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Environmental Impact Assessment Review 28 (2008) 562–571

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Environmental Impact Assessment Review

j o u r n a l h o m e p a g e : w w w. e l s e v i e r. c o m / l o c a t e / e i a r

Evaluation of environmental impact assessment system in Pakistan

Obaidullah Nadeem ⁎, Rizwan Hameed
Department of City and Regional Planning, University of Engineering and Technology, Lahore, Pakistan

a r t i c l e i n f o a b s t r a c t

Article history: Environmental impact assessment (EIA) was first introduced in Pakistan based on the
Received 10 January 2008 Environmental Protection Ordinance 1983. The EIA process was further strengthened under
Received in revised form 29 February 2008 the Pakistan Environmental Protection Act 1997, which became operational under EIA
Accepted 29 February 2008
Regulations 2000. Despite a sound legal basis and comprehensive guidelines, evidence
Available online 23 April 2008
suggests that EIA has not yet evolved satisfactorily in Pakistan. An evaluation of the EIA
system against systematic evaluation criteria, based on interviews with EIA approval authorities,
consulting firms and experts, reveals various shortcomings of the EIA system. These mainly
Environmental impact assessment
include; inadequate capacity of EIA approval authorities, deficiencies in screening and scoping,
poor EIA quality, inadequate public participation and weak monitoring. Overall, EIA is used
presently as a project justification tool rather than as a project planning tool to contribute to
achieving sustainable development. Whilst shortcomings are challenging, central government
has recently shown a high degree of commitment to the environmental protection by making
EIA compulsory for all the public sector projects likely to have adverse environmental impacts.
The paper identifies opportunities for taking advantage of the current environment for
strengthening the EIA process.
© 2008 Elsevier Inc. All rights reserved.

1. Introduction likely to have adverse environmental and social impacts. But,

it does not appear as an effective tool to “safeguard” the
Pakistan is experiencing a rapidly growing economy as well environment and socio-economic fabric of the communities
as high population and urbanization growth. Ineffective natural in Pakistan (Aslam, 2006; Saeed, 2004). To date, research on
resource management over many years and a long history of EIA has included numerous studies mainly on procedures and
unplanned development not only have had negative impacts on EIA effectiveness and comparative analyses of different EIA
Pakistan's socio-economic fabric but also on its environment, systems (Ahmad and Wood, 2002; Barker and Wood, 1999;
particularly in urban areas. Safeguarding public health and Lee and George, 2000; Lim, 1985; Sadler, 1996; Wood, 2003).
preserving its natural wonders has made environmental However, not much research has been undertaken on the
protection increasingly important. In order to make informed functioning of the EIA system in Pakistan. This research paper
decisions and facilitate sustainable development for future aims at filling this gap.
generations, environmental impact assessment (EIA) offers a The contemporary EIA practice is facing several chal-
systematic process for examining the environmental conse- lenges, some of which are (Wood, 2003):
quences of a development related initiative (Glasson et al., 1999).
In Pakistan, like in many jurisdictions around the globe, • weak integration of EIA into decision making system
not all development activities need to undergo EIA but those • inadequate involvement of stakeholders in the EIA process
• inadequate converge of impacts
• poor quality of EIA reports
⁎ Corresponding author. Tel.: +92 42 9029203; fax: +92 42 9250202.
• inadequate review of EIA reports
E-mail addresses: (O. Nadeem), • weak implementation of mitigation measures and monitor- (R. Hameed). ing of impacts.

0195-9255/$ – see front matter © 2008 Elsevier Inc. All rights reserved.
O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571 563

International experiences indicate that political factors Table 1

have been the driving forces behind the introduction and List of evaluation criteria used to analyse the EIA system of Pakistan

