Assignment in Energy management MS. khalil_fahad@hotmail.com

1. IMPLEMENTATION ISSUES OF NATIONAL
ENVIRONMENTAL QUALITY STANDARDS
(NEQ’s)
By
Fahad Khalil
MSEM-1

2. 1 Table of Contents
1. Introduction .......................................................................................................................................... 4
2 Background ........................................................................................................................................... 4
2.1 The Negotiation Process ............................................................................................................... 4
2.2 Concept of Pollution Charge ......................................................................................................... 4
2.3 Monitoring .................................................................................................................................... 5
3 Factors affecting the Implementation of National Environmental Standards...................................... 5
3.1 Governance ................................................................................................................................... 5
3.2 Implementation of Regulations .................................................................................................... 5
3.3 Lack of Integrated Environmental Policy ...................................................................................... 5
3.4 Public Awareness Towards Environment...................................................................................... 5
3.5 Lack of Skilled Manpower: ............................................................................................................ 5
3.6 Lack of Funding to Industries in Treatment Projects .................................................................... 5
3.7 Lack of Government Technical Support in Treatment Projects .................................................... 6
3.8 Strengthening of Environmental Authorities ................................................................................ 6
3.9 Lack of Division of Responsibilities between Provincial/Local Authorities ................................... 6
3.10 Lack of Independent Monitoring .................................................................................................. 6
3.11 Lack of Waste Disposal policy ....................................................................................................... 6
3.12 Lack of Sitting of Industry ............................................................................................................. 6
3.13 Lack of Research and Analysis in Support of Pollution Abatement .............................................. 6
3.14 Lack of Roundtables, Conferences and Workshops for Pollution Abatement.............................. 6
3.15 Provision of Incentives to Develop Indigenous Technology for Pollution Control ....................... 6
3.16 Lack of Human Element ................................................................................................................ 6
4 The Role of Non-Governmental Organizations ..................................................................................... 7
5 Functions of Provincial Authorities versus the Central Government ................................................... 7
6 Problems of Existing Industry versus New Industry.............................................................................. 8
7 Programs to Assist Industry Comply With Environmental Norms ........................................................ 8
7.1 Pollution control and Abatement Fund ........................................................................................ 9
7.2 Common Waste Treatment Systems ............................................................................................ 9
7.3 Demonstration Waste Treatment Systems................................................................................... 9
7.4 Cleaner Technology/Waste Minimization Project ........................................................................ 9

3. 7.5 Future Sitting of Industry .............................................................................................................. 9
7.6 Relocation of Selected industrial Sectors ..................................................................................... 9
7.7 Management of hazardous industrial waste .............................................................................. 10
7.8 Controls on the Import and Use of Toxic Chemicals ................................................................... 10
8 Self Monitoring and Reporting Program ............................................................................................. 10
9 National Environmental Quality Standards ........................................................................................ 10

4. 1. Introduction
A pollution charge regime has been introduced in Pakistan to achieve industrial compliance with the
National Environmental Quality Standards (NEQs). These Standards, if successfully implemented and
documented, would go a long way to meeting the standard requirements likely to be imposed by
importing countries. The modalities for the implementation of the pollution charges have gone through
a unique consultative process between representatives of industry, government, environmental NGOs
and academic researchers. The consensus of all stakeholders has been to adopt a market based
approach that is a pollution charge or tax combined with fiscal incentives to industries, rather than to
use coercive criminal procedures for ensuring compliance with NEQs.
2 Background
Although they were originally promulgated by the government in 1983, there had never been a
concerted effort to implement the NEQs until the Pakistan Environmental Protection Council (PEPC)
was reactivated in 1993 by Asif Ali Zardari, the minister for environment and husband of the then
Prime Minister, Benazir Bhutto. It was at this time that the sustainable development policy institute
(SDPI) suggested the use of a pollution charge, based on the German experience in pollution control
and initiated discussions on modalities for implementation.
There are obvious obstacles in the transition to more sustainable industrial production, not least of
which is the:
cost of new technology
lack of technical know-how or expertise
insufficient credit availability
and the already weak financial health of the industrial sector
Faced with these problems, it has been a challenging task to convince industry, especially the non
exporting sectors, to comply with new environmental standards.
2.1 The Negotiation Process
In order to rationalize the NEQs and to work out detailed modalities for their implementation,
the PEPC constituted on 12 March 1996 the Environmental Standards Committee (ESC)
under the chairmanship of Dr Shamsh Kassim Lakha, president of the Aga Khan University
and designated the SDPI as its secretariat.
The mandate of the ESC was very specific, to review the NEQs and suggest changes where
necessary and to recommend modalities for enforcing them. But in order to accomplish this
mandate, a multi-dimensional strategy would be necessary, one that combined a creative
market based formula with technical support to the industry and Government, a mass
awareness program and an effective monitoring system. The only way to ensure success was
to do all this openly and transparently.
2.2 Concept of Pollution Charge
The concept of the pollution charge is a key element of the implementation program.
According to the present proposal, the charge would be calculated on the basis of a pollution
load measured in pollution units. The principle is that the charge should be high enough to
introduce industry to clean up its act. In other words, the net cost of the clean-up should be
less than the pollution charge. Such a charge would ensure that those who introduce clean-up
activities do not suffer relative to those who persist with dirty production methods.

