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,
Keywords:
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,
Pakistan
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,

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

0195-9255/$ – see front matter © 2008 Elsevier Inc. All rights reserved.
doi:10.1016/j.eiar.2008.02.003
 O. Nadeem, R. Hameed / Environmental Impact Assessment Review 28 (2008) 562–571
International experiences indicate that political factors
have been the driving forces behind the introduction and
practice of EIA (Thomas, 2001). Cultural influences and
economic conditions have been said to have significant
bearing on the form of an EIA system. Generally speaking, EIA
appears to be most effective where environmental values are
integrated into a nation's culture and public law and policy
(Thomas, 2001). Though relevant literature suggest that, the
shortcomings of contemporary EIA practice could possibly be
overcome. This may involve enhancing the institutional
capacity to provide clear guidelines, initiating the assess-
ment process at early stages of the project, adequately
involving stakeholders, systematically reviewing EIA quality
and monitoring its implementation (Ahmad and Wood,
2002; Sadler, 1996). Nonetheless, “contribution made by
EIA, both to consent decisions and to project design, is
generally moderate rather than substantial” (Jay et al., 2007,
p291).
This paper evaluates the EIA system of Pakistan. It is based
on:
(1) literature review on evaluation of EIA systems
(2) document analysis including legislative provisions, EIA
guidelines and procedures in Pakistan
(3) secondary data including number and approval status
of EIA reports in the country, and
(4) information obtained through interviews with officials
of federal and provincial EPAs in the country, utility
services agencies/line departments, banks, proponents,
EIA consultants and experts from various backgrounds
(see Appendix A).
The next section introduces evaluation criteria used for
this paper. This is followed by a brief account of the evolution
and process of EIA in Pakistan. Legislative provisions and
guidelines are then introduced and an analysis of the per-
formance of the EIA system is provided. Weaknesses and
opportunities for improving EIA procedures and practice are
identified in the discussion. Finally, conclusions and recom-
mendations are presented in the light of evaluation results.
2. Evaluation criteria
The evaluation criteria methodology for analysis of the EIA
system of Pakistan are taken from Ahmad and Wood (2002),
Wood (2003) and Fuller (1999). These criteria consist of aims
and stages of EIA (screening, scoping, review of EIA reports,
public participation, decision making, mitigation of impacts
and monitoring). Generally speaking, “[t]he focus of the
criteria is on the requirements and operation of the EIA
process” (Wood, 2003, p12). Evaluation of legislative provi-
sions, guidelines and institutional set up for EIA has been
included to provide a comprehensive picture of the system.
The identification of the attitudes and opinions of those
involved in the process, i.e. proponents, consultants and
concerned officials also provides valuable input for the
evaluation, as has been suggested by Bartlett and Baber
(1989). Table 1 presents the evaluation criteria.
Ahmad and Wood (2002) and Wood (2003) used these
criteria to evaluate performance of EIA systems in some of the
developing and developed countries. Wood (2003, p13) also
suggested that “these criteria can be employed to judge the
563
Table 1
List of evaluation criteria used to analyse the EIA system of Pakistan
1) Legislative provisions for EIA
• Legal provisions
• Legal provisions for appeal by the proponent or stakeholders against
decisions
• Legal specification of time limits for approval and appeal
• Legal provisions for SEA
2) Administrative set up for EIA
• Competent authority for EIA screening and approval
• EIA review body
• Specification of responsibilities of sectoral authorities in the EIA process
• Level of coordination with other planning and development
agencies/departments
3) EIA process and practice
• Specification of screening categories
• Screening approach
• Scoping approach
• Requirement for consideration of alternatives
• Specification of EIA report contents
• Systematic approach for the review of EIA report
• Public participation in the EIA process
• Systematic approach for decision making and approval
• Specified requirement for environmental management plans
• Specified requirement for mitigation of impacts
• Specified requirement for monitoring of impacts
• SEA Experience
Source: Adapted from Wood (2003); Ahmad and Wood (2002); Fuller (1999).
effectiveness of any EIA system to enable an international
comparison to be made between systems”.
3. Evaluation of the EIA system of Pakistan
In this section, the EIA system of Pakistan is evaluated. The
performance of the major components of the EIA process and
practice are discussed in detail. Legislative provisions, guide-
lines and results of the evaluation are summarised in Table 2.
