THESIS ON ENVIRONMENTAL SCREENING TOOLS A Prospective Study

THESIS ON ENVIRONMENTAL SCREENING TOOLS
A Prospective Study
By
Ibad ur Rehman
A thesis
presented to the Bahria University, Karachi Campus,
in partial fulfillment of the requirements
for the degree of
Masters of Science (MS) Environmental Sciences
November 2015
DEPARTMENT OF EARTH & ENVIRONMENTAL SCIENCES
BAHRIA UNIVERSITY

THESIS ON ENVIRONMENTAL SCREENING TOOLS
A Prospective Study
By
Ibad ur Rehman
A thesis
Presented to the Bahria University, Karachi Campus,
In Partial Fulfillment of the Requirements
For the Degree of
Masters of Science (MS) Environmental Sciences
November 2015

BAHRIA UNIVERSITY, ISLAMABAD
APPROVAL SHEET
SUBMISSION OF HIGHER RESEARCH DEGREE THESIS
The following statement is to be signed by the candidates’ supervisor(s) and dean / head
of faculty / department and must be received by the Director of Examination, prior to the
dispatch of the thesis to the approved examiners.
Candidate’s Name: Ibad ur Rehman
Discipline: Environmental Sciences
Faculty / Department: Earth & Environmental Sciences
I hereby certify that the above candidate’s work, including the thesis, has been completed
to my satisfaction and that the thesis is in a format and of an editorial standard
recognized by the faculty / department as appropriate for examination.
Signature(s):
Principal Supervisor:
Date:
The undersigned, Certify that:
1. The candidate presented at a pre completion seminar, an overview and synthesis of
major findings of the thesis, and that the research is of a standard and extent appropriate
for submission as a thesis
2. I have checked the candidate’s thesis and its scope, format, and editorial standards are
recognized by the faculty / department as appropriate.
Signature(s): Dean / Head of Faculty / Department:
Date:
i

DECLARATION OF AUTHENTICATION
I certify that the research work presented in this thesis is to the best of my knowledge my
own. All sources used and any help received in the preparation of this dissertation have
been acknowledged. I hereby declare that I have not submitted this material, either in
whole or in part, for any other degree at this or any other institution.
Signature:
ii

ACKNOWLEDGEMENT
I am all thankful to the Almighty Allah, for making the journey of my life, till this point
and including the reparation of this thesis, a blessing indeed.
Many thanks are due to Dr. Mubarak Ali – my thesis supervisor, Mr. Sharif Mughal – Co-
supervisor, Dr. Yasmeen Nargis, my other teachers at Bahria University, and previously at
Karachi University, for their untiring efforts in trying to transform a very mediocre student
into a good one. Your efforts may or may not have brought the desired fruits, but may God
accept your efforts.
My colleagues at NEC Consultants deserve a lot of thanks for creating a knowledge
atmosphere at my work place.
Many thanks to all the respondents of my interview requests for this assignment. They
have provided the main thrust of this dissertation, and it really was very insightful
interaction with each one of them.
Thank you Shehbaz Ahmed, my classmate, colleague and dear friend, for making many
dull days into interesting ones.
And finally, a lot of thanks to my family – my parents, wife, kids and siblings – for being
there for me through the thick and thin of it all
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DEDICATION
This thesis is dedicated to my family,
For always believing in me, inspiring me, and encourage me,
to reach higher in order to achieve my goals.
iv