practice of EIA (Thomas, 2001). Cultural influences and 1) Legislative provisions for EIA
economic conditions have been said to have significant • Legal provisions
bearing on the form of an EIA system. Generally speaking, EIA • Legal provisions for appeal by the proponent or stakeholders against
appears to be most effective where environmental values are
• Legal specification of time limits for approval and appeal
integrated into a nation's culture and public law and policy • Legal provisions for SEA
(Thomas, 2001). Though relevant literature suggest that, the
shortcomings of contemporary EIA practice could possibly be 2) Administrative set up for EIA
• Competent authority for EIA screening and approval
overcome. This may involve enhancing the institutional
• EIA review body
capacity to provide clear guidelines, initiating the assess- • Specification of responsibilities of sectoral authorities in the EIA process
ment process at early stages of the project, adequately • Level of coordination with other planning and development
involving stakeholders, systematically reviewing EIA quality agencies/departments
and monitoring its implementation (Ahmad and Wood,
3) EIA process and practice
2002; Sadler, 1996). Nonetheless, “contribution made by
• Specification of screening categories
EIA, both to consent decisions and to project design, is • Screening approach
generally moderate rather than substantial” (Jay et al., 2007, • Scoping approach
p291). • Requirement for consideration of alternatives
This paper evaluates the EIA system of Pakistan. It is based • Specification of EIA report contents
• Systematic approach for the review of EIA report
on: • Public participation in the EIA process
• Systematic approach for decision making and approval
(1) literature review on evaluation of EIA systems
• Specified requirement for environmental management plans
(2) document analysis including legislative provisions, EIA • Specified requirement for mitigation of impacts
guidelines and procedures in Pakistan • Specified requirement for monitoring of impacts
(3) secondary data including number and approval status • SEA Experience
of EIA reports in the country, and Source: Adapted from Wood (2003); Ahmad and Wood (2002); Fuller (1999).
(4) information obtained through interviews with officials
of federal and provincial EPAs in the country, utility
services agencies/line departments, banks, proponents,
effectiveness of any EIA system to enable an international
EIA consultants and experts from various backgrounds
comparison to be made between systems”.
(see Appendix A).
The next section introduces evaluation criteria used for 3. Evaluation of the EIA system of Pakistan
this paper. This is followed by a brief account of the evolution
and process of EIA in Pakistan. Legislative provisions and In this section, the EIA system of Pakistan is evaluated. The
guidelines are then introduced and an analysis of the per- performance of the major components of the EIA process and
formance of the EIA system is provided. Weaknesses and practice are discussed in detail. Legislative provisions, guide-
opportunities for improving EIA procedures and practice are lines and results of the evaluation are summarised in Table 2.
identified in the discussion. Finally, conclusions and recom-
mendations are presented in the light of evaluation results. 3.1. Legislative provisions for EIA

2. Evaluation criteria The Pakistan Environmental Protection Ordinance (PEPO) of

1983 first introduced EIA in the country (GoP, 1983). Before
The evaluation criteria methodology for analysis of the EIA conducting an EIA, the Ordinance required that an initial
system of Pakistan are taken from Ahmad and Wood (2002), environmental examination (IEE) of projects to be carried out to
Wood (2003) and Fuller (1999). These criteria consist of aims assess the need and scope for an EIA. The PEPO defines IEE as,
and stages of EIA (screening, scoping, review of EIA reports,
“Initial environmental examination means preliminary
public participation, decision making, mitigation of impacts
environmental review of the reasonably foreseeable quali-
and monitoring). Generally speaking, “[t]he focus of the
tative and quantitative impacts on the environment of a
criteria is on the requirements and operation of the EIA
proposed project to determine whether it is likely to cause
process” (Wood, 2003, p12). Evaluation of legislative provi-
an adverse environmental effect for requiring preparation of
sions, guidelines and institutional set up for EIA has been
an environmental impact assessment” (GoP, 1983).
included to provide a comprehensive picture of the system.
The identification of the attitudes and opinions of those
Thus, IEE was supposed to supplement the screening and
involved in the process, i.e. proponents, consultants and
scoping mechanisms. Later on, the ordinance was replaced by
concerned officials also provides valuable input for the
the Pakistan Environmental Protection Act (PEPA) 1997 (GoP,
evaluation, as has been suggested by Bartlett and Baber
1997a). During the same year, an environmental assessment
(1989). Table 1 presents the evaluation criteria.
package was also released (GoP, 1997b). The package
Ahmad and Wood (2002) and Wood (2003) used these
comprises various sets of guidelines, for:
criteria to evaluate performance of EIA systems in some of the
developing and developed countries. Wood (2003, p13) also (a) preparation and review of environmental reports;
suggested that “these criteria can be employed to judge the (b) public consultation;
564 O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571

Table 2
Evaluation of EIA System in Pakistan against systematic evaluation criteria

Sr. Systematic evaluation criteria The EIA system and practice in Pakistan
(1) Legislative provisions for EIA
1.1 Legal provisions Enabling legislation: Federal Govt.'s PEPA, 1997 (section 12); Specific Regulations: IEE/EIA
1.2 Legal provisions for appeal by the proponent or Provision under Section 22 of PEPA, 1997 for appeal against concerned EPAs decisions to the Provincial
stakeholders against decisions Environmental Tribunal
1.3 Legal specification of time limits for approval Four months time limit (extendable) for decision on EIA, and the proponent or general public may
and appeal appeal against EIA approval or any decision within 30 days of the decision
1.4 Legal provisions for SEA None. But indicated desire in the IEE/EIA Regulations for consideration of strategic or cumulative
environmental impacts during EIA studies

