convention of biodiversity are          a small grant project has more environmental impact.
to be pursued in accordance with its relevant                   There is a general view held at the P&D’s that EIA is
provisions, the sustainable use of its components and           anti-development and internalization of the cost of
the fair and equitable sharing of the benefits arising          environmental protection in the project cost makes it a
out of the utilization of genetic resources, including by       hindrance in achieving the targets of economic growth
appropriate access to genetic resources and by                  set by the state as the attention is more focused on
appropriate transfer of relevant technologies, taking           economic growth than the economic development.
into account all rights over those resources and to

                                                            9
Faisal Aslam                                                                          TRITA LWR Masters Thesis 0624.


Although, provincial P&D departments have                      The delegated powers can be rescinded, although in
environment sections but these are not very effective          practice this has not happened, as PEPA has to be
as far as environmental screening of the projects is           implemented through Provincial Governments. Under
concerned as they lack capacity to do so. Pak-EPA in           section 27(a), Federal Government can give directions
association with NEAP-Support Program by UNDP                  to federal and provincial agencies.
organized a workshop on EIA in December 2004 in
which representatives from various public sector               6.6. Implementation Problems and Effectiveness
organizations were invited for orientation on issues           Issues
related to EIA.
                                                               A review of EIA systems and current practices in
                                                               Pakistan carried out for this study identified the
6.3. Quality of EIA Review
                                                               following major problematic issues.
The quality of the EIA reports submitted to EPA’s by
the project developers varies considerably [6]. Reports
                                                               6.6.1. Implementation
for large projects being developed by multinational            EPA ability to carry out their functions, particularly
organizations and donor agencies are generally                 effective monitoring and enforcement, is constrained
thorough, but those for smaller projects tend to be            by problems in retaining and effective use of
vague.      Although many EIA reports mention                  professional skills and expertise. Weaknesses in
alternatives, including the no-project option, this            environmental data collection, analysis, and disclosure
appears to be a mere formality.                                are important constraints on informed policymaking
                                                               and the engagement of the public in policy dialogue.
There is no formal system of EIA review panels
comprising experts from various fields as EPA’s do              There is no legal mandate to EPA for coordinating in
not have financial resources to support that system by         land use planning in the context of EIA. Public sector
paying honoraria or fee to the reviewers and to spend          compliance with the EIA system is one of the major
on cost of communication.                                      problems throughout the country. The private sector’s
                                                               compliance with the EIA system varies from industry
6.4. Public consultation                                       to industry. With the exception of some multinational
                                                               companies in oil and gas sector, there is generally little
One of the major drawbacks in the EIA package is               environmental awareness in most industries, and there
that it does not have guidelines for public                    is no system in place that would prevent projects from
consultations. Public consultation during the                  being implemented without EPA approval.
preparation of EIA is almost non-prevalent. Although
reports generally say that stakeholders have been              6.6.2. Baseline data
consulted, in most cases this consultation does not            The environmental impact of any activity or process is
happen.                                                        assessed on the basis of a deviation from the baseline
Environmental assessments of some of the high                  or normal situation. Therefore, the reliable baseline
                                                               data on ecological and socio-economic environment is
profile projects conducted by well-established firms do
include a public hearing component after submitting            a prerequisite for conducting an EIA.
EIA reports to EPA and get its confirmation of                  In Pakistan, either the baseline data are not available
completeness within 10 days as provided by clause (a)          or patchy and fragmented and in most cases
of sub-regulation (1) of regulation 9 of EIA                   unreliable. This is one of the major factors responsible
regulations 2000. The EPA, simultaneously with issue           for poor quality of EIA studies being conducted in the
of confirmation of completeness can publish a public           country. The collection of primary data is time
hearing notice under Regulation 10(1) of IEE/EIA               consuming and needs resources, therefore, the most of
Regulations, 2000. [Appendix-II]                               the consultants rely on the data, whatever or wherever
                                                               it is available or alternatively on data from a similar
6.5. Jurisdiction of responsibility                            habitat elsewhere. The process of conducting EIA can
                                                               become more efficient and low cost if a countrywide
Under the existing legislative framework, the federal          reliable environmental database is available.
EPA has jurisdiction over all EIA/IEE [Appendix-V].
However the federal has delegated the powers of Pak-           6.6.3. Procedures
EPA under section 26(1) of PEPA, 1997 to Provincial            The effectiveness of EIA system is seen to depend
Governments except for the projects on federal land,           upon their successful integration within the project
military projects, inter-provincial and international          cycle from an early stage. The detailed form of its
projects. For public works, responsibility for IEE             integration varies according to the procedural
management and review and granting or refusing                 characteristics of the project cycle. The prescribed
environmental approval all the projects listed in              procedures for filing and review of EIA’s are not
Schedule-I of IEE/EIA Regulations of 2000 is vested            followed which resulted in delays and the process is
in the P&D Division and its corresponding provincial           considered as anti development. Guidelines for the
departments. The IEE and EIA for all private                   preparation and review of environmental reports are a
projects, the respective EPA’s are responsible for             longer and more descriptive document, which covers:
environmental approvals (Pak-EPA, 1997).                       (i) The initial environment report