3.1. Legislative provisions for EIA
The Pakistan Environmental Protection Ordinance (PEPO) of
1983 first introduced EIA in the country (GoP, 1983). Before
conducting an EIA, the Ordinance required that an initial
environmental examination (IEE) of projects to be carried out to
assess the need and scope for an EIA. The PEPO defines IEE as,
“Initial environmental examination means preliminary
environmental review of the reasonably foreseeable quali-
tative and quantitative impacts on the environment of a
proposed project to determine whether it is likely to cause
an adverse environmental effect for requiring preparation of
an environmental impact assessment” (GoP, 1983).
Thus, IEE was supposed to supplement the screening and
scoping mechanisms. Later on, the ordinance was replaced by
the Pakistan Environmental Protection Act (PEPA) 1997 (GoP,
1997a). During the same year, an environmental assessment
package was also released (GoP, 1997b). The package
comprises various sets of guidelines, for:
(a) preparation and review of environmental reports;
(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
No.
(1) Legislative provisions for EIA
1.1 Legal provisions Enabling legislation: Federal Govt.'s PEPA, 1997 (section 12); Specific Regulations: IEE/EIA
Regulations-2000
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
approval
2.2 EIA review body
2.3 Specification of responsibilities of sectoral
authorities in the EIA process
2.4 Level of coordination with other planning and
development agencies/departments
Pak-EPA at federal level; Provincial EPAs at provincial level
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
experts
EIAs are submitted to EPAs for private projects and through P&Ds for public sector projects as required
under project Schedule II. Other sectoral authorities are invited for comments on concerned EIA report.
Need stressed in Regulations for interagency coordination at key stages of EIA process but practically
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
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
criteria in Table 1, except the formal requirements for SEA.
Though, the overall practice of EIA in Pakistan shows that
implementation of relevant laws and guidelines is limited.
3.2. Administrative set up for EIA
The responsibility for implementing the 1997 PEPA and
2000 IEE/EIA regulations lies with the Pakistan Environmental
Protection Agency (Pak-EPA) within Islamabad and other areas
under Federal Government control. Provincial Environmental
Protection Agencies (EPAs) are responsible within their pro-
vincial jurisdiction. The four provincial agencies (Punjab-EPA,
Sindh EPA, North West Frontier Province (NWFP)-EPA, Baluchi-
stan-EPA) were created during different years from 1987
onwards. The responsibility of processing IEE of public sector
projects is vested in the Planning and Development Depart-
ment of the Federal government. The same jurisdiction of
responsibilities exists at the provincial level with the exception
of military projects and trans-country impact projects.
While institutional capacity building is increasingly seen
as one of the means for “improving the management of EIA
systems and enhancing the effectiveness of practices” (Clark,
1999, p49), Pakistan's administrative set up is severely lacking
in institutional capacity. Interviews with concerned officials
(see List after references) reveal 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
filed staff for monitoring of impacts is negligible as compared
to that actually required. Only 1 to 2 filed inspectors are
appointed at district (borough) 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).
3.2.1. Interagency coordination
Interagency coordination is crucial for an effective EIA
system, since environmental issues, in their complexity and
variety, are often inter-sectoral or regional (GoP, 1997c). But
the EIA practice, interviews with consultants and officials of
the sectoral authorities (see List after references) suggest that
generally informal or weak coordination exists among the
proponents/consultants, EPAs and other agencies/line depart-
ments. Proponents/consultants least bother to consult con-
cerned agencies/departments to identify issues during
preparation of EIA reports. Brief discussion on the laws and
policies of agencies concerned with the project is considered
sufficient for the EIA reports.
The Environmental Protection Agencies (EPAs) invite
concerned agency/department for submitting their comments
and participating in the public hearing of the projects. But the
utility services providing agencies like Water and Power
Development Authority (WAPDA), Sui Northern Gas Pipelines
(SNGPL), Water and Sanitation Agency (WASA) and even
banks are not bound to check EIA clearance prior to extending
their services. This often results in the start of construction and
even operation of the projects, with connections of all the
565
utility services, well before EIA approval. And once the
construction work of a project takes off, the role of EIA
becomes just a ritual to fulfil legal requirement. Inadequate
institutional capacity, lack of training and weak coordination
among line departments and agencies have also been
identified as impediments to effective EIA in other developing
countries (Ahmad and Wood, 2002; Wood, 2003).