(2) Administrative set up for EIA

2.1 Competent authority for EIA screening and Pak-EPA at federal level; Provincial EPAs at provincial level
2.2 EIA review body EPAs within their jurisdictions and may consult environmental review committees mainly comprising
officials of EPAs and other depts. concerned with EIA of the project under review and individual
2.3 Specification of responsibilities of sectoral EIAs are submitted to EPAs for private projects and through P&Ds for public sector projects as required
authorities in the EIA process under project Schedule II. Other sectoral authorities are invited for comments on concerned EIA report.
2.4 Level of coordination with other planning and Need stressed in Regulations for interagency coordination at key stages of EIA process but practically
development agencies/departments weak coordination exists

(3) EIA process and practice

3.1 Specification of screening categories Two screening lists: Schedule I — Projects requiring IEE; Schedule II — Projects requiring full EIA
3.2 Screening approach Schedules of projects requiring EIA, sectoral guidelines and checklists of likely impacts, and if need of
EIA is assessed on the basis of IEE
3.3 Scoping approach EPAs provide guidelines but TOR is primary responsibility of proponent
3.4 Requirement for consideration of alternatives Required under Section 1.7 of guidelines for preparation and review of environmental reposts but
consideration of alternatives is inadequate
3.5 Specification of EIA report contents Identified in detail in Section 5 of guidelines; A standard form indicating contents provided by EPAs
3.6 Systematic approach for the review of EIA report Comprehensive provision under Section 6 of guidelines identifying steps/criteria in reviewing but
practically informal approach
3.7 Public participation in the EIA process Act provides for public hearing during review. Proponent is responsible to arrange hearing after
admission of EIA by the EPA. An official of EPA administers public hearings. EIA guidelines also request
public consultation during EIA study. But, generally not done or inadequate where consulted.
3.8 Systematic approach for decision making and EPA grants environmental approval for both public private projects within its jurisdiction, if satisfied
approval from the response of the proponent to the objections of reviewers and the public.
3.9 Specified requirement for environmental Required in guidelines but not necessary for environmental report. Just outlines required to accompany
management plans with. However, EMP to be developed at the operating approval stage of the project.
3.10 Specified requirement for mitigation of impacts General requirement in guidelines for preparation and review of environmental reports but proponent
usually avoid costly mitigation measures
3.11 Specified requirement for monitoring of impacts Proponent held responsible for undertaking and paying for monitoring and management of monitoring
information; Responsible Authority may set up environmental monitoring committees but normally no
monitoring by RAs field staff except upon complaint by affectees
3.12 SEA experience SEA of couple of policies only by the individual government departments

(c) sensitive and critical areas; and contravention continues. These are heavy fines as compared
(d) specific developmental sectors, for example, major to the amounts of fines imposed on violation of other legal
road, industrial estates, oil and gas exploration etc. provisions in the country. However, in practice, the fines are
rarely imposed. In 2000, review of IEE/EIA regulations were
The Pakistan Environmental Protection Act 1997, under
promulgated which contain mandatory requirements and
section 12, states that project proponents, whether belonging
procedures for the public hearing and review of environ-
to a public or private sector, are required to prepare an IEE,
mental assessment reports along with provisions for mon-
and where a project is likely to cause adverse environmental
itoring (GoP, 2000).
effects, to undertake an EIA for review and approval prior to
The regulations and guidelines for EIA preparation and
project construction. The Act contains provisions for imposing
review and public consultation are quite comprehensive and
fines in case of non-compliance with section 12 and other
can possibly be compared with those of Egypt, Tunisia, India
specified clauses of the Act and any of the subsequent rules
and Sri Lanka (Ahmad and Wood, 2002; Paliwal, 2006; Zubair,
and regulations. The fine may extend up to 1 million rupees
2001). Sectoral guidelines for 7 out of 9 major categories of
(US$ 16,1291), with an additional fine extendable to one
projects listed in the schedule of EIA are also available.
hundred thousand rupees (US$ 1613) per day during which
However, availability of guidelines does not always mean
those are being followed in practice (Fuller, 1999). Legal
1 US$ = 62 rupees. provisions for EIA in Pakistan meet the legislative provisions
O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571 565