                                                          10
            Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


(ii) Assessing impacts                                           6.7. Post Monitoring & Analysis of EIA
(iii) Mitigation & impact management                             Environmental assessment monitoring is the planned,
(iv) Reporting                                                   systematic collection of environmental data to meet
(v) Review and decision making                                   specific objectives. Monitoring can be used to ensure
                                                                 that the benefits anticipated as a result of the
(vi) Monitoring and Auditing
                                                                 Environmental Report are effectively achieved as the
(vii) Project Management                                         project proceeds. Monitoring can be particularly
6.6.4. Capacity to implement                                     important when the decision to proceed with a
                                                                 proposal is controversial—where overall the project is
A panel of experts for EIA review is needed, along
                                                                 seen to provide net community benefit, despite
with a system for compensating them. In addition,
                                                                 considerable uncertainty concerning the scale and
EPA’s are deficient in trained human resources,
                                                                 significance of one or more adverse impacts. The local
equipment and physical resources to support
                                                                 community may be concerned about the potential
monitoring of projects in the implementation and
                                                                 impact of a project on an important resource (e.g. a
operation stage. Capacity to address resettlement and
                                                                 fishery) even if the environmental study indicates that
social issues is particularly limited.
                                                                 no significant impacts are likely. In such situations
6.6.5. Institutional Mechanisms                                  agreement to implement and fund a monitoring
About ten years ago, the Environment Section of the              program can be important in reducing community
P&D Division at Planning Commission with the                     fears and hostility towards the project. At the same
assistance of a Canada International Donor Agency                time, the monitoring data will function as an “early
(CIDA), Canadian consultant had developed a                      warning system” indicating if an impact is occurring,
screening checklist for in-house scrutiny of the                 and allowing remedial action to be taken before the
projects. This checklist was supposed to be attached to          impact has reached unacceptable levels.
all PC-I documents received at the Planning
Commission before presenting to the decision makers.             7. FINAL CONCLUSIONS
The checklist could not be used effectively due to its
complex nature and now it is being redesigned.                   Increasing population and improper management of
                                                                 natural resources has been always a greater threat to
Currently the P&D send each and every project to                 Pakistan’s environment. Like all other developing
Pak-EPA for screening. Pak EPA has received 700 PC               countries Pakistan always strived hard for economic
I documents in the current financial year till March             growth, controlling population growth and fulfill the
2006[6]. Another important issue is that, particularly           ever-increasing energy demands rather than having
for smaller projects in the public sector, project               concerns about the output of such processes in the
developers do not have sufficient funds to carry out an          form of environmental hazards. As a result, "green"
EIA until the project PC-I is approved. When the PC-             concerns have never been up on the agenda.
I is approved and funds are released, it is generally too
late to conduct an EIA; construction generally starts
immediately, ignoring the EIA process.                           Due to more focus on economic growth and lowering
                                                                 the poverty rate with limited resources, the country’s
6.6.6. Consultancy Services                                      environmental record is quite poor. Although Pakistan
The standard of the consultancy services is also a               was among one of the first countries to introduce
major factor in poor quality of EIA. Some times the              environmental laws in 80’s but yet not been able to
EIA reports are very good but the information is not             back up its commitment to environmental protection.
based on complete facts. The consultants only collect            There are some serious steps taken at the government
information necessary to fill the prescribed format of           and industrial levels to meet the requirements of the
an IEE or EIA. They are also aware of the fact that              ever-changing needs of the environment in local and
the information provided would hardly affect the                 global context. But it is clear that the government
decision-makers. In general the consultancy is not               needs to take a step forward and give greater emphasis
based on fair principles.                                        towards country’s environmental issues.
6.6.7. Judicial Support
The judicial support for implementation is insufficient.         8. RECOMMENDATIONS
So far most of the actions taken are in the domain of            Despite all these measures for environmental
public interest litigation instead of PEPA, 1997.                screening of the development projects, the EIA
6.6.8. Financial Resources                                       system is still not very effective in Pakistan,
                                                                 particularly in the public sector development projects.
There is need to improve the financial resources for
                                                                 Not only in terms of its implementation but also in
supporting effective EIA review process. The fee
                                                                 terms of its review and appraisal of issues while
received with the EIA reports is deposited in the
                                                                 making decisions, and its evaluation through post-
federal or provincial treasury and provide to EPA to
                                                                 decision monitoring by the government. The reason is
meet the expenses on review of EIA reports.
                                                                 that all public sector projects, which need an EIA, are
                                                                 submitted       to     Planning     &     Development