ABSTRACT
Under the federal environmental legislative regime, all proposed projects underwent an
initial screening based on Schedule I and II of EPA (Review of EIA & IEE) Regulations
2000. However, experience suggests that the two schedules prove inconclusive and / or
insufficient in many cases. The Sindh Environmental Protection Act 2014 has only been
promulgated by the provincial government in March 2014, and the other relevant
statutes, procedures and regulations are being developed currently. The relevant
procedure for environmental screening under SEPA 2014 has been notified through SRO
739 / 2014 in December 2014. This SRO identifies three categories of Projects under
Schedules I, II and III, requiring EIA, IEE and Environmental Checklist respectively.
However, unlike the chief law (SEPA 2014) which was formulated after painstaking
consultations with all stakeholders, the mentioned rules have been developed without
much consultation. Consequently, many parameters (or their values) need to be reviewed
in these rules.
This study seeks to review the schedule I, II, and III mentioned above in light of
practices by EPAs of other regional countries, developed countries, and development
institutions.
After extensive literature review and detailed deliberations with various experts, this
study finds that the schedules need a statement of guiding principle; areas not under the
mandate of provincial government need to be removed; core parameters for the basis of
categorization need to widen; and use of financial threshold as an indicator of potential
environmental impacts is a debatable idea. Finally, there are certain errors and omissions
that should be corrected.
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Table of Contents
APPROVAL SHEET......................................................................................................................................................................................i
DECLARATION OF AUTHENTICATION.......................................................................................................................................................ii
ACKNOWLEDGEMENT.............................................................................................................................................................................iii
DEDICATION.............................................................................................................................................................................................iv
ABSTRACT.................................................................................................................................................................................................v
Table of Contents....................................................................................................................................................................................vi
1.1 Background.........................................................................................................................................................................................1
1.2 Overview.............................................................................................................................................................................................2
1.2.1 Environment – the Service Provider...........................................................................................................................................2
1.2.2 Environmental Assessment - Definition.....................................................................................................................................3
1.2.3 Environmental Screening – Definition & Objectives..................................................................................................................4
1.2.4 Criteria for Environmental Screening ........................................................................................................................................5
1.2.5 Need to Review Provincial Environmental Screening Tools......................................................................................................6
2.1 Exploratory Research.........................................................................................................................................................................8
2.2 In-depth Interviews............................................................................................................................................................................8
2.2.1 Information Sharing Protocol...................................................................................................................................................10
3.1 Progression of Environmental Legislation in Pakistan....................................................................................................................12
3.2 Environmental Screening – Initial Step in Project Cycle.................................................................................................................14
3.3 Difference between Screening & Assessment................................................................................................................................15
3.5 Legally Binding Approach to Environmental Screening..................................................................................................................17
3.6 Guidance-based Approach to Environmental Screening................................................................................................................20
4.1 Current Screening Schedules...........................................................................................................................................................25
4.2 Freedom of Interpretation...............................................................................................................................................................34
4.3 Core Parameters for Categorization................................................................................................................................................36
4.4 Financial Threshold..........................................................................................................................................................................37
4.5 Clarity on Jurisdiction.......................................................................................................................................................................38
4.6 Integration of Environmental Checklist into the Act.......................................................................................................................39
4.7 List of Projects NOT Requiring Environmental Assessment............................................................................................................40
4.8 Errors & Omissions...........................................................................................................................................................................40
Bibliography............................................................................................................................................................................................46
vi

List of Tables:
Table 1: Follow-up on Screening..............................................................................................................................................................5
Table 2: Interviews Conducted................................................................................................................................................................9
Table 3: Environmental Legislative Development in Pakistan – Chronology.......................................................................................13
Table 4: Intensity of Environmental Assessment..................................................................................................................................17
Table 5: Comparison of SEPA Schedule I & PEPA Schedule I (Projects Requiring IEE).........................................................................26
Table 6: Comparison of SEPA Schedule II & PEPA Schedule II (Projects Requiring EIA).......................................................................29
vii

