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Chapter-5 Environmental Impact Assessment Process and Decision Making in Pakistan

The EIA process in Pakistan is critically examined in this chapter with particular focus on decision making. It is based on document analysis, secondary data about number of EIA reports and information obtained through semi-structured interviews with government officials and experts. These included: concerned officials of the federal and provincial Environmental Protection Agencies in the country, line departments/agencies, proponents, EIA consultants and experts from various backgrounds (See Section 4.5.4). The first and second sections provide with a brief account of the legislative provisions, guidelines and administrative set up for EIA. Major steps of the decision making and approval process are presented in the third section. Lastly, the overall weaknesses and opportunities regarding the EIA system in Pakistan are summarised. This chapter is also published in the form of a research paper in an international journal (See Nadeem and Hameed, 2008). 5.1 Legal Provisions for EIA

Environmental impact assessment was first introduced in the country by promulgation of Pakistan Environmental Protection Ordinance (PEPO) 1983 (GoP, 1983). The Ordinance required that every proponent shall file a detailed environmental impact statement at the time of planning the project, which was likely to cause adverse effects on the environment. However, being an ordinance, it was later on repealed and the Pakistan Environmental Protection Act (PEPA) 1997 was enforced (GoP, 1997). This Act was prepared after consulting stakeholders including industrialists, NGOs and even general public through holding seminars and workshops. The PEPA under section 12, states that the project proponents, whether belonging to public or private sectors, are required to prepare an Initial Environmental Examination (IEE). The IEE mainly includes preliminary environmental review in order to determine if the proposed project may lead to adverse environmental and socioeconomic impacts and thus needs to undergo an EIA. The EIA is required to be

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submitted to the concerned environmental protection agency (EPA) prior to start of construction work. However, there is no legal requirement for SEA of policies, plans and programmes in the country till now. The Act also contains provisions for imposing fine in case of non-compliance with section 12 and other specified clauses of the Act and any of the subsequent rules and regulations. The fine may extend up to one million rupees (US$ 11905) (1 US$ = 84 Rupees), with an additional fine extendable up to one hundred thousand rupees (US$ 1190) per day during which contravention continues. These amounts of fine are much higher as compared to the fines on violating other laws in the country. Under this Act, the concerned EPA is bound to a make decision about the fate of EIA within a period of four months. If no decision or objection is communicated within the specified time period, an application is deemed approved up to the extent that it does not contravene with the provisions of the Act. Section 22 provides for appeal against any order by the federal or provincial EPA under any provision of the Act, to the environmental protection tribunal within 30 days after the date of the order. The environmental protection tribunals are the `final fact finding authority' with regard to cases and issues pertaining to the environment as a whole (GoP, 2006). For this purpose, four tribunals were created in all the provinces of the country each headed by a chairperson with two technical members and one legal member (GoP, 2006). But unfortunately, most of these tribunals remain non-functional because of no appointment of its members (GoP, 2006). At the time of writing this thesis, only the environmental protection tribunal of Lahore was functional. In order to facilitate project proponents and the implementing agencies, the Pakistan environmental assessment package was also formulated during the year 1997 (GoP, 1997d). The package includes guidelines for: a) preparation and review of environmental reports; b) public consultation; c) sensitive and critical areas; and d) specific developmental sectors, for example, major road, industrial estates, oil and gas exploration etc.

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The package also includes sectoral guidelines for 7 important types of mega development projects like industrial estates, major roads etc. But unfortunately, these guidelines are not fully practiced, as just availability is not sufficient to ensure good practice, other things are also needed in the system (Fuller, 1999). Albeit, the guidelines are primarily based on the guidelines of Asian Development Bank and World Bank, the official stance is that these have been formulated keeping in view the local circumstances. Later in the year 2000, Review of Initial Environmental Examination (IEE)/EIA regulations were promulgated. These contained mandatory requirements and procedures for the public hearing, review of environmental assessment reports along with provisions for the monitoring (GoP, 2000). It is important to note that the guidelines as well as regulations for EIA are very detailed and quite comprehensive in nature as compared with such guidelines and regulations in other countries like Sri Lanka, India, Bangladesh and Egypt (Zubair, 2001; Paliwal, 2006; Momtaz, 2002; Ahmad and Wood, 2002). 5.2 EIA Administration