3.3. EIA decision making and approval process
The EIA decision making and approval process in Pakistan is
presented in Fig. 1. Whereas, it is mandatory under section 12 of
Pakistan Environment Protection Act (PEPA) 1997 to submit
either an IEE or an EIA, prior to commencement of the con-
struction. In practice, EIA is undertaken as a result of repeated
requests by the concerned EPA, usually after the start of
construction work. This happens particularly in case of public
sector projects and in some cases of private projects too. The
very reasons behind preparation and approval of EIA after the
initiation of public sector projects is the role of Planning and
Development Departments (P&Ds) in screening and “political
pressure to expedient EIA clearances” (World Bank, 2006, p35).
Taking advantage of this situation, proponent departments
sometimes submit un-approved EIA reports directly to P&D for
approval of funds by the competent authority.
However, the authority responsible for granting economic
approval to the mega development projects of public sector,
i.e. 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).
Following the ECNECs decision, it appears that the number
of EIA reports produced in the country increased dramatically
from 12 in the year 2003 to 29 (i.e. 242%) in the year 2004. But
this number could not cross 36 during the following years.
The total number of EIA reports produced in the country from
the year 2000 to 2006 is 136, i.e. approximately 20 reports per
annum. During subsequent years, ECNEC approved several
projects, most of which were subjected to EIA. But the EIA
reports of such projects were not approved by the concerned
Environment Protection Agency prior to economic approval
by the ECNEC. Hence, the usefulness of such EIAs can be
questioned. This situation can lead to irreversible decisions
regarding site selection and sometimes severe environmental
consequences. This is not only the case in Pakistan. Coordina-
tion of the EIA procedure and the project cycle has been said
to be weak in other Asian countries, as well (Werner, 1992). In
cases where EIA is carried out, its effect on decision making,
like in many jurisdictions internationally, suggests that
projects are not often rejected or withdrawn prior to approval
(Sadler, 1996).
3.3.1. Screening
For the purpose of environmental screening, the Pakistan
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
projects into two schedules (GoP, 2000). Schedule I enlists
projects in broader categories like agriculture, livestock and
fisheries, energy, manufacturing and processing, transport,
water management (dams), water supply treatment, waste
disposal and urban development and others, to require an
initial environmental examination (IEE). Schedule II enlists
projects, in roughly the same broad categories as that of
Schedule I, excluding agriculture, livestock and fisheries, but
with addition of projects located in environmentally sensitive
areas, requiring an EIA. The project cost and capacity with
respect to every development sector are the bases for
determining the requirement of an IEE or EIA. For instance,
a highway project with a total cost of less than 50 million
rupees (0.806 million US$) requires an IEE and a highway
project above this cost requires an EIA; a hydro power
generation project of less than 50 MW (MG) needs to undergo
an IEE. An EIA is required if it is above this generation capacity
(GoP, 2000).
It is clearly indicated in the guidelines relating to review
and approval of environmental assessments that revision of
categorization of projects in schedules I and II is an ongoing
process. Interviews with EIA consultants and discussions with
academics (see List after references) also suggest that there is
an immense need to review the schedules, but no progress has
been made to this end. Oil and gas extraction and large
housing schemes' projects are included in the list of projects
requiring an IEE not EIA, while these should have gone
through the EIA process. This is creating difficulty for the EPA
officials to convince the proponents of such projects, particu-
larly from the public sector, for undertaking EIA studies.
3.3.2. Scoping
The basis of determining the scope of an initial environ-
mental examination (IEE) or EIA in Pakistan derives from the
sectoral guidelines. The sectoral guidelines are available for
projects belonging to various development sectors e.g.
industrial estates, major roads etc. (GoP, 1997b). The guide-
lines for preparation of environmental reports also suggest for
thorough discussion with key stakeholders, assembling
available information from concerned departments and
agencies, consulting with possible affectees, considering
alternatives and identifying information gaps (GoP, 1997c).
Although, roles of stakeholders in the scoping process have
been identified, the primary responsibility of developing
terms of reference (TOR) lies with the proponents.