5. 2.3 Monitoring
A major issue for the environmental standards committee was the absence of an adequate
monitoring capacity in the EPAs and in the Government more generally. Industry
Representatives were skeptical about the transparency and fairness of any system that relied
primarily on monitoring by a limited number of overburdened and under trained Government
inspectors. The Government representatives also felt that the current capacity of the
monitoring agencies was considerably short of the demands likely to be placed upon it. As
such, there was a consensus on developing a sophisticated monitoring system that didn‟t rely
exclusively on Government inspections. Such a system would begin initially by self-monitoring
and reporting of the units concerned. EPA authentication would be required for a randomly
selected sample. Finally, reporting of compliance with NEQs from all industrial units would be
placed in the public domain to enable independent researchers and environmental NGOs to
monitor them and access the performance of the entire system. Any entities that willfully
conceal or falsely declare the level of pollutants in their report will be open to prosecution
under the harsher penal clauses of the environmental protection Act.
3 Factors affecting the Implementation of National Environmental
Standards
Following are the factors affecting the NEQs implementation:
3.1 Governance
Governance is the major issue in all the departments of Pakistan. Lack of interest towards good
governance, insufficient academic career, lack of merit during the Ministries allocation and lack of
knowledge about the environmental issues.
3.2 Implementation of Regulations
Environmental Regulations are approved and are on the papers but implementation is very weak.
Main reason is the lack of interest from the Government side. Many industrial units are owned by
the political representatives and these people usually put pressure on the respective
environmental authorities that result in poor implementation of Environmental Regulations.
3.3 Lack of Integrated Environmental Policy
Presently, there is a need for the integrated environmental policy on National Level by allowing
effective participation of Provincial Environmental Authorities, different industrial representatives
and Government Representatives, covering all the environmental issues in present and of future.
3.4 Public Awareness Towards Environment
From the Government side, lack of environmental public awareness policy. Lack of public
awareness programs regarding the environmental issues. A detailed action plan for implementing
an environmental monitoring program, including awareness raising and training for industry, has
been finalized by EPA and SDPI.
3.5 Lack of Skilled Manpower:
National & Provincial Environmental Authorities facing shortage of skilled manpower to cope with
the problem of rising environmental issues.
3.6 Lack of Funding to Industries in Treatment Projects
Government has no effective policy to fund the industries in developing the waste treatment
projects.