criteria in Table 1, except the formal requirements for SEA. utility services, well before EIA approval. And once the
Though, the overall practice of EIA in Pakistan shows that construction work of a project takes off, the role of EIA
implementation of relevant laws and guidelines is limited. becomes just a ritual to fulfil legal requirement. Inadequate
institutional capacity, lack of training and weak coordination
3.2. Administrative set up for EIA among line departments and agencies have also been
identified as impediments to effective EIA in other developing
The responsibility for implementing the 1997 PEPA and countries (Ahmad and Wood, 2002; Wood, 2003).
2000 IEE/EIA regulations lies with the Pakistan Environmental
Protection Agency (Pak-EPA) within Islamabad and other areas 3.3. EIA decision making and approval process
under Federal Government control. Provincial Environmental
Protection Agencies (EPAs) are responsible within their pro- The EIA decision making and approval process in Pakistan is
vincial jurisdiction. The four provincial agencies (Punjab-EPA, presented in Fig. 1. Whereas, it is mandatory under section 12 of
Sindh EPA, North West Frontier Province (NWFP)-EPA, Baluchi- Pakistan Environment Protection Act (PEPA) 1997 to submit
stan-EPA) were created during different years from 1987 either an IEE or an EIA, prior to commencement of the con-
onwards. The responsibility of processing IEE of public sector struction. In practice, EIA is undertaken as a result of repeated
projects is vested in the Planning and Development Depart- requests by the concerned EPA, usually after the start of
ment of the Federal government. The same jurisdiction of construction work. This happens particularly in case of public
responsibilities exists at the provincial level with the exception sector projects and in some cases of private projects too. The
of military projects and trans-country impact projects. very reasons behind preparation and approval of EIA after the
While institutional capacity building is increasingly seen initiation of public sector projects is the role of Planning and
as one of the means for “improving the management of EIA Development Departments (P&Ds) in screening and “political
systems and enhancing the effectiveness of practices” (Clark, pressure to expedient EIA clearances” (World Bank, 2006, p35).
1999, p49), Pakistan's administrative set up is severely lacking Taking advantage of this situation, proponent departments
in institutional capacity. Interviews with concerned officials sometimes submit un-approved EIA reports directly to P&D for
(see List after references) reveal that the EIA directorates at approval of funds by the competent authority.
provincial level are facing a severe shortage of staff with However, the authority responsible for granting economic
expertise in EIA. The number of staff dedicated to EIA approval to the mega development projects of public sector,
processing in each EPA ranges from 4 to 8 officials belonging i.e. the Executive Committee of National Economic Council
to various professional backgrounds. Specifically dedicated (ECNEC) of the Government of Pakistan on 27th July, 2004
filed staff for monitoring of impacts is negligible as compared decided that:
to that actually required. Only 1 to 2 filed inspectors are
appointed at district (borough) level along with a district “In case of development projects [public sector] having
officer. In case of metropolitan cities like Lahore which is environmental implications, an environmental impact
having 9 towns within its District Government, there is only assessment (EIA) report should invariably be submitted
one district and one deputy district officer in addition to a along with the project document at the time of getting
field inspector for each town. Similarly, 3 out of 4 of approval” (GoP, 2004).
environmental tribunals mostly remain non-functional
because of a failure to appoint its members (GoP, 2006). Following the ECNECs decision, it appears that the number
of EIA reports produced in the country increased dramatically
3.2.1. Interagency coordination from 12 in the year 2003 to 29 (i.e. 242%) in the year 2004. But
Interagency coordination is crucial for an effective EIA this number could not cross 36 during the following years.
system, since environmental issues, in their complexity and The total number of EIA reports produced in the country from
variety, are often inter-sectoral or regional (GoP, 1997c). But the year 2000 to 2006 is 136, i.e. approximately 20 reports per
the EIA practice, interviews with consultants and officials of annum. During subsequent years, ECNEC approved several
the sectoral authorities (see List after references) suggest that projects, most of which were subjected to EIA. But the EIA
generally informal or weak coordination exists among the reports of such projects were not approved by the concerned
proponents/consultants, EPAs and other agencies/line depart- Environment Protection Agency prior to economic approval
ments. Proponents/consultants least bother to consult con- by the ECNEC. Hence, the usefulness of such EIAs can be
cerned agencies/departments to identify issues during questioned. This situation can lead to irreversible decisions
preparation of EIA reports. Brief discussion on the laws and regarding site selection and sometimes severe environmental
policies of agencies concerned with the project is considered consequences. This is not only the case in Pakistan. Coordina-
sufficient for the EIA reports. tion of the EIA procedure and the project cycle has been said
The Environmental Protection Agencies (EPAs) invite to be weak in other Asian countries, as well (Werner, 1992). In
concerned agency/department for submitting their comments cases where EIA is carried out, its effect on decision making,
and participating in the public hearing of the projects. But the like in many jurisdictions internationally, suggests that
utility services providing agencies like Water and Power projects are not often rejected or withdrawn prior to approval
Development Authority (WAPDA), Sui Northern Gas Pipelines (Sadler, 1996).
(SNGPL), Water and Sanitation Agency (WASA) and even
banks are not bound to check EIA clearance prior to extending 3.3.1. Screening
their services. This often results in the start of construction and For the purpose of environmental screening, the Pakistan
even operation of the projects, with connections of all the Environment Protection Agency has divided development
566 O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571