In Pakistan, separate ministries of environment have been created both at federal and provincial levels. The Prime Minister of the country chairs the Pakistan Environmental Protection Council at the federal level. This council consists of 40 members out of which at least 20 should be non-official members representing various sectors of the community. The council has been established with the view to approve and ensure implementation of National Environmental Policies and National Environmental Quality Standards (NEQSs) etc. Primary responsibility for the EIA process in the country is vested in the Pak-EPA at the federal level and provincial EPAs at provincial level. It may be noted that the federal EPA works under the administrative control of the Ministry of Environment. Some of provincial EPAs are under the administrative control of their respective Environment Protection Departments and others under various Ministries. Figure 5.1 indicates the jurisdiction of EPAs at the federal and provincial levels. The four provincial agencies (Punjab-EPA, Sindh EPA, NWFP-EPA, Baluchistan-EPA) were created during different years from 1987 onwards. The Pak-EPA has delegated 94

powers to the provincial EPAs for implementing the requirements of EIA and other provisions of the PEPA 1997. Like Pak-EPA, every provincial EPA has separate directorate of EIA which is responsible to process the EIA of both private and public sector development projects.

Figure 5.1 Jurisdictions of Competent Authorities for EIA Jurisdiction of Competent Authorities

Federal Level Projects in Federal Area; Trans-country projects; Trans-province projects Military projects

Provincial Level All other projects including concerned trans-province projects

EPA IEE's for private projects, and EIA's for private & public projects

P&D IEE's for public projects

P & D's IEE's for public projects

EPAs IEE's for private projects, and EIA's for private & public projects

Adapted from: GoP (1997d)

At the federal level, Pak-EPA is the competent authority (with other responsibilities as well) to process the EIAs of all the projects in federal area including military projects, and projects with trans-country and trans-province impacts. But the responsibility of processing IEE of public sector projects is vested in the Planning and Development Department (P & DD) of the federal government. The same jurisdictions of responsibilities also exist at provincial level with the exception of military projects possibly having trans-country impacts. It is also pertinent to mention here that the responsibility of processing EIAs also include post decision implementation and monitoring.

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Whilst building institutional capacity is considered as a mean to enhance the management and efficacy of EIA (Clark, 1999, p.49), Pakistan's administrative set up is severely lacking in institutional capacity. Interviews with concerned officials revealed that the EIA directorates at provincial level are facing a severe shortage of staff with expertise in EIA. The number of staff dedicated to EIA processing in each EPA ranges from 4 to 8 officials belonging to various professional backgrounds. Specifically dedicated field staff for monitoring of impacts is negligible as compared to what is actually required. Only 1 to 2 field inspectors are appointed at district level along with a district officer. In case of metropolitan cities like Lahore, which is having 9 towns within its District Government, there is only one district and one deputy district officer in addition to a field inspector for each town. Similarly, 3 out of 4 of environmental tribunals mostly remain non-functional because of a failure to appoint its members (GoP, 2006). How well the EPAs are discharging their duties regarding various stages of the EIA process have been discussed in the relevant sections of this chapter. 5.2.1 Interagency Coordination Interagency coordination is crucial for an effective EIA system, as environmental impacts of development projects are interrelated with other development sectors and may affect the policies and programmes of other government departments or agencies (GoP, 1997e). But interviews with consultants and officials of the sectoral authorities suggest that generally informal or weak coordination exists among the proponents/ consultants, the EPAs, and other agencies/line departments. Proponents and consultants least bother to approach concerned agencies/departments for identifying issues during preparation of EIA reports. Rather, EIA related guidelines and regulations are reproduced in the reports. Although, comments of the concerned officials of other government departments/agencies are sought by the EPAs, those agencies/departments or even financial institutions do not wait for environmental clearance before extending their services. For instance, loans, electricity, gas and water connections are needed to start construction of a development project. If a proponent gets theses connections and the construction of 96

the project is started, the EIA becomes just a legal formality. Such inadequacies due to lack of coordination among government agencies also exist in EIA regimes of other developing countries (Ahmad and Wood, 2002; Wood, 2003). 5.3 EIA Decision Making and Approval Process