6. 3.7 Lack of Government Technical Support in Treatment Projects
Government is lacking in providing the technical assistance to industries regarding the selection of
optimum treatment options. Government doesn‟t have such kind of skilled people to cope with this
project nor are they hiring any consultants as well.
3.8 Strengthening of Environmental Authorities
There is lack of strengthening of National as well as Provincial Environmental Authorities. by
providing the skilled manpower, funds and administrative powers regarding the implementation of
NEQs.
3.9 Lack of Division of Responsibilities between Provincial/Local
Authorities
The division of responsibilities between Provincial/Local Authorities versus the Center requires are
not well clear.
3.10 Lack of Independent Monitoring
There is lack of Independent monitoring of environmental authorities from Government side.
3.11 Lack of Waste Disposal policy
There are no clear measures in regard to waste disposal policy. Usually unwanted materials are
concentrated to reduce the volume of the waste & then it is sent to the final waste disposal facility.
3.12 Lack of Sitting of Industry
There is lack of sittings with the industries from the Government and environmental authorities fro
the resolving the environmental issues & implementation of NEQs.
3.13 Lack of Research and Analysis in Support of Pollution Abatement
There is no R&D work in this sector. Research & Analysis (R&D) work should be implemented on
National Level and universities should be financed from Government as well as from the industrial
sector to go after the R&D work.
3.14 Lack of Roundtables, Conferences and Workshops for Pollution
Abatement
There is lack of roundtables, conferences and workshops for the sake of pollution abatement.
Government should take serious steps in promoting the conferences & also encourage the
industrial associations to fund for the conduct of the conferences as well.
3.15 Provision of Incentives to Develop Indigenous Technology for
Pollution Control
There are incentive policies from the Government side in this sector but not well clear so these
policies must be well clear about the incentives and Government should take serious serious steps
in developing the indigenous pollution control units, that will save foreign exchange & local
manufacturers will be encouraged as well.
3.16 Lack of Human Element
There is lack of Human element in the implementation of NEQS. The human element was
probably the most critical element that enabled the process to develop as it did. Intellectual and
Political leadership went into making the process a success.

7. 4 The Role of Non-Governmental Organizations
The role of NGOs in this entire process has been a crucial one from the start and one that has been
acknowledged by both government and industry. Benefits for including NGOs in environment sector
are:
First, the PEPC‟s appointment of the leader of an NGO as president of the ESC with the SDPI
(another leading environmental NGO) as its secretariat supports this view.
Second, the presence of the NGOs has provided an openness and transparency to the negotiation
process and has allowed a balanced expression of openness that catered to the interests of all
concerned parties.
Third, certain NGOs are playing an important role in raising awareness, not only of industry but also of
the public, about the importance and need for environmental conservation.
Fourth, a few NGOs working in this sector (such as the IUCN and the SDPI) are making efforts to
strengthen capacity of both the private sector and the government.
Fifth, NGOs are expected to have an important monitoring function in the future implementation of the
program.
Sixth, The sharing of technical expertise between the private sector, government and NGOs has
resulted in an unprecedented constructive partnership between these diverse entities.
Seventh, Several NGOs leaders have been appointed to be members of the PEPC, which is the
highest level environment policy making body in the country.
5 Functions of Provincial Authorities versus the Central Government
Although at present, a majority of the Pollution Control Programs are being implemented by the
Central Government through the Central Environmental Authority, with the devolution of powers to the
provinces, it is envisaged that a majority of the pollution control activities will be devolved to the
regions, in time to come.
At the present time the Provincial Environmental Authorities have their own statute and the
Environmental Protection License program for industries is being administered through the Provincial
Authority. This system is acceptable except for a few problems which have to be overcome. The
following specific problems have been identified in this regard.
The Provincial Authority is somewhat hampered in the performance of its duties due to the lack of
personnel. In addition, the Provincial Authority does not have the experience and expertise presently
available at the Central Environmental Authority in order to tackle major pollution problems arising from
large scale high polluting industry.
Pollution problems such as air or water pollution, do not respect boundaries. A pollution problem in one
province can severely affect the neighboring provinces. It is important therefore, that minimum
standards are available to the provinces in order for them to operate in such manner that is acceptable
to the rest of the country.
The division of responsibilities between Provincial/Local Authorities versus the Center requires to be
clarified. At the present time, the roles of Provincial Authorities as opposed to that of the Central
Government will have to be clearly defined in order to avoid confusion.
Provincial Environmental Authorities are not functioning in an effective manner. Government should
take serious steps towards the complete functionality of these authorities.