List of Annexure:
Annexure – 1: IEE / EIA Regulation 2014
viii

CHAPTER – 1
INTRODUCTION
1.1 Background
This research paper has come about to fulfill the requirements of MS (Environmental
Sciences) degree by the Bahria University.
This research paper focuses on the procedures and protocols applied when determining
the level of environmental assessment required for any proposed project in the province
of Sindh. This determination of level of assessment is known as environmental screening.
The research has been conducted with the following objectives:
a. To evaluate schedule I, II and III of SEPA (Review of IEE and EIA) Regulations 2014 for
its relevance and efficacy in the current scenario of Sindh
b. To formulate suggestions and recommendations for improvement, if needed, in the above
mentioned schedules
The Schedule I, II and III of SEPA (Review of IEE and EIA) Regulations 2014 are the
statutory tools that currently govern the environmental screening process in Sindh.
However, there is a need to review and modify the above mentioned schedules. This need
primarily emanates from the following:
1. Experience suggests that the schedules prove inconclusive and / or insufficient in
many cases.
2. Many financial limits mentioned in the schedules have to be checked under current
market price mechanism.
3. Currently, the schedules provide only lists of projects, and lack specification of
screening criteria that could be used in cases where a specific project is not listed.
4. The current regulations do not consider cumulative assessment.
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This paper essentially expands and elaborates the above mentioned points, in the light of
the theory given in literature, practical experience in the local arrangement gleaned from
various assessment reports, and extensive interviews with professionals attached with the
field of environmental assessment as part of their job responsibilities.
1.2 Overview
1.2.1 Environment – the Service Provider
Our surrounding environment provides two of the most basic requirements for existence
of life on planet earth:
• It provides the resources and raw material for everything, from oxygen for breathing
to uranium for atomic reactors. Some of these raw materials and resources, e.g.
oxygen for breathing, are renewable i.e. they are again available for the same use after
going through some natural regeneration steps. Whereas, some of these materials are
non-renewable that are lost forever once used, for example any fossil fuel.
• It also serves as the sink for all the waste and trash resulting from existence of life and
anthropological activities, from human sewerage to industrial wastes. Some of this
waste or trash goes through a natural cyclic process, whereby it regains its original
form and becomes available for reuse in the previous manner. Whereas for much of
the material, the existing scientific wisdom points to a limited and definite supply, and
no cyclic natural regeneration process is known.
With growing population and improving lifestyles everywhere in the world, there is ever
more pressure on the environment for both the above mentioned services. It has been
argued that we might by outracing the nature’s ability to redeem itself: in terms of
recycling of waste into useful resources and also in terms of its assimilation capacity for
various forms of pollution. It means that we are not only running out of the non-
renewable resources, but also causing irreparable damage to the renewable resources. The
most common example for the former is the fossil fuel, while the pertinent, and most
worrisome, example for the latter is the fresh water.
The human society is coming up with various solutions to this environmental challenge.
The responses are in various forms starting from using best practices for manufacturing
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industry to major technological innovations. Therefore, it could be seen that while an
average automobile used to go about only 2-3 km in one liter of petrol during the 50s, it
now runs more than 15 km in a liter. This has been made possible by continuous
technological advancements, and the target is to develop technology that goes 100 km in
a liter of petrol by 2025.
However, technology is not the only facet of environment. There has been intense debate
in the world revolving around the concept of sustainable development – a development
for the current generation without compromising the ability of future generations to use
the environmental resources for their own needs. Simultaneously, there has been a general
consensus that any individual development project must be not only financially feasible,
but it should also be viable in terms of the environment that it is going to operate in.
further, it should also be socially acceptable to the communities that are directly or
indirectly affected by its implementation. This debate has resulted environmental
assessment becoming an integral part of all development projects, everywhere in the
world.
1.2.2 Environmental Assessment - Definition
Environmental assessment is the process through which educated-estimates are made
about the potential positive and negative impacts of any proposed project on the
environment. Depending on a number of factors – technical and others - it may be a
smaller, secondary data based exercise, or a comprehensive, primary data oriented
enterprise. Various terms are used nationally and internationally to describe
environmental assessments of varying depths. Most common, and most used in literature,
are the terms Initial Environmental Examination and Environmental Impact Assessment.
In terms of time and human resources, the preliminary level assessment may require only
a couple of days and limited technical expertise on the part of the assessor(s). Whereas,
many large scale projects need a detailed assessments warranting a sizable team of
subject experts and taking up as long as a couple of years for completion.
The International Association for Impact Assessment (IAIA) defines an environmental
impact assessment as ‘the process of identifying, predicting, evaluating and mitigating the
biophysical, social, and other relevant effects of development proposals prior to major
decisions being taken and commitments made’ [1]. When defined this way, the
3