It is common practice in Pakistan that proponents rarely
involve stakeholders during scoping. However, scoping is not
a mandatory requirement like it is in many other jurisdictions
in East Asia, for example, China, Thailand and India (Briffett,
1999). Therefore, areas of concerns of affectees and concerned
government department are not truly reflected in the EIA
reports. This is also because the EPAs have just a suggestive
role but no responsibility for preparing terms of reference
(ToR) for scoping.
3.3.3. Reviewing the quality 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). It is
important to carry out this stage, as effectively and efficiently
as possible (Ahmad and Wood, 2002). The clauses 9 and 10 of
567
the IEE/EIA Regulations 2000 stipulate that the responsible
Environment Protection Agency (EPA) shall advise the
proponent of the adequacy of the EIA report or confirmation
of completeness within 10 days of receipt. The responsible
EPA is also required to complete the review process within
90 days after confirmation of the adequacy of the EIA report.
Interviews with consultants (see List after references)
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.
However, the study of EIA case files and interviews of EPA
officials (see List after references) reveal that some members
of the review committee also belong to various stakeholders.
Often they are government departments or sectoral agencies
concerned with the project, educational and research institu-
tions, Non-Governmental Organizations (NGOs) and editors/
reporters of some leading newspapers of the country. The
comments of the concerned departments and experts are
actually sought by all EPAs and the proponents are asked to
respond prior to formal 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 projects located in Punjab, the biggest province of
Pakistan, revealed that their quality is generally poor and
inadequate in many respects (Nadeem and Hameed (2006b).
This review identified the following key shortcomings:
○ An insufficient allocation of time and money by the
proponents for conducting 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
Such inadequacies regarding EIA reports also exist in many
other EIA regimes and have been identified and discussed
elsewhere (see for example, Glasson et al., 1999; Wood, 2003).
Over and above, it is unfortunate to note that there is no
practice of auditing EIA quality. It could be done through
matching the impacts which were predicted in EIA with those
actually arising during construction and operation phases of
the project (Glasson et al., 1999). This may help in improving
the EIA quality in future.
3.3.4. Public participation
Public participation or consultation in the form of public
hearings is mandatory only during the EIA review process in
Pakistan. Further, in comparatively well developed EIA
systems like those of the Netherlands and Western Australia,
public participation is obligatory during screening and
scoping (Wood, 2003). But there is no compulsion on the
proponents in case of 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 project.
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
comments before the public hearing. The venue for public
hearing is normally a high class hotel in the city or office of the
concerned Environment Protection Agency or public sector
proponent. Such venues are often inaccessible by the directly
affected indigenous people who are living in remote areas. 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. (Boyle, 1998; Momtaz, 2002; Paliwal, 2006;
Zubair, 2001). However, Pakistan is no exception.
Despite all of the above, there are some examples of public
sector initiatives during which stakeholders (affectees, NGOs,
print media, EIA and other experts) played very active roles.
Consequently, the competent authority had to pend the
approval of EIA till the proponent gave a satisfactory response
to the objections of the stakeholders or re-consider project
alternatives. The Lahore Canal Road Widening and Lahore
Ring Road projects are classic examples of this sort (Kashif
and Dogar, 2007; The News, 2006). In a few cases (for
example, New Murree Tourist Resort and Islamabad Chalets
Projects) as a result of media campaigns and suo motu notices
by the Supreme Court of Pakistan, development works of the
projects have been stopped. Yet, in another case (National
Highways Rehabilitation Project) according to the proponent
and the EIA report, the stakeholders and particularly the
affectees were consulted during scoping, impact identifica-
tion and mitigation stages. The affectees' concerns were
adequately addressed in the EIA report and a grievance
redressal system was developed to compensate them (NHA,
2003). Those examples of active stakeholders' involvement in
the EIA process are quite encouraging given the fact that in
general the actual practice of EIA has yet to evolve into
substantial public participation.
3.3.5. Environmental management plan, mitigation and
monitoring of impacts
Implementation of environmental management plans,
mitigation measures and compliance monitoring are overall
inadequate. Interviews with the concerned officials of Envir-
onment Protection Agencies (see List after references) suggest
that after obtaining EIA approval the proponents least bother
to adopt the mitigation measures and those who do, they do
not maintain the equipment so installed for mitigation of
impacts. Despite a legal requirement, monitoring mostly takes
place in response of complaints. The self-monitoring and
reporting system indicated in the environmental manage-
ment plans (EMPs) are rarely practiced by project proponents.