8. 6 Problems of Existing Industry versus New Industry
In reviewing the present status in Pakistan in relation to industrial effluents, it is clear that major
pollution problems arise mainly from those industries which were established two to three decades
ago, before the present Environmental Regulations came into force. As such, a clear demarcation has
to be made between the so called „existing‟ industries which are industries already in operation when
the present environmental regulations came into force as opposed to „new‟ industries which came into
existence after environmental regulations came into force.
The Central Environmental Authority has been successful to a great extent in controlling pollution
arising from new industries (i.e., industries established after 1990). It is a relatively easy task to control
pollution from these „new‟ industries, as action is taken by the industry at the planning stage itself to
install the necessary pollution control systems.
The major problem lies in the control of pollution from the so called „existing‟ industries. These are
industries which were established twenty to thirty years ago before environmental regulations were in
place. Many of these older industries often use outdated technology and have not given any thought to
waste minimization or end of pipe treatment. Many of these industries are cash strapped, and find it
difficult to adopt new technology or install end of pipe treatment systems as it may require
considerable amounts of funds. Some of these industries also face problems such as the lack of
physical space for the installation of the required end of pipe treatment systems.
The industries which generate the largest quantities of waste water in Pakistan are the textile, natural
rubber processing and food processing industry sectors. These three industry sectors are widely
distributed throughout the country. In addition to these, large scale industries such as the pulp and
paper mills and small scale leather tanneries also contribute to water pollution, although these are few
in number.
Industrial effluents are generally disposed of into nearby water bodies such as rivers, lakes or into the
ocean. The major problem with disposal of waste water into water bodies arise from the fact that most
of these rivers are being used by the general public for various purposes such as bathing, washing etc.
The situation regarding sitting and control of pollution from new industries has significantly improved
since the enactment of the National Environmental Act and its regulations in 1990. Most new
industrialists are now aware of the need to plan their pollution control strategy at an early stage of the
planning process unlike in the older industries when not much attention was paid to pollution
abatement measures at the planning stage, thereby making it more difficult and costly to incorporate
pollution control measures at a later stage.
The necessary legislative provisions are already in place for taking legal action against errant
industrialists who are violating the norms and standards stipulated by the Central Environmental
Authority. However, the Authorities have been fairly flexible in this regard particularly in relation to
existing industries. These industries have been allowed sufficient time to meet the stipulated
standards. In cases where the industry concerned does not make any attempt at all to abate the
pollution from his industry the Central Environmental Authority proceeds with legal action.
7 Programs to Assist Industry Comply With Environmental Norms
In Pakistan a mix of regulatory and incentive based strategies are adopted in order to control pollution
arising from industries. There are many programs which have been initiated in recent times with a view
to providing assistance to industries. Special emphasis has been given to the control of pollution from
the so called “existing” industries which older industries are set up several years or decades ago
before the present environmental regulations were in force. Some of these programs are briefly
described below.

9. 7.1 Pollution control and Abatement Fund
A „Pollution Control and Abatement Fund‟ is be set up in order to provide interest free loans as
well as free technical assistance to industries which have been established in the past and
which have pollution problems at present.
Under this scheme industries will be able to obtain funding on a concessionary basis for the
installation of waste treatment systems and for the implementation of other pollution
minimization measures. The funds will be being disbursed through the major development
banks.
This is a boon to industries, in particular the small and medium scale industry that may lack the
finances required for implementation of pollution control measures.
7.2 Common Waste Treatment Systems
In order to assist older industries in special areas with a high concentration of industries where
the necessary space for the installation of treatment systems is not available, the Government,
with World Bank assistance, will have to set up common waste treatment systems for joint
waste treatment. Industries in such areas will be expected to join the common waste treatment
system or install waste treatment systems on their own.
7.3 Demonstration Waste Treatment Systems
There are several specific industrial sectors where the required pollution control technology is
not available in the country at present. Demonstration waste treatment systems will have to be
set up for such industrial sectors by the Government in order to assist similar industries to set
up their own treatment systems with confidence.
7.4 Cleaner Technology/Waste Minimization Project
Another program which is to be implemented in order to assist industries is a demonstration
waste minimization project in selected industrial sectors. A UNIDO assisted waste minimization
project is to be implemented by the Central Environmental Authority covering major selected
industrial sectors. These include the distillery, textile and metal finishing industrial sectors.
Through this kind of project, selected industries in these major industrial sectors will show ways
and means of reducing waste generation quantities through simple process and raw material
changes, as well as good house keeping practices. Demonstration waste minimization projects
such as these help industries in meeting the required environmental standards while at the
same time reducing end-of-pipe treatment costs.
7.5 Future Sitting of Industry
In order to avoid the problems arising from inappropriate sitting of industry, the Government will
have to make a policy decision that in future, all effluent generating high polluting industry
should be sited in industrial estates with treatment facilities.
7.6 Relocation of Selected industrial Sectors
Other programs which will be concentrated upon are the relocation of industries which have
similar processes, to one central location in order to facilitate sharing of costs for waste
treatment and disposal. The main reason for the relocation of these tanneries was that these
tanneries which were established several decades ago were carrying out their operations in
highly residential areas which had developed in and around these industries. The operation of
these tanneries was causing a major nuisance to the nearby residents. In addition, although
these tanneries many of which are involved in chrome tanning generate substantial quantities of
waste water often containing chromium, in most of these locations there is not sufficient space
for the installation of the necessary treatment systems.
The relocation of the tanneries will give an opportunity to the industry to share the cost of waste
treatment in addition to minimizing pollution/nuisance problems by moving out from the
populated areas.