Fig. 1. Approval process for EIA of private and public sector development projects in Pakistan. Based on: GoP (1997c); Nadeem and Hameed (2006a).
Legend: Represents stages for public sector projects. Represents common stages for both public and private sectors projects. CDWP Central
Development Working Party, ECNEC Executive Committee of National Economic Council, P & D Planning and Development Department, PC-1 Project Cost-1, ToR
Terms of Reference, Dept. Department.
O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571 567

projects into two schedules (GoP, 2000). Schedule I enlists the IEE/EIA Regulations 2000 stipulate that the responsible
projects in broader categories like agriculture, livestock and Environment Protection Agency (EPA) shall advise the
fisheries, energy, manufacturing and processing, transport, proponent of the adequacy of the EIA report or confirmation
water management (dams), water supply treatment, waste of completeness within 10 days of receipt. The responsible
disposal and urban development and others, to require an EPA is also required to complete the review process within
initial environmental examination (IEE). Schedule II enlists 90 days after confirmation of the adequacy of the EIA report.
projects, in roughly the same broad categories as that of Interviews with consultants (see List after references)
Schedule I, excluding agriculture, livestock and fisheries, but suggest that in practice, the review is always subjective in
with addition of projects located in environmentally sensitive nature and depends primarily upon the personal judgment of
areas, requiring an EIA. The project cost and capacity with the concerned officials and affiliations of the consultants.
respect to every development sector are the bases for However, the study of EIA case files and interviews of EPA
determining the requirement of an IEE or EIA. For instance, officials (see List after references) reveal that some members
a highway project with a total cost of less than 50 million of the review committee also belong to various stakeholders.
rupees (0.806 million US$) requires an IEE and a highway Often they are government departments or sectoral agencies
project above this cost requires an EIA; a hydro power concerned with the project, educational and research institu-
generation project of less than 50 MW (MG) needs to undergo tions, Non-Governmental Organizations (NGOs) and editors/
an IEE. An EIA is required if it is above this generation capacity reporters of some leading newspapers of the country. The
(GoP, 2000). comments of the concerned departments and experts are
It is clearly indicated in the guidelines relating to review actually sought by all EPAs and the proponents are asked to
and approval of environmental assessments that revision of respond prior to formal public hearing. In some cases, the
categorization of projects in schedules I and II is an ongoing comments of EIA experts and proponent's response have been
process. Interviews with EIA consultants and discussions with presented during public hearings.
academics (see List after references) also suggest that there is A critical review of randomly selected EIA reports of
an immense need to review the schedules, but no progress has industrial projects located in Punjab, the biggest province of
been made to this end. Oil and gas extraction and large Pakistan, revealed that their quality is generally poor and
housing schemes' projects are included in the list of projects inadequate in many respects (Nadeem and Hameed (2006b).
requiring an IEE not EIA, while these should have gone This review identified the following key shortcomings:
through the EIA process. This is creating difficulty for the EPA
○ An insufficient allocation of time and money by the
officials to convince the proponents of such projects, particu-
proponents for conducting EIA
larly from the public sector, for undertaking EIA studies.
○ Absence of baseline data
○ Little experience and inadequate technical resources of
3.3.2. Scoping
EIA consultants
The basis of determining the scope of an initial environ-
○ Scant involvement of the stakeholders during preparation
mental examination (IEE) or EIA in Pakistan derives from the
of EIA reports
sectoral guidelines. The sectoral guidelines are available for
○ Heavy reliance on qualitative analysis of impacts
projects belonging to various development sectors e.g.
industrial estates, major roads etc. (GoP, 1997b). The guide-
○ Inadequate consideration of project alternatives
lines for preparation of environmental reports also suggest for
thorough discussion with key stakeholders, assembling Such inadequacies regarding EIA reports also exist in many
available information from concerned departments and other EIA regimes and have been identified and discussed
agencies, consulting with possible affectees, considering elsewhere (see for example, Glasson et al., 1999; Wood, 2003).
alternatives and identifying information gaps (GoP, 1997c). Over and above, it is unfortunate to note that there is no
Although, roles of stakeholders in the scoping process have practice of auditing EIA quality. It could be done through
been identified, the primary responsibility of developing matching the impacts which were predicted in EIA with those
terms of reference (TOR) lies with the proponents. actually arising during construction and operation phases of
It is common practice in Pakistan that proponents rarely the project (Glasson et al., 1999). This may help in improving
involve stakeholders during scoping. However, scoping is not the EIA quality in future.
a mandatory requirement like it is in many other jurisdictions
in East Asia, for example, China, Thailand and India (Briffett, 3.3.4. Public participation
1999). Therefore, areas of concerns of affectees and concerned Public participation or consultation in the form of public
government department are not truly reflected in the EIA hearings is mandatory only during the EIA review process in
reports. This is also because the EPAs have just a suggestive Pakistan. Further, in comparatively well developed EIA
role but no responsibility for preparing terms of reference systems like those of the Netherlands and Western Australia,
(ToR) for scoping. public participation is obligatory during screening and
scoping (Wood, 2003). But there is no compulsion on the
3.3.3. Reviewing the quality of EIA reports proponents in case of Pakistan to involve the concerned
The EIA review stage, helps to ensure that information on public during EIA preparation. Some proponents (particularly
the environmental impacts of an action is adequate before it is of foreign funded public sector projects) however, consult
used as a basis for decision making (Fuller, 1999). It is affectees mainly for collecting socio-economic baseline data
important to carry out this stage, as effectively and efficiently and occasionally for obtaining their views on project.
as possible (Ahmad and Wood, 2002). The clauses 9 and 10 of Stakeholders are given 30 days, following a notice published
568 O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571