environmental impact assessment becomes a whole cycle including the preparation of the
assessment, reviewing its outcomes, and management of the entire process. This
definition also entails both the Initial Environmental Examination (IEE) and
Environmental Impact Assessment (EIA), and any other nomenclature such as
Environmental & Social Impact Assessment (ESIA)[2].
1.2.3 Environmental Screening – Definition & Objectives
The term environmental screening is used to refer to two similar – but distinct processes:
one to determine whether environmental assessment is required by a particular proposed
project; and two, to identify significant environmental aspects and impacts while
conducting the actual exercise of environmental assessment. However, it is the former use
of the term that is generally taken as its quasi-official definition.
For the purposes of this thesis, Environmental Screening is defined as the process of
determining and establishing the need of an environmental assessment for a particular
project, and once the need is established, determining the necessary level of
environmental review.
Screening is carried out because of the following rationale:
• There are many developments that may not pose a significant threat to the
environment. In such cases, a full-fledged environmental assessment is not required.
• More importantly, many projects may require only a limited level of assessment and
not all environmental aspects need to be covered. For example, development of a road
in an already settled urban landscape will not require a strong focus on the geology
and meteorology of the area, but will demand an emphasis on the socio-economy.
Therefore, subjecting all proposed development projects to the same intense level of
environmental assessment could amount to waste of time and other resources.
As a whole, environmental screening of projects at the initial stage offers multiple
benefits. It can lead to a number of different important follow-on actions [3]:
4

Table 1: Follow-up on Screening
Screening Outcome Further Action
No significant environmental issues
identified
No further action
There are some potential issues that
require proper management for the
project to remain environmentally
sustainable.
Identification of environmental opportunities
and risks
Further environmental studies are
needed.
Identification of the need for further studies;
The project design could be altered and
improved by incorporating results and
recommendations of these studies
Action planning for any follow-up
actions that might be required during
design or implementation
Allocation of budget, staff responsibility and
accountability
The unlikely, but possible, scenario
where a project reaches concept stage
before a serious risk has been identified.
Decision that the intervention is inappropriate
in its current form
1.2.4 Criteria for Environmental Screening
There are three criteria that are typically used for screening:
1. Nature of the Project / Type Criteria
2. Size of the Project / Threshold Criteria
3. Location of the Project / Sensitive Area Criteria
The nature or type criteria focuses on whether the proposed project is likely to create a
sizable environmental impact due to the nature of the processes involved. Therefore, a
textile wet processing unit (washing / dyeing / printing / finishing) is typically subject to a
detailed environmental impact assessment, whereas a textile ginning or garments
manufacturing unit may require only an initial environmental examination to be carried
out.
5

The threshold criteria focuses on the size of the proposed interventions despite its similar
nature. Hence for example, an initial environmental examination is deemed sufficient for
small scale village roads, but a more comprehensive environmental impact assessment is
warranted for large scale inter-city roads or highways.
Finally, the location criteria takes into account the particular geographical location of a
proposed intervention, in terms of the sensitivity of the environmental receptors. Hence,
any project proposed to be located or passing through a declared national park or nature
reserve will be subject to an EIA.
In practice, employing a combination of the above three criteria is generally more
prudent, than using any one specific criteria.
1.2.5 Need to Review Provincial Environmental Screening Tools
The current statute governing the environmental screening process in Sindh is the Sindh
Environmental Protection Agency (Review of EIA & IEE) Regulations 2014. Notified in
December 2014, these regulations provide three schedules, each listing projects requiring
EIA, IEE, and Environmental Checklists respectively. However, there is a need to review
and modify the above mentioned schedules. This need primarily emanates from the
following:
1. Experience suggests that the schedules prove inconclusive and / or insufficient in
many cases. One of the latest examples in this regard is the Bahria Icon Case,
whereby an Initial Environmental Examination was conducted and environmental
NOC was duly granted by the EPA. But one of the major stakeholders (DHA) has
challenged this in the court of law. They insist that a more comprehensive EIA should
have been conducted for the project, before it could be granted approval by the EPA.
2. Many financial limits mentioned in the schedules have to be checked under current
market price mechanism. For example, a piece of land in Karachi is typically much
more expensive than a piece of same size in Hyderabad. This leads to a project of
same nature and size having much higher cost in Karachi, but the environmental
impacts are likely to remain the same whether it is located in Karachi or in
Hyderabad.
6

