CPI Cleaner Production Institute

Environmental Legislation in Pakistan – Compliance Perspectives

Ibad ur RehmanDeputy Director (Projects)

Cleaner Production Institute

CPI 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

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What we WILL talk about

• Compliance mechanism for non-environmental professionals

• Types of compliances required

• Some recommendations

• Some limitations

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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

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Regulatory Compliance – I

• Environmental Impact Assessment (EIA)

• Initial Environmental Examination (IEE)

• Environmental Statement / Environmental Audit

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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

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Projects requiring IEE

Projects with uncertain effects on the environment

Not located in Environmental Sensitive Areas

Listed on schedule B

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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

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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.

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Regulatory Compliance – II

• Regular monitoring of emissions

• Compliance with NEQS

• Preparation of Environmental Management Plans

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Categorization of Industries

In accordance with the international standards and practices the industries have been categorized as follows:

Category A. Category B. Category C.

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Self Monitoring & Reporting Under Normal Plant Condition

CategoryReporting Frequency

Liquid Effluent Gaseous Emissions

A Monthly Monthly

B Quarterly Quarterly

C Biannually (Six Monthly)

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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.

Recording and Reporting of Plant Start-up and Upset Schedules

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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).

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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

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WHAT IF OUR EFFLUENT OR EMISSIONS

DO NOT MEET NEQS???

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Scope of Environmental Management Plan

• Identification of Environmental Improvement

Options

• Prioritization of Environmental Improvement

Options

• Action Planning

• Report Formulation and Submission to EPA17

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Implications in Case of Non-Compliance

Pollution Charges

Environmental Protection Order

Environmental Tribunal

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