in two national daily news papers, for submitting written 2002; Paliwal, 2006; Werner, 1992; Zubair, 2001). The
comments before the public hearing. The venue for public regimes where mitigation measures are being implemented
hearing is normally a high class hotel in the city or office of the and monitoring of impacts is also being done more effectively,
concerned Environment Protection Agency or public sector for instance, the Netherlands and Canada, the competent
proponent. Such venues are often inaccessible by the directly authorities are well equipped with technically trained staff
affected indigenous people who are living in remote areas. In and monitoring equipment (Glasson et al., 1999).
addition, stakeholders are not informed about how their
concerns have been incorporated into the EIA report and final 4. Discussion: weaknesses and opportunities of the
decision. Such inadequacies pertaining to public participation Pakistan EIA system
in EIA also prevail in some of the other developing countries,
for instance, India, Bangladesh, Sri Lanka, Thailand, Indonesia Following paragraphs underpin the weaknesses and
and Malaysia etc. (Boyle, 1998; Momtaz, 2002; Paliwal, 2006; opportunities for rectification of the Pakistan EIA system.
Zubair, 2001). However, Pakistan is no exception.
Despite all of the above, there are some examples of public 4.1. Sound legislative provisions but weak administrative set up
sector initiatives during which stakeholders (affectees, NGOs,
print media, EIA and other experts) played very active roles. The legislative provisions and guidelines for EIA in the
Consequently, the competent authority had to pend the country are quite comprehensive. However, a lack of
approval of EIA till the proponent gave a satisfactory response implementing mandatory requirements for EIA including no
to the objections of the stakeholders or re-consider project use of powers to impose fines under the Pakistan Environ-
alternatives. The Lahore Canal Road Widening and Lahore ment Protection Act (PEPA) 1997 is resulting in the develop-
Ring Road projects are classic examples of this sort (Kashif ment and operation of many projects, likely to cause
and Dogar, 2007; The News, 2006). In a few cases (for environmental and socio-economic impacts, without under-
example, New Murree Tourist Resort and Islamabad Chalets going an EIA. Furthermore, proponents are aware that the
Projects) as a result of media campaigns and suo motu notices responsible authorities lack the enforcement machinery (Beg,
by the Supreme Court of Pakistan, development works of the 2004). Thus, projects for which EIA is carried out, it takes
projects have been stopped. Yet, in another case (National place after procurement of site or even after start of
Highways Rehabilitation Project) according to the proponent construction and hence EIA becomes just a formality.
and the EIA report, the stakeholders and particularly the
affectees were consulted during scoping, impact identifica- 4.2. Weak coordination
tion and mitigation stages. The affectees' concerns were
adequately addressed in the EIA report and a grievance Coordination among EIA proponents/consultants, EPAs,
redressal system was developed to compensate them (NHA, local financial institutions and the line departments is
2003). Those examples of active stakeholders' involvement in generally weak. This is leading not only to the inadequate
the EIA process are quite encouraging given the fact that in consideration of concerned departments' views in the EIA
general the actual practice of EIA has yet to evolve into report but also to the start of development works prior to
substantial public participation. getting EIA clearance. Also because the financial institutions
and utility services providing agencies are not responsible to
3.3.5. Environmental management plan, mitigation and ensure EIA clearance before providing loans and utility
monitoring of impacts connections. Once the development works take off, the
Implementation of environmental management plans, possibilities of alternatives or modifications in project design
mitigation measures and compliance monitoring are overall during construction are meagre or none in many cases.
inadequate. Interviews with the concerned officials of Envir-
onment Protection Agencies (see List after references) suggest 4.3. Few EIAs
that after obtaining EIA approval the proponents least bother
to adopt the mitigation measures and those who do, they do The EIA production rate of the country has been
not maintain the equipment so installed for mitigation of approximately 20 per annum during the last seven years.
impacts. Despite a legal requirement, monitoring mostly takes Data regarding average time of approval of an EIA are not
place in response of complaints. The self-monitoring and available. Some of the EIA reports are not yet approved.
reporting system indicated in the environmental manage- However, this is not an indication that all such projects are
ment plans (EMPs) are rarely practiced by project proponents. stopped. How many projects for which EIA was required by
This is clearly exemplified, for instance, by the case of a poultry law but have been developed during the last seven years
feed industry in Punjab Province, the EIA approval of which without EIA is also unknown. The investigation of these
has been withdrawn as a result of complaints from surround- aspects may provide useful insights into the causes of delays
ing community against nuisance resulting from non-compli- as well as the weight given to various types of impacts and to
ance with National Environmental Quality Standards (NEQS). the public opinion during review.
The major difficulty faced by the EPAs to effectively carry
out monitoring activities is limited institutional capacity, 4.4. Inadequate screening and scoping
arising mainly from insufficiency in numbers of suitably
qualified and experienced personnel and monitoring equip- The Planning and Development (P&D) Department's author-
ment, as has generally been the case in EPAs in other ity of screening and processing initial environmental examina-
developing countries (Ahmad and Wood, 2002; Momtaz, tion (IEE) of public sector projects appear to be one of the causes
O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571 569