This is clearly exemplified, for instance, by the case of a poultry
feed industry in Punjab Province, the EIA approval of which
has been withdrawn as a result of complaints from surround-
ing community against nuisance resulting from non-compli-
ance with National Environmental Quality Standards (NEQS).
The major difficulty faced by the 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 equip-
ment, as has generally been the case in EPAs in other
developing countries (Ahmad and Wood, 2002; Momtaz,
2002; Paliwal, 2006; Werner, 1992; Zubair, 2001). 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).
4. Discussion: weaknesses and opportunities of the
Pakistan EIA system
Following paragraphs underpin the weaknesses and
opportunities for rectification of the Pakistan EIA system.
4.1. Sound legislative provisions but weak administrative set up
The legislative provisions and guidelines for EIA in the
country are quite comprehensive. However, a lack of
implementing mandatory requirements for EIA including no
use of powers to impose fines under the Pakistan Environ-
ment Protection Act (PEPA) 1997 is resulting in the develop-
ment and operation of many projects, likely to cause
environmental and socio-economic impacts, without under-
going an EIA. Furthermore, proponents are aware that the
responsible authorities lack the enforcement machinery (Beg,
2004). Thus, projects for which EIA is carried out, it takes
place after procurement of site or even after start of
construction and hence EIA becomes just a formality.
4.2. Weak coordination
Coordination among EIA proponents/consultants, EPAs,
local financial institutions and the line departments is
generally weak. This is leading not only to the inadequate
consideration of concerned departments' views in the EIA
report but also to the start of development works prior to
getting EIA clearance. Also because the financial institutions
and utility services providing agencies are not responsible to
ensure EIA clearance before providing loans and utility
connections. Once the development works take off, the
possibilities of alternatives or modifications in project design
during construction are meagre or none in many cases.
4.3. Few EIAs
The EIA production rate of the country has been
approximately 20 per annum during the last seven years.
Data regarding average time of approval of an EIA are not
available. Some of the EIA reports are not yet approved.
However, this is not an indication that all such projects are
stopped. How many projects for which EIA was required by
law but have been developed during the last seven years
without EIA is also unknown. The investigation of these
aspects may provide useful insights into the causes of delays
as well as the weight given to various types of impacts and to
the public opinion during review.
4.4. Inadequate screening and scoping
The Planning and Development (P&D) Department's author-
ity of screening and processing initial environmental examina-
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
of no or late initiation of EIA studies, if so required under the
law. Being an in-house department for government projects, it
sometimes ignores the requirement of EIA due to political
pressure. No periodical review of the schedule of projects
requiring an EIA is the other cause of delayed or no EIA.
Furthermore, inadequate involvement of stakeholders and the
concerned EPA during scoping is resulting in a thin coverage of
environmental and socio-economic issues in the EIA reports.
4.5. Limited scope of EIA report review
Reviewing of EIA reports is generally process and sub-
stance oriented except some comments on the quality of
impact assessment by the EIA experts in review committees.
This third party involvement in the review can be marked as a
salient feature of the EIA process in Pakistan. Although, an
independent EIA review commission does not exist, more
resources are expected to be allocated by the government to
transform third party involvement in to formal review bodies.
Some anomalies, however, can be found due to lack of
technical capacity and subjective review. Political pressure is
also causing approval of poor quality EIA reports.
4.6. Poor quality of EIA reports
The overall quality of EIA reports is unsatisfactory. The lack
of experience of EIA consultants and approval authorities
along with reluctance on part of the proponents to allocate
sufficient resources are some of the impediments to better
quality EIA. In addition to that, there is no code of conduct for
EIA consultants; not even any requirement of registration. In
many cases, a consultant's role has been limited to highlight
the economic benefits and justify the project for getting
environmental approval.
4.7. Weak public participation
Good guidelines have been provided by the Pakistan
Environment Protection Agency for public consultation. Like
many EIA regimes around the globe, public involvement
during scoping, impact identification and evaluation is non-
mandatory in Pakistan. Taking the advantage, proponents try
to avoid public as much as possible during the preparation of
an EIA report. Where Non-Governmental Organizations
(NGOs), experts and affectees have joined hands, they have
succeeded in denting the shell of weak public participation.