                                                            11
Faisal Aslam                                                                        TRITA LWR Masters Thesis 0624.


Departments/Division, which lack a system for review             •   Economic and social appraisal of EIA
and the capacity to perform environmental screening
                                                                 •    Evaluation in terms of environmental costs and
while private sector projects are submitted for
                                                                      long-term social benefits
environmental clearance or NOC to EPA.
                                                                 Implementing agencies should be allowed to utilize the
The followings are the recommendations, which have
                                                                 funds (on the environmental improvement) generated
been drawn after the through study of EIA system in
                                                                 at the local level on account of violating
Pakistan in comparison of EU guidelines, keeping the
                                                                 environmental regulations. EPA should have the
geographical needs in mind. Issues identified at
                                                                 necessary powers to disburse the fee received from
stakeholders consultation meetings in the four
                                                                 IEE/EIA reports to be spent on the review process.
provinces by the Working Group on EIA in the
National Stakeholders Conference at Islamabad used
as facts. [Appendix-VI]                                          8.4. Effective Implementation
                                                                 •   Develop mechanisms for effective enforcement
8.1. Planned new legal EIA developments                              and necessary infrastructure
Sectoral guidelines are in process of development for            •   Involve      Local    Governments       in    the
small and medium size projects by provincial EPA’s.                  implementation at the (District, kommun) TMA
These guidelines are of dairy form, poultry form,                    level under the devolved governance structure
Petrol Pump & CNG Stations developed for the                     •   Strengthen public hearing systems through
guidance of the proponent regarding the preparation                  promotion of volunteerism like environmental
of Environmental Assessment report. But this project                 clubs or groups comprising of experienced people
is still in progress without any impressive                          from different sectors.
achievements .It should be finished soon to be
available for implementation.                                    •   Capacity building of various important sectors of
                                                                     the society for their effective and objective
8.2. Development of baseline data                                    involvement in the EIA process to play a positive
                                                                     role by the:
Development of reliable and systematically obtained
                                                                          Media persons through training
databases of ecological and socio-economic
environment with the coordination of universities,                        NGOs through training and networking
departments of related disciplines, conducting                            Academia       through   dissemination    of
postgraduate level research could be of great help. A                     interdisciplinary knowledge on EIA in the
program should be initiated with research and                             broader context of sustainable development
development organizations in related sectors to                           and poverty alleviation
establish a system of district-wise database at the              •   Development of judicial activism for environment
federal EPA. Development of modern GIS/GPS tools                     as public interest litigation
in accordance with the local conditions for improving
the efficiency and effectiveness of EIA process should
                                                                 8.5. Compliance
be done.
Linkage of the district-wise database at federal EPA to          Implement monitoring and evaluation by the
the respective provincial EPA’s and its availability at          provincial EPA at local government or TMA level
the District Environment Offices is necessary (until             under the existing devolved system.
the IT infrastructure develops in the country at district
level, then it may also be linked). This would help              8.6. Institutional Mechanisms
EPA in reviewing and evaluating the EIA reports, thus
                                                                 •   A clear mechanism of coordination between P&D
the process of decision-making will become efficient.
                                                                     and EPA for environmental screening of public
One of the developer’s concerns that EIA delays the
                                                                     sector projects at P&D and environmental need
development process can be addressed.
                                                                     to be developed.
8.3. Capacity to implement                                       •   Skilled professional staff in a variety        of
                                                                     organizations those are familiar with EIA’s.
Institutional capacity building of EPA for monitoring
should be undertaken in terms of:                                8.7. Consultancy Services
•   Provision of necessary monitoring equipment
                                                                 Improvement of consultancy services through a
•   Provision of trained manpower for carrying out               process of:
    monitoring
                                                                 •   Accreditation of consultants on the basis of a
•    Provision of logistics and transport for                        transparent criteria
     monitoring
                                                                 •   Annually renewable registration with the Ministry
Strengthen and develop the individual capability of the              of Environment
P&D Department, EPA and R&D staff in terms of:
•   Review of EIA reports


