LWR Ex 06 24

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
ii
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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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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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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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
2
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
3
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-
4
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
5
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
6
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
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
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
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
(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
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
• 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
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
14
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
15
16
APPENDIXES I-VI
17
Appendix I
Pakistan Environmental Protection Policy, 2005(Pak. EPA 2005)*
18
19
*For detailed description the document is available at http://www.environment.gov.pk
20
21
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.
22
(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
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.
24
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
(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
27
Appendix III
Current EIA Process in Pakistan (Pak. EPA 2005)
28
29
Appendix IV
Pakistan Environmental Protection Agency Organizational Chart (Pak. EPA)
30
31
Appendix V
Jurisdiction of Responsible Authority (Pak. EPA)
32
33
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.
34

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ENVIRONMENTAL IMPACT ASSESSMENT

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

3. LITERATURE REVIEW .................................................................................................................................... 3

5. ENVIRONMENTAL IMPACT ASSESSMENT AND PAKISTAN.............................................................. 4

6. DISCUSSION AND CONCLUSIONS .............................................................................................................. 7

1. INTRODUCTION Environmental Protection Agencies (EPA’s) for

Fig.1 Map of Pakistan [9]

3.4. Administrative procedures for coordinating 2008) is being implemented by Pak-EPA in

Fig.3 EIA working layout

EIA and PAKISTAN

SCREENING : initial Environmental Evaluation

Public, scientific community SCOOPING Define issues, Make Pre-feasibility studies

PREDICTION & MITIGATION Feasibility studies

Prepare draft EIS

MANAGEMENT & MONITORING Implementation

5.3.3. Description of project • Socioeconomic values

IEE EIA NOC Issued In Process Table 2. EPA

(ii) Assessing impacts 6.7. Post Monitoring & Analysis of EIA

• Quality assurance of services through a issues in a cost-effective manner. Consequently,

8.14. Environmental auditing

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

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

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

PAKISTAN ENVIRONMENTAL PROTECTION AGENCY (REVIEW OF IEE

1. Short title and commencement

3. Projects requiring an IEE

4. Projects requiring an EIA

5. Projects not requiring an IEE or EIA

6. Preparation of IEE and EIA

8. Filing of IEE and EIA

10. Public participation

13. Conditions of approval

14. Confirmation of compliance

15. Deemed approval

16. Extension in review period

17. Validity period of approval

18. Entry and inspection

20. Cancellation of approval

21. Registers of IEE and EIA projects

22. Environmentally sensitive areas

23. Environmental Assessment Advisory Committee

24. Other approvals

PAKISTAN ENVIRONMENTAL PROTECTION AGENCY (REVIEW OF IEE AND EIA)

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

Current EIA Process in Pakistan (Pak. EPA 2005)

Pakistan Environmental Protection Agency Organizational Chart (Pak. EPA)

Jurisdiction of Responsible Authority (Pak. EPA)

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

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