10. 7.7 Management of hazardous industrial waste
Although the quantities of hazardous waste arising from industrial operations in Pakistan is not
very substantial at the present time, it is envisaged that the problem is bound to become serious
with increased industrialization. There are a few industrial sectors which are already facing a
problem in relation to the disposal of hazardous waste. With an increasing number of industries
installing treatment systems for the treatment of their waste water, a serious problem with
regard to the disposal of sludge from such waste treatment systems has arisen. The proper
disposal of this waste poses a serious problem, due to the non availability of a high temperature
incinerator or a properly designed land fill site in the country. The government is in the process
of identifying a suitable site to be developed as a hazardous waste land fill site.
7.8 Controls on the Import and Use of Toxic Chemicals
Chemicals classified as pesticides, fertilizers or pharmaceuticals are fairly well regulated in
Pakistan, as legislation is already in place for the purpose. All pesticides, fertilizers and
pharmaceuticals go through a registration process whereby aspects such as toxicity and
environmental effects are looked into very carefully, as well as efficiency.
However, the use of toxic chemicals by industry is a fairly serious problem in Pakistan, as
extremely toxic/hazardous chemicals are sometimes being imported into the country, for use in
industry. At the present time there is permit scheme in place for the control of industrial
chemicals.
8 Self Monitoring and Reporting Program
To minimize the role of environmental inspectors and giving self-respect to industry, a self monitoring and
reporting program was derived in consultation with the trade & industry. The program is comprised of 3
versions of software meant for industrial unit, Provisional EPAs and Federal EPA. The program is user
friendly and requires minimum efforts to enter and transfer data of industrial effluents to concerned EPA. A
pilot program was introduced and successfully completed at the federal level for 50 selected industrial
units. It is intended to expand the program to provisional level for full scale implementation through EPA.
Based on the reported data, EPAs will start negotiations with highly polluting industries and enter into
pollution agreements with specific targets to be set through environmental improvement plans.
Ministry of Environment/Pak-EPA opened dialogue with the industry. Consequently, the industry which
was initially reluctant to adopt environmental measures soon realized the importance of pollution control
for enhancing their export in the international market, where environment friendly products have edge.
The Federation of Pakistan Chamber of commerce FPCCI and other industrial associations took initiative
and created environment cells within their organizations. Extra efforts are still required to promote green
productivity and adoption if ISO 14000.
9 National Environmental Quality Standards
 S.R.O. 549 (I)/2000
 S.R.O. 742 (I)/93 & S.R.O. 1023 (I)/95
 S. R.O. 1062(I)/2010 & S.R.O. 1063(I)/2010 & S.R.O. 1064(I)/2010 (NEQS for Ambient Air,
Drinking Water and Noise)
 S.R.O 72(KE)/2009 (NEQS for Motor Vehicle Exhaust and Noise)