                                                            12
           Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


•   Quality assurance of services through             a         issues in a cost-effective manner. Consequently,
    recognized quality assurance system                         integration between environmental assessment and
                                                                feasibility studies is essential. The environmental
8.8. Human Resource and Capacity                                assessment team should be provided for frequent
                                                                coordination meetings with the feasibility study team
The human resource with capacity to review the                  to exchange information.
reports and assess the quality of EIA is lacking,
especially the deputed staff lack insight necessary to
analyze environmental issues in the broader context of          Screening section should include an evaluation of the
sustainable development.                                        screening process and should highlight whether
                                                                significant environmental impacts exist which need
The process of EIA review is not fully streamlined and
                                                                further detailed study or an EIA.
lacks checks and balances. Due to lack of resources,
experts rarely review EIA, even if they deal with issues
that are not well understood by EPA personnel.                  8.11. Public Awareness
Although EPA occasionally distributes EIA reports               In any decision making process in a society, common
for comments, this is done quite randomly, and                  public plays most vital role to achieve sustainability
comments are rarely received. A panel of experts for            goals.
EIA review is needed, along with a system for                   For raising the level of awareness and understanding,
compensating them.                                              the initiative of the Government of NWFP has taken
In addition, EPA is deficient in trained human                  lead in the country by establishing an EIA Center. For
resources, equipment and physical resources to                  raising the level of awareness and understanding, such
support monitoring of projects in the implementation            EIA centers can build up the capacity for the public
and operation stage. Capacity to address resettlement           and private sector organizations in the preparation of
and social issues is particularly limited. Monitoring           EIA studies for development projects, and in turn
only takes place at the request and cost of project             enhance the capacity of EPA. There is a need that
proponents, which makes it vague.                               other provincial governments also follow this example
                                                                and establish such program.
8.9. EIA      Training    and    Capacity     Building
Programs                                                        8.12. Effective Monitoring and Management
For raising the level of awareness and understanding,           Monitoring is expensive for a developing country like
the federal and provincials Environmental Protection            Pakistan. It needs to be aimed at the level required to
Agencies organizes trainings time to time. The                  successfully manage the project and review the
Government of NWFP has established an EIA Center                adequacy of the environmental assessment without
at Pakistan Academy of Rural Development, Peshawar              wasting money by unnecessarily monitoring impacts.
in collaboration with EPA-NWFP and some                         Monitoring should be focused on the impacts that are
prominent NGOs also organize training programs on               either significant, or where there is uncertainty.
EIA [6]. The process started as a public sector project         Monitoring is not necessarily required for all impacts.
of three years in year 2002 with funding from Annual            The collection of information needs to be optimized
Development Plan (ADP) of NWFP Government. In                   so that enough is collected to be useful, but not so
the first years funds could not be released but in              much that it is wasted. Careful thought must be given
second year 10 Master Trainers were trained by a                to the design of a monitoring program, as to how the
capacity building NGO (LEAD-Pakistan) through a                 results will be used in practice, and for how long the
one-month program of training. Based on                         monitoring needs to be continued.
performance the project has been extended for                   Monitoring should be linked to impact prediction so
another three years, up to 2008 for conducting                  that there is information on the nature, magnitude,
trainings on sector-based EIA [6]. But this should be           geographical extent, time scale, probability, and
done more often and in planed regular ways.                     significance of the impact. Monitoring programs need
                                                                to be constantly reviewed to make sure that they are
8.10. Effectiveness of EIA                                      effective, and to identify the time when they can be
                                                                stopped. While monitoring activities frequently require
The degree of effort expended in these and
                                                                sophisticated equipment, the value of simple
subsequent steps in EIA needs to be matched to the
                                                                observation should not be under-estimated. For this
likely impacts of the proposal, the scale of the
                                                                reason, amongst others, the involvement of local
development, the sensitivity of the site, and the level
                                                                communities can be most effective.
of concerns held by the community. Environmental
assessment is most effective when even preliminary
findings are made available early in the preparation            Effective monitoring programs include:
process. At that time, alternatives that might be               Monitoring programs should provide time series data
desirable from an environmental viewpoint can be                that can be analyzed from time series graphs, which
considered and implementation and operating plans               will show statistical significance of variations, and rates
can be designed to respond to critical environmental            and directions of change.

                                                           13
Faisal Aslam                                                                        TRITA LWR Masters Thesis 0624.


Monitoring programs need to be detailed and funds               complete project implementation. Feedback from this
allocated for the purpose and accounted for in the              type of audit can be used to improve the effectiveness
overall costing of the project. They can generally be           and efficiency of other Environmental Reports in the
offset against the benefits which monitoring brings.            future.
There are always immediate cost savings in identifying          An environmental assessment audit should be planned
and rectifying unacceptable environmental impacts at            to be specific to the site, although it can offer
an early stage in the project.                                  information, which is general to the environmental
                                                                assessment process as a whole. It can include the
8.13. Environmental Monitoring Committees                       completion of checklists and questionnaires, as well as
The Responsible Authority may, at their discretion, set         using rating systems. The table of contents of an
up an Environmental Monitoring Committee for any                Environmental Management Plan can be used as a
approved project to assist and guide the proponent in           checklist for an audit.
the management of the monitoring program. Such                  Auditing can also result in:
action shall be taken where the Responsible Authority           •   An improved image           for   the   project   as
considers that the scale of likely impacts, or the level            environmentally sound;
of public concern, warrant such action. The
Monitoring Committee shall consist of representatives           •   Reduction in public opposition to operations; and
of the Responsible Authority (who will chair the                •    Avoidance of penalties, which could result from
committee), the Proponent (and his Consultants as                    non-compliance with environmental controls.
required), key Government Agencies, relevant                    Findings of the audit and other less formal reviews
Municipal Authorities and representatives of NGO’s              need to be fed back into the monitoring plan and the
and the local community.                                        management systems. In this way strengths will be
                                                                highlighted, weaknesses acknowledged and remedied,
Such an Environmental Monitoring Committee can                  and gaps in information for effective reporting
typically could be effective if;                                defined. Both the Environmental Management Plan
                                                                and the monitoring program may need to be amended.
•   The committee meets periodically to advise the
    proponent whether the monitoring actions being              In the end I would like to say that it’s a long road to
    undertaken meet the requirements of the                     go, as Pakistan EPA is still in development stage.
    Environmental Approval and the Operating                    Sustainable environmental goals could be achieved
    Approval, and as further detailed in the                    with the sincere devotion and attention by the
    Environmental Management Plan;                              government as well as by the society. Further research
                                                                could be done in this field but it would worth only if it
•   The committee can advise on any further public              is taken into consideration and implemented in a
    consultation which it thinks is desirable;                  precise way.
•   The committee can consider any significant
    environmental impacts not foreseen in the
    Environmental Report, and can advise the
    proponent of suitable mitigating measures;
•   The committee would consider drafts of the
    Annual Report on the project prepared by the
    proponent;
•   The committee should advise the Director
    General, of any matters that they believe should
    be drawn to his attention.

8.14. Environmental auditing
Environmental auditing is a review process similar to
that carried out in financial auditing and can be done
on a regular or ad-hoc basis. It usually takes the form
of an independent ‘one off’ examination and
assessment of past performance, such as for the audit
of a contaminated site. One special type of
environmental audit is the environmental assessment
audit, which can provide an evaluation of the
conditions of approval along with an assessment of
the effectiveness of a particular Environmental Report
at predicting impacts, both their type and
characteristics. A formal environmental assessment
audit can therefore only be commenced after partial or


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           Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.