3. Currently, the schedules provide only lists of projects, and lack specification of
screening criteria that could be used in cases where a specific project is not listed. In
some cases, it leads to arbitrary decision-making by the EPA. For example, the oil
marketing companies generally maintain storage facilities in various parts of the
country, to ensure smooth supply of fuel to all parts. However, there is no clear
mention of diesel storage facilities maintained by OMCs in the schedules provided by
the EPA.
4. The current regulations do not consider cumulative assessment. For example, a
pharmaceutical unit is required to conduct an IEE, irrespective of whether it is
situated in an industrial estate where EIA has already been conducted, or located
elsewhere. Vice versa, there could be many small scale interventions, like developing
water wells in Thar by various Charities, which need to be checked against their
cumulative impacts.
7

CHAPTER – 2
METHODOLOGY
2.1 Exploratory Research
Based on the nature of the problem as identified above, exploratory research was required
– that is, an initial research to determine whether the problem really exists, and if so, what
are its various facets. Hence, qualitative research method was adopted for this
assignment.
Information was collected from both secondary and primary sources to provide insight
into the above-mentioned problems and develop suggestions for improvement. Secondary
information was collected from a number of authentic and published sources. The
references of these sources have been provided in the endnotes as a list of references
attached at the end of this document.
2.2 In-depth Interviews
Primary information was collected through in-depth interviews with following categories
of environmental professionals:
• EPA
• Academia
• Project Proponents
• Environmental Consulting Professionals
• Environmental Lawyers
The list of people interviewed is presented in the following table:
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Table 2: Interviews Conducted
S.
No.
Name Relevance / Category
Current
Organization
1. Engr. Tufail Ali Zubedi
Teaching environmental
engineering; environmental
consultant
NED University;
NEC Consultants
2. Mr. Rafi ul Haq Ecologist; Ex-IUCN CRAB
3. Mr. Kamran Naqvi Environmentalist IUCN
4. Mr. Waqar H. Phiulpoto EPA Sindh EPA
5. Mr. Imran Sabir EPA Sindh EPA
6. Dr. Sara Khan Academia IBA
7. Mr. Faisal Aziz
Project Proponent EHS
Manager
Getz Pharma
8. Ms. Rizwana Kazmi Project Proponent PPL
9. Mr. Qaiser Hasan
Environmental Advisor to
O&G Company
Name withheld upon
request
10. Mr. Mustafa Mirza Lawyer Makhdoom Ali Khan
11.
Dr. Arjumand Zehra
Zaidi
Academia; Environmental
Consultant
Institute of Space
Technology
12. Mr. Mustafa Matloob
Project Proponent EHS
Manager
SUPARCO
13. Dr. Bashir Lakhani Project designer
Techno-Consult
International
14. Mr. Shamim Ahmed Adv. High Court Free lance
15. Mr. Waqas Qadri Environmental Consultant
Pak-Marina
Consultants
The in-depth interview is an unstructured – direct technique in which no rigid format was
followed but the respondent was queried about the issue at hand. It used extensive
probing to prompt the respondent to express detailed opinion about the subject.
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The main reasons for using this technique were the following:
• It allowed for an intuitive and subjective approach for data gathering
• The needed information was related to the respondents’ core profession
• The research problem did not warrant any statistically or scientifically accurate data
• It allowed for open-ended data collection format
• It allowed for the use of small convenience sample.
The in-depth interviews covered the following thematic areas:
• Why is environmental screening carried out
• Are you familiar with current environmental screening tools in Pakistan
• Are you in agreement with current environmental screening tools
• If yes, why? If no, what improvement should be made
All the interviews were conducted at the workplaces of the respondents. The average
lapse time of each interview was one hour, but it took more time in a couple of cases.
Prior appointment was made with all interviewees before conducting the interview.
2.2.1 Information Sharing Protocol
For the secondary information, it has been ensured that only authentic and verifiable
sources are used. Further, wherever information has been gleaned from any particular
secondary data source, it has been duly mentioned in the text. Finally, there are a few
places in the paper where some piece of information has been used verbatim – or
reproduced from the original source. At all such places, use of parenthesis and reporting
speech has been made.
For the primary information, it was agreed with the respondents that the information
provided by them will be used only in generic terms and anonymously. In case their
background is needed to stress any point of information, only the general category they
10