Figure 5.2 shows an outline of the EIA decision making and approval process in Pakistan. For public works, the responsibility for IEE management and review as well as granting or refusing environmental approval, is vested in the Planning and Development (P & D) Departments at the Federal and Provincial levels. The P & D Departments are also responsible for economic and development planning. If an EIA is required for a public sector development project, then consultant is appointed and EIA is submitted to EPA for issuance of no objection certificate (NOC). For private projects, after screening by concerned EPA the proponent, if so required, is directed to submit an EIA. Whilst it is mandatory under section 12 of PEPA 1997 to submit either an IEE or an EIA prior to commencement of the construction, in practice, EIA is undertaken as a result of repeated requests by the concerned EPA after the start of construction work. This usually occurs during public sector development initiatives and even in some private projects. The very reasons behind preparation and approval of EIA after the initiation of public sector projects is the role of P & Ds in screening and "political pressure to expedient EIA clearances" (World Bank, 2006, p.35). Due to such reasons EIA reports are sometimes submitted to the P & D for economic approval of projects before seeking EIA clearance from the concerned EPA. On the other hand, the Executive Committee of National Economic Council (ECNEC) of the Government of Pakistan on 27th July, 2004 decided that: "In case of development projects [public sector] having environmental implications, an environmental impact assessment (EIA) report should invariably be submitted along with the project document at the time of getting approval" (GoP, 2004). During the year after the above quoted decision, ECNEC approved several projects, most of which were subjected to EIA. But the EIA reports were not approved by the concerned EPA prior to ECNECs economic sanctioning of projects. Co-ordination of the EIA procedure and the project cycle has also been said to be weak in other Asian countries (Werner, 1992). 97

Figure 5.2 Approval Process for EIA of Private and Public Sector Development Projects in Pakistan

Preparation of technical and financial feasibility & procurement of land

CDWP & ECNEC

Screening by EPA/ proponent dept.

No EIA required

Submission of PC-1 to P & D

EIA Required

Preparation of ToR by proponent & consultant

Proponent Deptt.

Discretionary consultations with direct affectees

EIA studies and preparation of EIA report/EIS

The EIA report/ EIS is incomplete Submission of EIA report to concerned EPA

Preliminary scrutiny of EIA report/ EIS

The EIA report/ EIS is complete

Site visit/inspection by EPAs field staff in collaboration with proponent

Comments by concerned depts. & NGOs

Public hearing by EPA officials in collaboration with proponent

Response to public comments by govt. depts. & NGOs

Final review by EIA review committee of EPA

Environmental clearance/ Conditional approval

N.B.

Represents stages for public sector projects Represents common stages for both public and private sector's projects Source: Based on GoP (1997c); Nadeem and Hameed (2006a)

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The number of EIA reports submitted to EPAs in the country reached 29 during the year 2004 compared to just 12 in the previous year. This number continued to rise at a gradual pace during the next two years but increased dramatically to 100 during 2007, perhaps due to unprecedented inflow of foreign aid and resultant increase in development projects. In total, 347 EIA reports were produced in Pakistan during the years 2000 to 2008, i.e. 38 reports per annum as shown in Table 5.1. According to an official of the Punjab EPA, all this happened as a result of a writ petition by a resident of Gulberg Town, Lahore against the social and environmental impacts of a multistorey commercial plaza adjacent to residential area.

Table 5.1 Number of EIA Reports Submitted to EPAs in the Country Punjab EPA 0 1 0 4 15 16 19 71 76 202 Sindh EPA 3 3 11 7 6 12 8 15 11 76 Balochistan EPA 1 1 0 0 1 4 3 4 3 17 NWFP EPA 1 1 0 0 5 4 3 5 14 33 Pak EPA 1 0 0 1 2 0 3 5 7 19 Yearwise Total 6 6 11 12 29 36 36 100 111 347

Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 Total

Source: Federal and Provincial EPAs, 2008

EPA's record showed that several cases were still in process. Those were in fact EIAs of such projects for which proponents could not yet satisfy the concerned EPA and the stakeholders. It therefore indicates that some sort of quality checks are there which also shows a ray of hope for further improvement. Although the rise in the number of EIA reports submitted to EPAs is also an indication of increased pace of development activities in the country. Yet the relationship between the number of EIAs submitted and the number of new development projects requiring EIA under the law is still not known. Another but important reason behind the increase in the number of submitted EIA cases is the role of media and directions of the Supreme Court of Pakistan to all

