II. ENVIRONMENTAL IMPLICATIONS OF UNSUSTAINABLE DEVELOPMENT
C. Environmental assessment as a planning tool
Environmental assessment is the primary means of managing the approval of major new development proposals, as it the systematic examination of proposals by following clear procedures which take account of the interests of relevant government departments and other stakeholders. It is a process of managing, preparing and reviewing IEEs and EIAs. It provides a means for promoting development which is environmentally sustainable. In NWFP, EPA is the responsible authority for environmental assessment. Section 8 of EPO 1983 and section 12 of EPO 1997 direct that all proponents of development projects from every sector, including agriculture, forestry, land levelling, industry, communications and roads, irrigation, canals and dams, undergo an IEE or, where the project is likely to cause any adverse environmental effects, that an EIA be filed with EPA for review and approval prior to project implementation. Section 17 (1) (4) deals with penalties for offenders. To date, IEEs and EIAs in NWFP have all been based on a subjective approach and no effort has been made during environmental impact quantification and monetization to include the findings, particularly the physical impacts, in the cost benefit analysis.
The EIA objectives are:
In NWFP, EIAs/IEEs on two categories of projects are submitted to EPA for review: (a) private projects which require loans from the national and local banks; and (b) public projects which require loans from various international donor sources. In the case of projects where an No Objection Certificate is not required EIAs/IEEs are not carried out.
In all cases where a project proponent requires a bank loan, EPA must be approached for No Objection Certificate. EPA will then request the preparation of an IEE/EIA according to World Bank and Asian Development Bank guidelines. In the case of major public projects, EIAs are submitted to EPA through the Planning, Environment and Development Department for comment. Once an EIA is submitted to EPA, the document is thoroughly reviewed and, if required, sent for further consideration by experts in other departments outside EPA. The comments and observations are conveyed to the project proponent. After the proponent provides a satisfactory reply to the observations an No Objection Certificate is issued and work starts on the project.
In the case of small projects, EPA staff visit the site and an inspection report is submitted to EPA. Standard guidelines are provided to the proponents and they are requested to file an undertaking with EPA.
Expertise in carrying out EIAs/IEEs is lacking in Pakistan, and especially in NWFP. EPA is the only provincial government department to possess some knowledge in that area. However, it is understaffed, so it is not possible for EPA staff to cover the whole province. The existing staff may be able to carry out or review IEEs in-house. However, scrutinizing EIAs requires considerable technical knowledge which may be available at the University of Peshawar, Pakistan Council for Scientific Industrial Research laboratories, the Pakistan Forest Institute and the National Institute of Public Administration (NIPA) where a few qualified and trained personnel are available who can contribute to the IEE/EIA process. A lack of coordination is the major problem experienced in tapping those resources. Friends of the Environment, private EIA consultants and environmental graduates undertake EIA/IEEs and other environment related studies in NWFP.