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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
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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
What we WILL talk about • Compliance mechanism for non-environmental professionals • Types of compliances required • Some recommendations • Some limitations
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
Regulatory Compliance – I • Environmental Impact Assessment (EIA) • Initial Environmental Examination (IEE) • Environmental Statement / Environmental Audit
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
Projects requiring IEE • Projects with uncertain effects on the environment • Not located in Environmental Sensitive Areas • Listed on schedule B
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…
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.
Regulatory Compliance – II • Regular monitoring of emissions • Compliance with NEQS • Preparation of Environmental Management Plans
Categorization of Industries • In accordance with the international standards and practices the industries have been categorized as follows: • Category A. • Category B. • Category C.
Self Monitoring & Reporting Under Normal Plant Condition
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.
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).
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
WHAT IF OUR EFFLUENT OR EMISSIONS DO NOT MEET NEQS???
Scope of Environmental Management Plan • Identification of Environmental Improvement Options • Prioritization of Environmental Improvement Options • Action Planning • Report Formulation and Submission to EPA
Implications in Case of Non-Compliance • Pollution Charges • Environmental Protection Order • Environmental Tribunal