belong to will be mentioned. This protocol has been followed throughout this research
paper.
11

CHAPTER – 3
LITERATURE REVIEW
3.1 Progression of Environmental Legislation in Pakistan
The issue of environmental protection in Pakistan has been addressed from time to time
by legislations such as a Hazardous Occupation Regulation (1963), the West Pakistan
Pure Food Act (1965), the Motor Vehicle Ordinance (1965), the East Pakistan Sound
Amplifiers Ordinance (1965), the Agricultural Pesticides Ordinance (1971), the Cutting
of Trees (Prohibition Act (1975), Local Government Ordinance (1979/80), etc.
In 1983, the Pakistan Environmental Protection Ordinance (PEPO) was promulgated.
PEPO also provided for the establishment of Federal and Provincial Environmental
Protection Agencies (EPAs).
However, even after the promulgation of the 1983 Environmental Protection Ordinance,
environment remained largely a neglected area at the official level, while the word
‘environment’ remained unfamiliar to the common people [4]. The level of official apathy
was such that it took 9 years after the promulgation of PEPO for the Pakistan
Environmental Protection Council to meet for the first time.
However, a positive change came about with the initiation of NCS process. This process
had the full support of Ministry of Environment and NGOs in the country. This process
derived a general increase in the environmental awareness in the country. It involved civil
society institutions and other stakeholders in the environmental policy development. And
probably most important achievement was that it created an enabling atmosphere wherein
basic environmental institutions could be established in Pakistan [5].
A more comprehensive statute, the Pakistan Environmental Protection Act 1997, was
notified by the Government of Pakistan on December 06, 1997 to replace PEPO 1983. Up
until the start of new millennium, the development of environmental legislation regime
has been documented in various sources of literature. One source summarizes this
development quite succinctly [6]:
12

Table 3: Environmental Legislative Development in Pakistan – Chronology
Year Event
1972 UN Stockholm Conference on Environment and Development
1975
Environment and Urban Division (Ministry of Housing, works and Urban
Affairs) established
1976 Draft Pakistan Environmental Protection Ordinance prepared
1983 Pakistan Environmental Protection Ordinance enacted
1983 Pakistan Environmental Protection Council established
1987-89 EPAs established
1992 National Conservation Strategy adopted
1992 FPCCI Standing Committee on Environment established
1993 Pakistan Environmental Quality Standards notified
1993 Pakistan Environmental Protection Act drafted
1995 Ministry of Environment, Urban Affairs, Forestry and Wildlife established
1996
Name changed to the Ministry of Environment, Local Government and
Rural Development (M/o ELG&RD)
1996 Drafts of Provincial Environmental Protection Acts (NWFP, Punjab)
1996 Environmental Technology Program for Industry (ETPI)
1997
Pakistan Environmental Protection Act (December 1997) (Repealed PEPO
1983)
1997 Standing Committees on Environment of various Chambers of Commerce
1998 Rules and Regulations for PEPA drafted
1998 Environmental Magistrates notified (NWFP)
1999 Delegation of powers under PEPA 1997 to provincial EPAs
1999 Environmental Tribunals established (Karachi & Lahore)
2000 First Rules under PEPA notified; revised NEQS notified
2000
NEQS Implementation Committee headed by Dr. Pervez Hassan and
comprising representatives of trade and industry, NGOs and other
stakeholders constituted
With the advent of the new millennium, the environmental movement in Pakistan
continued to gain momentum. Many economic aspects became an important cog in its
wheel. For one, most multilateral and bilateral grants started to take environment as their
13