REFERENCES
Coleen,T., Hilderbrand,L.P., Rousseau,F.R., (2006) “Community-Based Environmental Management in Atlantic
           Canada: The Impacts and Spheres of Influence of the Atlantic Coastal Action Program”. Journal of
           Environmental Monitoring and Assessment. Vol. 113,442:pp367-383.
EPA, Pakistan., (1997) “Pakistan Environmental Protection Act, 1997”. Government of Pakistan, Ministry of
           Environment. 25p.
EPA, Pakistan., (2000) “ Pakistan Environmental Protection Agency (review of IEE and EIA) Regulation”.
           Government of Pakistan, Ministry of Environment. 18p.
EPA, Pakistan., (2005) “National Environmental Policy 2005”. Government of Pakistan , Ministry of Environment.
           16p.
EPA, Pakistan., (2005)“State of Environment Report”. Government of Pakistan, Ministry of Environment. 155p.
Glasson, J., Thérivel, R., Chadwich, A., (1999). Introduction to Environmental Impact Assessment: Principles and
            Procedures, Process, Practice and Prospects. UCL Press, London.
Maal-Bared,R., (2006) “Comparing environmental issues in Cuba before and after the Special Period: Balancing
           sustainable development and survival”. Journal of Environmental International. Vol. 32,704:pp349-358.
Ng Leng, K., Obbard, J.P., (2005) “SEA in Hong Kong”. Journal of Environmental International. Vol. 31,
           1212:pp483-492.
United Nations University.,(2004) “Cities as Drivers of Sustainable Development’’.World Urban Forum 2004
           Networking Event. 7p.
Other references:
[1] EIA Course (KTH) Home Page
 http://www.lwr.kth.se/grundutbildning/1B1634
[2] International Association for Impact Assessment Web Site
 http://www.iaia.org
[3] Ministry of Environment, Pakistan Web Site
 http://www.pakistan.gov.pk/ministries
[4] Pakistan Environmental Protection Agency Web Page
http://www.environment.gov.pk/
[5] Statistics Division, Government of Pakistan Web Site
http://www.statpak.gov.pk/
[6] Sajjad, H: Pakistan Environmental Protection Agency,
 Islamabad (Pakistan) Personal communication February 2006
 Stockholm (Sweden) Personal communication April 2006.
[7] The United Nations Industrial Development Organization (UNIDO) Web-Site
 http://www.un.org.pk/unido/about.htm
[8] United Nations University Web Site
 http://www.ias.unu.edu/binaries2/WUF_2004_Discussion_Paper.doc
[9] University of Texas Libraries Web Site
 http://www.lib.utexas.edu/maps/pakistan.html
[10] EUROPA:EU guidelines for EIA
 http://ec.europa.eu/environment/eia/eia-support.htm
[11] Wikipedia:Pakistan
http://en.wikipedia.org/wiki/Districts_of_Pakistan#column-one
[12] EIA History
www.env.go.jp/earth/coop/ coop/materials/10-eiae/10-eiae-2.pdf
[13] Convention on Biodiversity
http://www.biodiv.org/convention/arti




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Faisal Aslam        TRITA LWR Masters Thesis 0624.




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     Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.



APPENDIXES I-VI




                                                17
Faisal Aslam                                                     TRITA LWR Masters Thesis 0624.




Appendix I

Pakistan Environmental Protection Policy, 2005(Pak. EPA 2005)*




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Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           19
Faisal Aslam                                                            TRITA LWR Masters Thesis 0624.




*For detailed description the document is available at http://www.environment.gov.pk




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Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           21
Faisal Aslam                                                                      TRITA LWR Masters Thesis 0624.



Appendix II

Pakistan Environmental Protection Agency Regulations, 2000 (Pak. EPA 2000)*

PAKISTAN ENVIRONMENTAL PROTECTION AGENCY (REVIEW OF IEE
AND EIA) REGULATIONS, 2000
S.R.O. 339 (1)/2001. - In exercise of the powers referred by section 33 of the Pakistan Environmental Protection
Act, 1997 (XXXIV of 1997), Pakistan Environmental Protection Agency, with the approval of the Federal
Government is pleased to make the Following Rules, namely: -

1. Short title and commencement
(1) These regulations may be called the Pakistan Environmental Protection Agency Review of Initial Environmental
Examination and Environmental Impact Assessment Regulations, 2000.
(2) They shall come into force at once.

2. Definitions
(1) In these regulations, unless there is anything repugnant in the subject or context –
(a) “Act” means the Pakistan Environmental Protection Act, 1997 (XXXIV of 1997);
(b) “Director-General” means the Director-General of the Federal Agency;
(c) “EIA” means an environmental impact assessment as defined in section 2(xi);
(d) “IEE” means an initial environmental examination as defined insection 2(xxiv); and
(e) “section” means a section of the Act.
(2) All other words and expressions used in these regulations but not defined shall have the same meanings as are
assigned to them in the Act.

3. Projects requiring an IEE
A proponent of a project falling in any category listed in Schedule I shall file an IEE with the Federal Agency, and
the provisions of section 12 shall apply to such project.