Under what circumstances the reactive public participation
achieves its goals or is effective and how far the mandatory
public hearings are actually influencing the decision making
processes in EIA in the country are yet to be evaluated.
4.8. Inadequate implementation of mitigation measures and
monitoring
The implementation of an environmental management
plan, mitigation measures and post-decision monitoring are
some of the weakest facets of Pakistan's EIA system. These
weaknesses can be explained by the lack of enforcement
machinery and authority of the Environment Protection
Agencies (EPAs). While the project proponents (usually
industrialists and government departments) are highly
569
influential, EPAs are considered among the weakest govern-
ment agencies. Political manifestos, generally speaking, are to
encourage investment in the development sector. There is a
need to transform political will in favour of development but
not at the cost of environment.
5. Conclusions and recommendations
Pakistan is one of the developing countries that has sound
legal provisions for EIA. Furthermore, a comprehensive package
of EIA guidelines exists. While it appears that EIA in Pakistan is
improving steadily, an overall evaluation of the EIA system
reveals several weaknesses, not only in the institutional
framework, but also in implementation and actual practice.
The influence of EIA on decision making is weak, owing to
numerous reasons pertaining to inadequate technical and
financial resources, deficiencies in screening and scoping,
weak coordination, subjective review, ineffective public parti-
cipation and no formal monitoring. Nonetheless, some oppor-
tunities other than the legal basis also exist in the form of
political support of EIA, third party review and role of NGOs and
media in supporting public concerns. Thus, there is a good hope
that the EIA system in Pakistan will strengthen further in near
future. The need is to tap the existing opportunities. It is
suggested that the following measures can help enhance the
effectiveness of the EIA system in Pakistan.
➢ The legal framework for EIA in the country is strong
enough to provide back up for taking stern action against
violators of EIA requirements. It needs a strong political
will and institutional capacity to enforce the 1997 Pakistan
Environment Protection Act. The decision of the Executive
Committee of National Economic Council includes some
political will. The EIA directorates of the EPAs should be
strengthened by giving more administrative powers to
impose fine or seal any project violating EIA requirements.
In this regards, adequately qualified staff and equipment
particularly required for inspection and enforcement are
some of the pre-requisites.
➢ Good coordination among proponents/consultants, financial
institutions, revenue/land registration department, planning
and building control and utility services providing agencies
can play a pivotal role in consideration of their concerns early
in the EIA process. It would also help in ensuring that no
project, likely to have adverse environmental impacts could
be launched before securing EIA clearance. This can be
achieved by making amendments in the 1997 PEPA to assign
responsibility to all the aforementioned government depart-
ments/agencies to coordinate with the concerned Environ-
ment Protection Agency before extending any services to the
projects requiring an EIA under the Act.
➢ The Planning and Development Department should send a
copy of the IEE of projects to the concerned EPA for decision
on whether an EIA is required or not. The revision of screening
lists (schedules of projects requiring an IEE/EIA) has been due
for many years. The Pakistan Environment Protection Agency
should initiate consultations with all the concerned govern-
ment departments/agencies, EIA experts and academia to
update the lists. EPAs should ensure, by giving significant
weight during review, that the proponent has consulted
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
Sri Lanka (Zubair, 2001). This can help ensure an early consi-
deration of major areas of concern by the directly affected
public and the concerned government departments.
➢ Review should, however, be done by independent EIA
review bodies at different levels of decision making. Third
party evaluation is already done at individual Environment
Protection Agency (EPA) levels. Such review bodies/boards
can be established at federal and provincial levels like the
environmental tribunals. Official sources also confirmed
that EPAs have asked the government to increase funds
allocation for the review committees as without paying
handsome remuneration some experts do not return their
comments and even the copy of EIA report.
➢ A code of conduct and registration of EIA consultants is
important. It will not only help do away with a copy and
paste culture when producing reports but also discourage
one or two persons ‘jack of all master of none’ type
consultants. Grabbing international opportunities of fund-
ing for foreign training of officials and consultants may
also contribute to improving the quality of EIA reports.