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the concerned Government departments and agencies for compliance of EIA requirements. 5.3.1 Screening For the purpose of environmental screening, the Pak-EPA has divided development projects into two schedules (GoP, 2000). Schedule I requires IEE of projects in the major categories of transport infrastructure, processing industries, agriculture, livestock and fisheries, energy, water management (dams), water supply treatment, waste disposal and urban development. Schedule II requires EIA of projects of almost similar types as indicated in Schedule I, but excluding agriculture, livestock and fisheries. The basis for deciding whether an IEE or EIA required is the cost of the project as well as its size. For instance, a highway project with a total cost of less than 50 million rupees (US$ 0.595 million) (1US$ = 84 Rs.) requires an IEE and a highway project above this cost requires an EIA; a hydro power generation project of less than 50 Mega Watt needs to undergo an IEE or an EIA if above this capacity (GoP, 2000). After initiation of a project by a proponent, the decision whether an EIA is required or not is made by the concerned EPA in case of private sector and by the Planning and Development (P & D) Department or sometimes by the proponent department/agency in case of public sector projects. EPAs generally require that every project whether included in schedule I or II should undergo an IEE. Proponents of the projects not falling in both the schedules are required to give an undertaking that the guidelines and NEQSs shall be fully complied with. Concerned EPAs, however, reserve the right to direct the proponent of a project to file an IEE or EIA, whether or not listed in the schedules. The guidelines suggested that screening schedules shall be revised periodically. Interviews of the academics, consultants, and officials of concerned government departments/agencies, also revealed that there was an urgent need to review the schedules, but no progress has been made to this end. For instance, oil and gas extraction and large housing schemes included in the list of projects requiring an IEE, whereas these should have gone through the EIA process. This is creating difficulty for the EPA officials to convince the proponents, particularly of public sector projects,

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for undertaking EIA studies just on the basis of sub-regulation (2) of regulation 5 of the IEE/EIA Regulations 2000. The sub-regulation (2) gives authority to the Pak-EPA to require EIA of any project which is not included in the schedule II. 5.3.2 Scoping The sectoral guidelines for preparing EIA of projects belonging to various development sectors viz major roads and industrial estates etc, have been prepared to decide the issues to be included in the EIA studies (GoP, 1997d). The responsible EPA provides a typical list of steps for scoping and directs the proponents (if he/she contacts before conducting EIA) for thorough discussion with key stakeholders, assembling available information from concerned departments and agencies, consulting with possible affectees, considering alternatives, and identifying information gaps. Despite suggesting the role of stakeholders in the scoping process, the guidelines put the responsibly of formulating terms of reference on the proponents. Nevertheless, they rarely involve stakeholders during scoping. Hence, the areas of concerns of affectees and concerned government department are not truly reflected in the EIA report. 5.3.3 Review of EIA Reports

The EIA review stage helps to ensure that information on the environmental impacts of an action is adequate before it is used as a basis for decision making (Fuller, 1999). The clauses 9 and 10 of the IEE/EIA Regulations 2000 stipulate that the concerned EPA is responsible to inform the proponent about adequacy of the EIA report or confirm its completeness within 10 days of receipt. The EPA is legally bound to review EIA report in a period of 90 days, once it confirms the adequacy of the report or admits it for this purpose. The review criteria as suggested in the guidelines are given in Table 5.2. The official EIA review criteria are more inclined towards quantitative review rather than a qualitative one. According to EIA guidelines (GoP, 1997e), the review is normally undertaken by assessment officer(s) within a responsible EPA and then presented before an in-house committee which may include independent experts, if so

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required. Interviews with EIA consultants suggest that, in practice, the review is always subjective in nature and depends primarily upon the personal judgment of the concerned officials and affiliations of the consultants.

Table 5.2 1. Criteria for Evaluating EIA Reports in Pakistan

Does the executive summary present significant impacts, cumulative effects of impacts, mitigation measures, and requirements for monitoring and supervision? 2. Is the project description complete and at least includes aspects which can affect the environment? 3. Whether project alternatives are discussed? 4. Are the baseline conditions described adequately in an easily understandable manner with comments on quality of data? 5. Are significant impacts predicted and evaluated with indication of potential impacts expected at scoping stage but not found at this stage? 6. Are the mitigation measures to control adverse impacts and enhance project benefits proposed? 7. Are the institutional arrangements for implementing mitigation measures defined in the form of Environmental Management Plan (EMP)? 8. Is the cost of implementing all recommendations adequately budgeted in the cost estimate? 9. Is the monitoring program described and commitment made with reasons for and detail of the cost of carrying out monitoring activities? 10. Are the directly affected and interested people consulted during the EIA studies? 11. Is an overview of the issues raised by the local people given with indication of how their concerns have been dealt with/incorporated in the EIA report? 12. Is the EIA report written in clear language without excessively using technical terms in a manner understandable to a common man? Based on: GoP (1997e); Nadeem and Hameed (2006b)

