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

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 2

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

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 4

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

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 6

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

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 8 Cont…

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. 9

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

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

Self Monitoring & Reporting Under Normal Plant Condition Category Reporting Frequency Liquid EffluentGaseous Emissions AMonthly BQuarterly CBiannually (Six Monthly) - 12

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

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). 14

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 15

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

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

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

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