4. Projects requiring an EIA
A proponent of a project falling in any category listed in Schedule II shall file an EIA with the Federal Agency, and
the provisions of section 12 shall apply to such project.

5. Projects not requiring an IEE or EIA
(1) A proponent of a project not falling in any category listed in Schedules I and II shall not be required to file an
IEE or EIA: Provided that the proponent shall file –
(a) an EIA, if the project is likely to cause an adverse environmental effect;
(b) for projects not listed in Schedules I and II in respect of which the Federal Agency has issued guidelines for
construction and operation, an application for approval accompanied by an undertaking and an affidavit that the
aforesaid guidelines shall be fully complied with.
(2) Notwithstanding anything contained in sub-regulation (1), the Federal Agency may direct the proponent of a
project, whether or not listed in Schedule I or II, to file an IEE or EIA, for reasons to be recorded in such
direction: Provided that no such direction shall be issued without the recommendation in writing of the
Environmental Assessment Advisory Committee constituted under Regulation 23.
(3) The provisions of section 12 shall apply to a project in respect of which an IEE or EIA is filed under sub-
regulation (1) or (2).

6. Preparation of IEE and EIA
(1) The Federal Agency may issue guidelines for preparation of an IEE or an EIA, including guidelines of general
applicability, and sectoral guidelines indicating specific assessment requirements for planning, construction and
operation of projects relating to particular sector.




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           Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


(2) Where guidelines have been issued under sub-regulation (1), an IEE or EIA shall be prepared, to the extent
practicable, in accordance therewith and the proponent shall justify in the IEE or EIA any departure there from.

7. Review Fees
The proponent shall pay, at the time of submission of an IEE or EIA, a nonrefundableReview Fee to the Federal
Agency, as per rates shown in Schedule III.

8. Filing of IEE and EIA
(1) Ten paper copies and two electronic copies of an IEE or EIA shall be filed with the Federal Agency.
PAKISTAN ENVIRONMENTAL PROTECTION AGENCY (REVIEW OF IEE AND EIA) REGULATIONS,
2000 33
(2) Every IEE and EIA shall be accompanied by –
(a) an application, in the form prescribed in Schedule IV; and
(b) copy of receipt showing payment of the Review Fee.

9. Preliminary scrutiny
(1) Within 10 working days of filing of the IEE or EIA, the Federal Agency shall –
(a) confirm that the IEE or EIA is complete for purposes of initiation of the review process; or
(b) require the proponent to submit such additional information as may be specified; or
(c) return the IEE or EIA to the proponent for revision, clearly listing the points requiring further study and
discussion.
(2) Nothing in sub-regulation (1) shall prohibit the Federal Agency from requiring the proponent to submit
additional information at any stage during the review process.

10. Public participation
(1) In the case of an EIA, the Federal Agency shall, simultaneously with issue of confirmation of completeness under
clause (a) of sub-regulation (1) of Regulation 9, cause to be published in any English or Urdu national newspaper and
in a local newspaper of general circulation in the area affected by the project, a public notice mentioning the type of
project, its exact location, the name and address of the proponent and the places at which the EIA of the project
can, subject to the restrictions in sub-section (3) of section 12, be accessed.
(2) The notice issued under sub-regulation (1) shall fix a date, time and place for public hearing of any comments on
the project or its EIA.
(3) The date fixed under sub-regulation (2) shall not be earlier than 30 days from the date of publication of the
notice.
(4) The Federal Agency shall also ensure the circulation of the EIA to the concerned Government Agencies and
solicit their comments thereon.
(5) All comments received by the Federal Agency from the public or any Government Agency shall be collated,
tabulated and duly considered by it before decision on the EIA.
(6) The Federal Agency may issue guidelines indicating the basic techniques and measures to be adopted to ensure
effective public consultation, involvement and participation in EIA assessment.

11. Review
(1) The Federal Agency shall make every effort to carry out its review of the IEE within 45 days, and of the EIA
within 90 days, of issue of confirmation of completeness under Regulation 9.
(2) In reviewing the IEE or EIA, the Federal Agency shall consult such Committee of Experts as may be constituted
for the purpose by the Director-General, and may also solicit views of the sectoral Advisory Committee, if any,
constituted by the Federal Government under subsection 6) of section 5.
(3) The Director-General may, where he considers it necessary, constitute a committee to inspect the site of the
project and submit its report on suchmatters as may be specified.
(4) The review of the IEE or EIA by the Federal Agency shall be based on quantitative and qualitative assessment of
the documents and data furnished by the proponent, comments from the public and Government Agencies received
under Regulation 10, and views of the committees mentioned in sub-regulations (2) and (3) above.



                                                          23
Faisal Aslam                                                                         TRITA LWR Masters Thesis 0624.


12. Decision
On completion of the review, the decision of the Federal Agency shall be communicated to the proponent in the
form prescribed in Schedule V in the case of an IEE, and in the form prescribed in Schedule VI in the case of an
EIA.