➢ Public participation is a key component of EIA helping to
bring procedural democracy and better acceptability of
decision making into the EIA process (Aschemann, 2007). It
needs to be strengthened by raising stakeholders' awareness
about potential environmental and socio-economic impacts
of mega development projects. Since Non-Governmental
Organizations (NGOs) and media are playing a leading role
in this regards, international donor agencies should provide
ample funding to NGOs and EPAs should encourage them by
providing better access to EIA related information. It is also
suggested that a judge of an environmental tribunal should
head the public hearings along with the technical support of
an independent panel of environmental experts. It is
expected that the role of expert's panel (and that of judge)
would help assessing the genuineness of the concerns of
stakeholders and promoting an environment of justice
during hearings. After the hearings, stakeholders must be
informed about how their concerns have been incorporated
in the EIA report and the final decision.
➢ To enhance the implementation of management plans,
mitigation measures and post-EIA monitoring, EPAs
should be provided with sufficient staff and equipment.
Of course, more autonomy in the form of minimum
political interference and involvement of local commu-
nities shall also be needed to ensure better compliance of
the conditions of EIA approval and monitoring.
Acknowledgements
This paper is a part of an ongoing Ph.D. research by the first
author at the department of City and Regional Planning,
University of Engineering and Technology (UET), Lahore, Paki-
stan. The research is funded by the UET and the Higher Education
Commission (HEC) of Pakistan. Mr. Obaidullah Nadeem has also
worked on this research as a Fellow at the Department of Civic
Design, the University of Liverpool, UK, under the International
Research Support Initiative Programme of the HEC. We would
like to thank the UET and the HEC for providing with necessary
resources and financial support. Special thanks are due to Dr.
Thomas B. Fischer, Reader in Environmental Planning at the
University of Liverpool for his invaluable comments as a foreign
supervisor. The comments of the anonymous reviewers are also
acknowledged.
Appendix A. Institutional affiliation of interviewees and
discussion participants
Government Officials
• Pakistan Environmental Protection Agency (PAK-EPA), Islamabad
• Punjab Environmental Protection Agency (PEPA), Lahore
• Sindh Environment Protection Agency (SEPA), Karachi
• North West Frontier Province Environment Protection
Agency (NWFP-EPA), Peshawar
• Environment Cell, Planning Commission, Islamabad
• Environment Cell, Planning and Development Department
(P & D), Lahore
• Punjab Industrial Estate Development and Management
Company (PIEDMC), Lahore
• Water and Power Development Authority (WAPDA), Lahore
• Sui Northern Gas Pipelines (SNGPL), Lahore
• Lahore Development Authority (LDA), Lahore
• Water and Sanitation Agency (WASA), Lahore
• Revenue Department Punjab, Lahore
Consultants
• National Engineering Services Pakistan (NESPAK), Lahore
• National Environmental Consultants (NEC) Private Limited.
Lahore
• ECTECH Environmental Consultants, Lahore
Financial Institutions/Banks
• National Bank of Pakistan (NBP), Lahore
• Habib Bank Limited (HBL), Lahore
Academics
• University of Engineering & Technology, Peshawar
• University of Engineering & Technology (UET), Lahore
• Allama Iqbal Open University (AIOU), Islamabad
Non-Governmental Organizations
• World Wildlife Fund (WWF) Pakistan
• Pakistan Environmental Assessment Association, Karachi
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Obaidullah Nadeem is an Urban and Regional Planner who
received his B.Sc. and M.Sc. Degrees in City and Regional
Planning (CRP) from UET Lahore, Pakistan in 1992 and 1997.
He has 15 years of teaching, research and consultancy
experience with various national and international consul-
tants. He has authored 5 research papers, published in
international journals and conference proceedings. Presently,
he is doing his Ph.D. in the field of Environmental Planning
and Management from UET with focus on Public Participa-
tion in EIA of Development Projects in Pakistan. He has also
worked on his doctoral research as a Fellow at the
Department of Civic Design, the University of Liverpool, UK.
Rizwan Hameed is an Environment Planner who received his
Ph.D. Degree in the field of Environmental Planning and
Management from Heriot–Watt University, Edinburgh, UK in
2000. He has over 17 years of teaching, research and
consultancy experience. He has authored several research
papers some of which have been published in local and
international reputed journals. He has also offered consul-
tancy services to national and international consulting firms
on various urban planning and environmental management
issues. His current research interests include environmental
assessment, transport and environment, industrial pollution
regulation, and solid waste management.