of no or late initiation of EIA studies, if so required under the influential, EPAs are considered among the weakest govern-
law. Being an in-house department for government projects, it ment agencies. Political manifestos, generally speaking, are to
sometimes ignores the requirement of EIA due to political encourage investment in the development sector. There is a
pressure. No periodical review of the schedule of projects need to transform political will in favour of development but
requiring an EIA is the other cause of delayed or no EIA. not at the cost of environment.
Furthermore, inadequate involvement of stakeholders and the
concerned EPA during scoping is resulting in a thin coverage of 5. Conclusions and recommendations
environmental and socio-economic issues in the EIA reports.
Pakistan is one of the developing countries that has sound
4.5. Limited scope of EIA report review legal provisions for EIA. Furthermore, a comprehensive package
of EIA guidelines exists. While it appears that EIA in Pakistan is
Reviewing of EIA reports is generally process and sub- improving steadily, an overall evaluation of the EIA system
stance oriented except some comments on the quality of reveals several weaknesses, not only in the institutional
impact assessment by the EIA experts in review committees. framework, but also in implementation and actual practice.
This third party involvement in the review can be marked as a The influence of EIA on decision making is weak, owing to
salient feature of the EIA process in Pakistan. Although, an numerous reasons pertaining to inadequate technical and
independent EIA review commission does not exist, more financial resources, deficiencies in screening and scoping,
resources are expected to be allocated by the government to weak coordination, subjective review, ineffective public parti-
transform third party involvement in to formal review bodies. cipation and no formal monitoring. Nonetheless, some oppor-
Some anomalies, however, can be found due to lack of tunities other than the legal basis also exist in the form of
technical capacity and subjective review. Political pressure is political support of EIA, third party review and role of NGOs and
also causing approval of poor quality EIA reports. media in supporting public concerns. Thus, there is a good hope
that the EIA system in Pakistan will strengthen further in near
4.6. Poor quality of EIA reports future. The need is to tap the existing opportunities. It is
suggested that the following measures can help enhance the
The overall quality of EIA reports is unsatisfactory. The lack effectiveness of the EIA system in Pakistan.
of experience of EIA consultants and approval authorities
along with reluctance on part of the proponents to allocate ➢ The legal framework for EIA in the country is strong
sufficient resources are some of the impediments to better enough to provide back up for taking stern action against
quality EIA. In addition to that, there is no code of conduct for violators of EIA requirements. It needs a strong political
EIA consultants; not even any requirement of registration. In will and institutional capacity to enforce the 1997 Pakistan
many cases, a consultant's role has been limited to highlight Environment Protection Act. The decision of the Executive
the economic benefits and justify the project for getting Committee of National Economic Council includes some
environmental approval. political will. The EIA directorates of the EPAs should be
strengthened by giving more administrative powers to
4.7. Weak public participation impose fine or seal any project violating EIA requirements.
In this regards, adequately qualified staff and equipment
Good guidelines have been provided by the Pakistan particularly required for inspection and enforcement are
Environment Protection Agency for public consultation. Like some of the pre-requisites.
many EIA regimes around the globe, public involvement ➢ Good coordination among proponents/consultants, financial
during scoping, impact identification and evaluation is non- institutions, revenue/land registration department, planning
mandatory in Pakistan. Taking the advantage, proponents try and building control and utility services providing agencies
to avoid public as much as possible during the preparation of can play a pivotal role in consideration of their concerns early
an EIA report. Where Non-Governmental Organizations in the EIA process. It would also help in ensuring that no
(NGOs), experts and affectees have joined hands, they have project, likely to have adverse environmental impacts could
succeeded in denting the shell of weak public participation. be launched before securing EIA clearance. This can be
Under what circumstances the reactive public participation achieved by making amendments in the 1997 PEPA to assign
achieves its goals or is effective and how far the mandatory responsibility to all the aforementioned government depart-
public hearings are actually influencing the decision making ments/agencies to coordinate with the concerned Environ-
processes in EIA in the country are yet to be evaluated. ment Protection Agency before extending any services to the
projects requiring an EIA under the Act.
4.8. Inadequate implementation of mitigation measures and ➢ The Planning and Development Department should send a
monitoring copy of the IEE of projects to the concerned EPA for decision
on whether an EIA is required or not. The revision of screening
The implementation of an environmental management lists (schedules of projects requiring an IEE/EIA) has been due
plan, mitigation measures and post-decision monitoring are for many years. The Pakistan Environment Protection Agency
some of the weakest facets of Pakistan's EIA system. These should initiate consultations with all the concerned govern-
weaknesses can be explained by the lack of enforcement ment departments/agencies, EIA experts and academia to
machinery and authority of the Environment Protection update the lists. EPAs should ensure, by giving significant
Agencies (EPAs). While the project proponents (usually weight during review, that the proponent has consulted
industrialists and government departments) are highly stakeholders and incorporated their concerns into the EIA
570 O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571