13. Conditions of approval
(1) Every approval of an IEE or EIA shall, in addition to such conditions as may be imposed by the Federal Agency,
be subject to the condition that the project shall be designed and constructed, and mitigatory and other measures
adopted, strictly in accordance with the IEE/EIA, unless any variation thereto have been specified in the approval
by the Federal Agency.
(2) Where the Federal Agency accords its approval subject to certain conditions, the proponent shall –
(a) Before commencing construction of the project, acknowledge acceptance of the stipulated conditions by
executing an undertaking in the form prescribed in Schedule VII;
(b) before commencing operation of the project, obtain from the Federal Agency written confirmation that the
conditions of approval, and the requirements in the IEE/EIA relating to design and construction, adoption of
mitigatory and other measures and other relevant matters, have been duly complied with.

14. Confirmation of compliance
(1) The request for confirmation of compliance under clause (b) of sub regulation
(2) of Regulation 13 shall be accompanied by an Environmental Management Plan indicating the measures and
procedures proposed to be taken to manage or mitigate the environmental impacts for the life of the project,
including provisions for monitoring, reporting and auditing.
(2) Where a request for confirmation of compliance is received from a proponent, the Federal Agency may carry out
such inspection of the site and plant and machinery and seek such additional information from the proponent as it
may deem fit: Provided that every effort shall be made by the Federal Agency to provide the requisite confirmation
or otherwise within 15 days of receipt of the request, with complete information, from the proponent.
(3) The Federal Agency may, while issuing the requisite confirmation of compliance, impose such other conditions as
the Environmental Management Plan, and the operation, maintenance and monitoring of the project as it may deem
fit, and such conditions shall be deemed to be included in the conditions to which approval of the project is subject.

15. Deemed approval
The four-month period for communication of decision stipulated in sub-section
(4) of section 12 shall commence from the date of filing of an IEE or EIA in respect of which confirmation of
completeness is issued by the Federal Agency under clause (a) of sub-regulation (1) of Regulation 9.

16. Extension in review period
Where the Federal Government in a particular case extends the four-month period for communication of approval
prescribed in sub-section (5) of section 12, it shall, in consultation with the Federal Agency, indicate the various steps
of the review process to be taken during the extended period, and the estimated time required for each step.

17. Validity period of approval
(1) The approval accorded by a Federal Agency under section 12 read with Regulation 12 shall be valid, for
commencement of construction, for a period of three years from the date of issue.
(2) If construction is commenced during the initial three-year validity period, the validity of the approval shall stand
extended for a further period of three years from the date of issue.
(3) After issue of confirmation of compliance, the approval shall be valid for a period of three years from the date
thereof.
(4) The proponent may apply to the Federal Agency for extension in the validity periods mentioned in sub-
regulations (1), (2) and (3), which may be granted by the Federal Agency in its discretion for such period not
exceeding three years at a time, if the conditions of the approval do not require significant change: Provided that the
Federal Agency may require the proponent to submit a fresh IEE or EIA, if in its opinion changes in location,
design, construction and operation of the project so warrant.




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           Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.


18. Entry and inspection
(1) For purposes of verification of any matter relating to the review or to the conditions of approval of an IEE or
EIA prior to, during or after commencement of construction or operation of a project, duly authorized staff of the
Federal Agency shall be entitled to enter and inspect the project site, factory building and plant and equipment
installed therein.
(2) The proponent shall ensure full cooperation of the project staff at site to facilitate the inspection, and shall
provide such information as may be required by the Federal Agency for this purpose and pursuant thereto.

19. Monitoring
(1) After issue of approval, the proponent shall submit a report to the Federal Agency on completion of construction
of the project.
(2) After issue of confirmation of compliance, the proponent shall submit an annual report summarizing operational
performance of the project, with reference to the conditions of approval and maintenance and mitigatory measures
adopted by the project.
(3) To enable the Federal Agency to effectively monitor compliance with the conditions of approval, the proponent
shall furnish such additional information as the Federal Agency may require.

20. Cancellation of approval
(1) Notwithstanding anything contained in these Regulations, if, at any time, on the basis of information or report
received or inspection carried out, the Federal Agency is of the opinion that the conditions of an approval have not
been complied with, or that the information supplied by a proponent in the approved IEE or EIA is incorrect, it
shall issue notice to the proponent to show cause, within two weeks of receipt thereof, why the approval should not
be cancelled.
(2) If no reply is received or if the reply is considered unsatisfactory, the Federal Agency may, after giving the
proponent an opportunity of being heard:
(i) require the proponent to take such measures and to comply with such conditions within such period as it may
specify, failing which the approval shall stand cancelled; or
(ii) cancel the approval.
(3) On cancellation of the approval, the proponent shall cease construction or operation of the project forthwith.
(4) Action taken under this Regulation shall be without prejudice to any other action that may be taken against the
proponent under the Act or rules or regulations or any other law for the time being in force.

21. Registers of IEE and EIA projects
Separate Registers to be maintained by the Federal Agency for IEE and EIA projects under sub-section (7) of
section 12 shall be in the form prescribed in Schedule VIII.

22. Environmentally sensitive areas
(1) The Federal Agency may, by notification in the official Gazette, designate an area to be an environmentally
sensitive area.
(2) Notwithstanding anything contained in Regulations 3, 4 and 5, the proponent of a project situated in an
environmentally sensitive area shall be required to file an EIA with the Federal Agency.
(3) The Federal Agency may from time to time issue guidelines to assist proponents and other persons involved in
the environmental assessment process to plan and prepare projects located in environmentally sensitive areas.
(4) Where guidelines have been issued under sub-regulation (3), the projects shall be planned and prepared, to the
extent practicable, in accordance therewith and any departure there from justified in the EIA pertaining to the
project.

