Environmental Legislation in Pakistan – Compliance Perspectives

1. Environmental Legislation in Pakistan – Compliance Perspectives Ibad ur Rehman Deputy Director (Projects) Cleaner Production Institute

2. What we will NOT talk about • History of environmental legislation in Pakistan • Development process of environmental legislation • Statutory details contained in the ext of PEPA 1997 • Roles & responsibilities of regulatory institutions

3. What we WILL talk about • Compliance mechanism for non-environmental professionals • Types of compliances required • Some recommendations • Some limitations

4. Environmental Concerns raised by EPAs • No enrolments under SMART program • No environmental reports submitted • No monitoring report submitted • Organizations’ commitment for environment is not visible • No reports submitted to Associations by member units

5. Regulatory Compliance – I • Environmental Impact Assessment (EIA) • Initial Environmental Examination (IEE) • Environmental Statement / Environmental Audit

6. Projects requiring EIA • Projects likely to cause adverse environmental impacts • Projects in Environmental Sensitive Areas may require EIA • Listed on schedule A of Pakistan Environmental Assessment Procedures

7. Projects requiring IEE • Projects with uncertain effects on the environment • Not located in Environmental Sensitive Areas • Listed on schedule B

8. Scope of Environmental Report • Description of the Proposed Project • Description of the Environment • Legislative and Regulatory Considerations • Determine the Potential Impacts of the Proposed Project • Analysis of Alternatives to the Proposed Project • Mitigation and Management of Negative Impacts • Development of a Monitoring Plan • Assistance in Inter-Agency Coordination and Public/NGO Participation Cont…

9. Recommendations • EPA should include concept of Cleaner Production and Energy Efficiency in the scope of environmental report • Proponents should also consider the above, specially for EA, for cost benefit • Proponents’ responsibility is limited to submission of report and responding to queries. Follow-up for NOC is NOT required.

10. Regulatory Compliance – II • Regular monitoring of emissions • Compliance with NEQS • Preparation of Environmental Management Plans

11. Categorization of Industries • In accordance with the international standards and practices the industries have been categorized as follows: • Category A. • Category B. • Category C.

12. Self Monitoring & Reporting Under Normal Plant Condition

13. Recording and Reporting of Plant Start-up and Upset Schedules • Industries in Category A would be required to maintain a record of times during which start-up and upset conditions occur. • Total time for start-up and upset conditions would be reported on a periodic basis.

14. Scope of Monitoring Assignment • Develop sampling plan • Conduct sampling • Engage an EPA approved laboratory for environmental testing • Evaluate test results based on professional experience • Prepare environmental monitoring report for onward submission to EPA, having sections on monitoring results, technical discussion on results, and mitigation measures (if any).

15. NEQS Compliance - Limitations • Space limitation specially for WWTP • Huge Capital expenditure involved • Technical limitations specially in some cases of air emissions • Technical basis of NEQS • Individual ETP vs CETP

16. WHAT IF OUR EFFLUENT OR EMISSIONS DO NOT MEET NEQS???

17. Scope of Environmental Management Plan • Identification of Environmental Improvement Options • Prioritization of Environmental Improvement Options • Action Planning • Report Formulation and Submission to EPA

18. Implications in Case of Non-Compliance • Pollution Charges • Environmental Protection Order • Environmental Tribunal

19. Thank You