However, the study of EIA case files and interviews of concerned officials revealed that some members of the review committee also belong to various stakeholders like, government departments or sectoral agencies concerned with the project, educational and research institutions, NGOs and editors/reporters of some leading newspapers of the country. The proponents are then asked to send detailed reply on the comments of experts before holding public hearing. In some cases, the comments of EIA experts and proponent's response have been presented during public hearings. A critical review of randomly selected EIA reports of industrial and road construction projects revealed that their quality is generally poor and inadequate in many respects (Nadeem and Hameed, 2006b).

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The review identified following key shortcomings (Nadeem and Hameed, 2006b): o o o o o o An insufficient allocation of time and money by the proponents for EIA Absence of baseline data Little experience and inadequate technical resources of EIA consultants Scant involvement of the stakeholders during preparation of EIA reports Heavy reliance on qualitative analysis of impacts significance Inadequate consideration of project alternatives

Although legislation and guidelines do exist and, except a few weaknesses, these provide a sound basis for promoting quality in EIA. The problems not only lie with the limited institutional capacity and experience of consultants but also with the limited allocation of resources to EIA both by the responsible authorities and proponents. Project proponent, be it a public sector organization or a private party, is not willing to allocate sufficient resources both in terms of time and finances required for conducting a good quality EIA. Weak coordination among various parties involved in EIA is also contributing towards poor quality of EIA reports. As mentioned in the previous section, the prospective affectees and other stakeholders are not involved in scoping and identifying likely impacts during the EIA preparation but only at the time of public hearing. Even the magnitude of likely impacts is assessed mainly using qualitative methods. Furthermore, it is a common practice that the project alternatives are discussed as a formality in the EIA reports. No detailed feasibility studies or environmental studies are conducted for alternatives. Mainly, the alternatives are rejected indicating high cost, and using government policies and secondary data against the alternatives. Thus, alternative project locations and designs are given inadequate consideration. Unfortunately, no efforts are made to improve the quality of EIA reports or learn lessons after conducting post EIA monitoring. For this purpose, Glasson, et al. (1999) suggested that the impacts which were predicted in EIA report should be compared with the impacts arising while the projects start operation. This kind of deficiencies can also be noted in the EIA systems of several other developing countries (See for example, Glasson et al., 1999; Wood, 2003).

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5.3.4 Public Participation Public participation or consultation in the form of public hearing is mandatory under section 12(3) of PEPA 1997 and section 10 of IEE/EIA Regulations, 2000 during the EIA review process in Pakistan. A separate module of guidelines for public consultation has been prepared by the Pak-EPA in the light of the World Bank `s Participation Sourcebook, 1995. The guidelines suggest that project proponents should hold comprehensive discussions with the affected public and adequately incorporate their genuine concerns in the project design and mitigation measures to avoid adverse effects. While in comparatively better EIA systems, like those of the Netherlands and Western Australia, public participation is obligatory during screening and scoping (Wood, 1999), there is no compulsion on the proponents in Pakistan to involve the concerned public during EIA preparation. Some proponents (particularly of foreign funded public sector projects), however, consult affectees mainly for collecting socio-economic baseline data and occasionally for obtaining their views on the project. Stakeholders are given 30 days, following a notice published in two national daily news papers, for submitting written comments before the public hearing. The venue for public hearing is normally a high class hotel in the city or office of the concerned EPA or public sector proponent which are often inaccessible by the directly affected indigenous people who are living in remote areas (Nadeem and Hameed, 2006c). In addition, stakeholders are not informed about how their concerns have been incorporated into the EIA report and final decision. Such inadequacies pertaining to public participation in EIA also prevail in some of the other developing countries, for instance, India, Bangladesh, Sri Lanka, Thailand, Indonesia and Malaysia etc. (Paliwal, 2006; Momtaz, 2002; Zubair, 2001; Boyle, 1998). In spite of all the odds, few instances of environmental activism also exist in this country. The cases of Karachi Elevated Expressway Project, Lahore Canal Bank Road Remodelling Project, Lahore Ring Road Project etc., as discussed in statement of the problem in Chapter 1, indicate that awareness about the environmental impacts of mega projects is rising particularly among those living in the urban areas of Pakistan. This awareness is leading to active participation in the public hearings and follow-up of the outcome of EIA related decisions. 104