23. Environmental Assessment Advisory Committee
For purposes of rendering advice on all aspects of environmental assessment, including guidelines, procedures and
categorization of projects, the Director-General shall constitute an Environmental Assessment Advisory Committee
comprising –
(a) Director EIA, Federal Agency … Chairman
 (b) One representative each of the Provincial Agencies … Members


                                                        25
Faisal Aslam                                                                    TRITA LWR Masters Thesis 0624.


(c) One representative each of the Federal Planning Commission and the Provincial Planning and Development
Departments … Members
(d) Representatives of industry and non-Governmental organizations, and legal and other experts … Members

24. Other approvals
Issue of an approval under section 12 read with Regulation 12 shall not absolve the proponent of the duty to obtain
any other approval or consent that may be required under any law for the time being in force.

PAKISTAN ENVIRONMENTAL PROTECTION AGENCY (REVIEW OF IEE AND EIA)
REGULATIONS, 2000

*For detailed description document is available at http://www.environment.gov.pk




                                                        26
Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           27
Faisal Aslam                                           TRITA LWR Masters Thesis 0624.



Appendix III

Current EIA Process in Pakistan (Pak. EPA 2005)




                                                  28
Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           29
Faisal Aslam                                                          TRITA LWR Masters Thesis 0624.



Appendix IV

Pakistan Environmental Protection Agency Organizational Chart (Pak. EPA)




                                                 30
Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           31
Faisal Aslam                                            TRITA LWR Masters Thesis 0624.



Appendix V

Jurisdiction of Responsible Authority (Pak. EPA)




                                                   32
Environmental Impact Assessment in Pakistan – overview, implementation and effectiveness.




                                           33
Faisal Aslam                                                                             TRITA LWR Masters Thesis 0624.



Appendix VI

Table 2: Issues identified through stakeholder consultations (Pak. EPA 2005)


                   ISSUES                                                      SUGGESTIONS
                                                  Development of a national environmental data base with the coordination
                                                  of:
                                                  R & D organizations in related sectors
       Availability and reliability of baseline   Developing a nationwide program of linking universities’ departments of
  1    data due to lack of coordination and       related disciplines through an integrated system to develop a system similar
                    cooperation.                  to that developed in the British India.
                                                  Based on the data, develop GIS/GPS other modern tools for efficient
                                                  environmental management
                                                  All environmental data must be provided and available to develop a national
                                                  environmental data base at NADRA
                                                  Revision of EIA procedures and streamlining the guidelines in the local and
        EIA procedures and guidelines are         indigenous context of social and environmental issues.
  2       not properly disseminated and
                clearly understood.               Dissemination of the environmental procedures not only on Internet but
                                                  also through other means of communication.
                                                  Capacity building of EPA’s and P&D’s department for:
                                                  Review of EIA reports
                                                  Economic and social appraisal of EIA
  3        Lack of institutional capacity         Evaluation in terms of environmental costs and long-term social benefits.
                                                  Capacity building of EPA’s for monitoring in terms of
                                                  Availability of necessary monitoring equipment
                                                  Trained manpower for carrying out monitoring
                                                  Logistics and transport for monitoring
       Lack of institutional mechanisms of        A clear mechanism of coordination between P&D and EPA for
       coordination for EIA of public sector      environmental screening of public sector projects at P&D and
  4                  projects.                    environmental clearance by the EPA.
        No relationship of EIA with Land           Role and responsibilities be clearly defined.
              Use Planning exists.                Land Use Planning must incorporate EIA
                                                  A strong political will is must at all level
                                                  Mechanisms for effective enforcement and necessary infrastructure need to
                                                  be developed
            Weak implementation and               Involvement of Local Governments for implementation at TMA level under
  5
            enforcement mechanisms                the devolved governance structure. Suggestion is:
                                                  Implementation at TMA level under the devolved system
                                                  Monitoring by the provincial EPA
                                                  Evaluation by the federal EPA
                                                  Identification and engagement of actual stakeholders rather than people with
                                                  vested in the public consultation process.
                                                  Public hearing system must be strengthened through promotion of
       Weak public participation during the       voluntary associations or clubs or groups comprising of experienced people
  6     process of EIA and public hearing         from different sectors.
       system is not effective and objective.     Capacity building of
                                                  Media persons through trainings
                                                  NGOs through training and networking
                                                  Academia through dissemination of interdisciplinary knowledge on EIA in
                                                  the broader context of sustainable development and poverty alleviation
                                                  Improved consultancy services through:
  7            Consultancy services:              Quality assurance mechanism need to be devolved
                                                  Accreditation of consultants on the basis of a transparent selection criteria
                                                  Development of judicial activism for environment is needed merely public
  8        Insufficient Judicial support          interest litigation is not sufficient.
                                                  Promoting legal instrument for implementation of EIA.
                                                  EPA’s may be allowed to disburse the fee collected with EIA reports to
                                                  spend on review process.
  9        Lack of Financial Resources            Implementing bodies may be allowed to utilize the funds (on the
                                                  environmental improvement) generated at the local level on account of
                                                  violating environmental regulations.




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