report. EPAs should also be held responsible for scoping like in University of Liverpool for his invaluable comments as a foreign
Sri Lanka (Zubair, 2001). This can help ensure an early consi- supervisor. The comments of the anonymous reviewers are also
deration of major areas of concern by the directly affected acknowledged.
public and the concerned government departments.
➢ Review should, however, be done by independent EIA Appendix A. Institutional affiliation of interviewees and
review bodies at different levels of decision making. Third discussion participants
party evaluation is already done at individual Environment
Protection Agency (EPA) levels. Such review bodies/boards Government Officials
can be established at federal and provincial levels like the
environmental tribunals. Official sources also confirmed • Pakistan Environmental Protection Agency (PAK-EPA), Islamabad
that EPAs have asked the government to increase funds • Punjab Environmental Protection Agency (PEPA), Lahore
allocation for the review committees as without paying • Sindh Environment Protection Agency (SEPA), Karachi
handsome remuneration some experts do not return their • North West Frontier Province Environment Protection
comments and even the copy of EIA report. Agency (NWFP-EPA), Peshawar
➢ A code of conduct and registration of EIA consultants is • Environment Cell, Planning Commission, Islamabad
important. It will not only help do away with a copy and • Environment Cell, Planning and Development Department
paste culture when producing reports but also discourage (P & D), Lahore
one or two persons ‘jack of all master of none’ type • Punjab Industrial Estate Development and Management
consultants. Grabbing international opportunities of fund- Company (PIEDMC), Lahore
ing for foreign training of officials and consultants may • Water and Power Development Authority (WAPDA), Lahore
also contribute to improving the quality of EIA reports. • Sui Northern Gas Pipelines (SNGPL), Lahore
➢ Public participation is a key component of EIA helping to • Lahore Development Authority (LDA), Lahore
bring procedural democracy and better acceptability of • Water and Sanitation Agency (WASA), Lahore
decision making into the EIA process (Aschemann, 2007). It • Revenue Department Punjab, Lahore
needs to be strengthened by raising stakeholders' awareness
about potential environmental and socio-economic impacts Consultants
of mega development projects. Since Non-Governmental
Organizations (NGOs) and media are playing a leading role • National Engineering Services Pakistan (NESPAK), Lahore
in this regards, international donor agencies should provide • National Environmental Consultants (NEC) Private Limited.
ample funding to NGOs and EPAs should encourage them by Lahore
providing better access to EIA related information. It is also • ECTECH Environmental Consultants, Lahore
suggested that a judge of an environmental tribunal should
head the public hearings along with the technical support of Financial Institutions/Banks
an independent panel of environmental experts. It is
expected that the role of expert's panel (and that of judge) • National Bank of Pakistan (NBP), Lahore
would help assessing the genuineness of the concerns of • Habib Bank Limited (HBL), Lahore
stakeholders and promoting an environment of justice
during hearings. After the hearings, stakeholders must be Academics
informed about how their concerns have been incorporated
in the EIA report and the final decision. • University of Engineering & Technology, Peshawar
➢ To enhance the implementation of management plans, • University of Engineering & Technology (UET), Lahore
mitigation measures and post-EIA monitoring, EPAs • Allama Iqbal Open University (AIOU), Islamabad
should be provided with sufficient staff and equipment.
Of course, more autonomy in the form of minimum Non-Governmental Organizations
political interference and involvement of local commu-
nities shall also be needed to ensure better compliance of • World Wildlife Fund (WWF) Pakistan
the conditions of EIA approval and monitoring. • Pakistan Environmental Assessment Association, Karachi

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