According to a news report, the alignment (as in the approved EIA report) of the Karachi Elevated Expressway Project has been withdrawn recently by the proponent (City District Government, Karachi) due to legal and financial constraints in the land acquisition. The route alignment suggested by the stakeholders during public hearing was being pursued (Daily Times, 2007). Similarly, some of the environmental NGOs and stakeholders of the Lahore Canal Bank Road Remodelling Project have filed a petition in the Lahore High Court against the proposed project and issuance of environmental approval by the Punjab EPA. Likewise, as a result of protest by the affectees, a section of Lahore Ring Road Project, proposed to traverse through Gulshan-e-Ravi Housing Scheme, has been withdrawn. The proponent department (Communication and Works Department of the Government of Punjab) has asked its consultants to design the said section through new route alignment avoiding Gulshane-Ravi (The News, 2006). Finally, the New Murree Project is still pending due to the Supreme Court's ruling against its likely environmental impacts. Keeping in view the above scenario, it can be stated that although the actual practice of EIA has yet to be evolved into substantial public participation, still there are some encouraging examples. These, in fact, call for a thorough investigation to determine under what conditions the public involvement in EIA is effective, and that up to what extent the public participation in EIA is actually influencing decisions. 5.3.5 Environmental Management Plan, Mitigation and Monitoring of Impacts

Before commencing the operation of a project, submission of environmental management plan (EMP) is mandatory under section 14 of IEE/EIA Regulations 2000. A non-mandatory but quite comprehensive format for EMP has been furnished in the sub-section 4.3 of the guidelines for the preparation and review of environmental reports, 1997. The EMP is required to present mitigation measures for the life cycle of the proposed project. Procedures to ensure regular monitoring and effectiveness of implementing mitigation measures should also be included in it. In practice, EMP is made part of EIA reports and it is also reviewed by the concerned EPA.

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However, every approval of an EIA is subjected to the condition that proposed mitigation measures shall be adopted strictly in accordance with the EIA. This condition is required to be verified by the responsible EPA at the time of request by the proponent for written confirmation of compliance. Mitigation measures can be incorporated in the development decision through many ways. For instance, project alternatives, modification in project design, improved monitoring and management, monetary compensation to affectees, and relocation or rehabilitation of affected amenities and the people (GoP, 1997d). But interviews with officials portray different picture by suggesting that after obtaining environmental approval, the proponents least bother to adopt the mitigation measures and those who do, rarely maintain the equipment so installed for mitigation of impacts. Despite a legal requirement to be included in the EMP, monitoring mostly takes place in response to complaints. In many cases, EMPs in the EIA reports indicated self monitoring and reporting system. However, such plans are not generally implemented by the proponents. This is clearly exemplified, for instance, by the case of a poultry feed industry in Punjab Province, the environmental approval of which has been withdrawn as a result of complaints from surrounding community against nuisance resulting from non-compliance with National Environmental Quality Standards (NEQSs). The major difficulty faced by EPAs to effectively carry out monitoring activities is limited institutional capacity, arising mainly from insufficiency in numbers of suitably qualified and experienced personnel and monitoring equipment, as has generally been the case in EPAs in other developing countries (Paliwal, 2006; Ahmad and Wood, 2002; Momtaz, 2002; Zubair, 2001; Werner, 1992). The regimes where mitigation measures are being implemented and monitoring of impacts is also being done more effectively (for instance, the Netherlands and Canada), the competent authorities are well equipped with technically trained staff and monitoring equipment (Glasson et al., 1999).

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5.4

Overall Weaknesses and Opportunities in respect of EIA System in Pakistan

The EIA system of Pakistan is working under a reasonably sturdy legal cover supplemented with a comprehensive package of EIA guidelines. Although EIA practice is gradually advancing, the analysis of the EIA system suggests some weaknesses pertaining to institutional set up, enforcement of legal requirements and actual practice. Overall influence of EIA on decision making is weak due to various reasons. These include: meagre technical and financial resources, outdated screening lists, no involvement of EPA in scoping, weak coordination, subjective review, weak public participation and no proper monitoring of impacts arising during operation of projects subjected to EIA. However, the encouraging role of the federal government and judiciary to support EIA, inviting expert's comments on EIA reports of publicly important projects as well as role of print media and NGOs in disseminating and supporting public concerns are the opportunities which can strengthen EIA system in the country.

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