core agenda. Environmental soundness of any development project became the core
criteria of international funding. Even in the private sector, many international buyers
started to put greater pressure on Pakistani suppliers for improved environmental
performance. As many researchers have argued, environment became one of the main
non-tariff barriers after demolition of most tariff related barriers under the WTO.
Environment also became a quite prominent feature of the judicial activism in the
country.
On 8th
April 2010, the National Assembly amended the Constitution of Islamic Republic
of Pakistan 1973 [7]. Under this, the 18th Amendment to the Constitution, the subject of
environment was devolved to the provincial level. Subsequently, the Sindh
Environmental Protection Act 2014 has been promulgated by the Government of Sindh
on March 20th, 2014. The Sindh EIA / IEE Review Rules, including the three schedules
for environmental screening of projects, were notified in December 2014. Various rules
and regulations under this act are currently being developed.
3.2 Environmental Screening – Initial Step in Project Cycle
It comes out as almost universally acknowledged that environmental screening should
form the first step in the environmental assessment process. Clarke (1998) suggests that
as the first step in environmental assessment, environmental screening should be carried
out using certain pre-developed criteria, to determine whether there are likely to be any
significant impacts. Afterwards, any of the following three courses of action could be
adopted, based on the outcome of the screening.
1. No further study if no significant environmental impacts are expected
2. Initial environmental examination if there is doubt about the significance of the likely
environmental impacts
3. Formal guidance on the extent of EA, to the proponent by the relevant authority.
The IFC guidelines put the (initial) screening of the project and the scoping of the
assessment process immediately after project definition. Then the next steps are identified
as stakeholder identification and gathering of social and environmental baseline data,
14

where relevant; impact identification and analysis; and; generation of mitigation or
management measures and actions [8].
In fact, OECD and the Nordic Council of Ministers go as far as to suggest that trade
agreements and policies should also be first environmentally screened [9].
3.3 Difference between Screening & Assessment
Though environmental screening is the first step in environmental assessment, technically
it is different than the assessment itself. The Canadian Government, for example,
describes it as the following [10]:
• Screening is the process used by the Environmental Assessment (EA) Branch to
determine whether or not a project, operation or activity is a ‘development' within
Section 2(d) of The Environmental Assessment Act.
• The proponent is asked to submit a project proposal that describes the project purpose,
manner of operation, location and surrounding environment as well as any
environmental protection measures that will be applied.
• On the basis of information submitted, the EA Branch considers if the project is likely
to have impacts significant enough to warrant an environmental assessment.
• If the EA Branch concludes the project is unlikely to meet the definition of
‘development', the proponent is advised that the project has not triggered the EA
process and may go on to get any further environmental approvals and requirements
under other legislation.
• If the EA Branch concludes the project is likely to have significant impacts, then the
proponent will be asked to submit an environmental impact statement for analysis and
approval by the Minister following a period of public review and comment.
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3.4 Environmental Screening in Pakistan
The environmental assessment process in Pakistan is given as flow chart by Aslam F. [11]
The guidelines issued by Pakistan EPA [12] in October 1997 clearly categorize the
projects in three classes based on preliminary environmental screening:
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Table 4: Intensity of Environmental Assessment
Project Environment Relationship Assessment Depth required
Projects likely to cause adverse environmental effects EIA required
Projects where their effects on environment are
uncertain
IEE required
Projects not likely to cause any adverse environmental
effect
No formal IEE or EIA
required
However, situation on ground is rather more complex. Pastakia (2012) notes that under
PEPA 1997, a vast range of smaller projects escape the net of impact assessment.
Therefore, she argues, the steps for impact assessment should begin with screening for all
projects that have a potential to affect environment, regardless of scale. Depending on the
results, initial screening should be followed by an EIA or IEE [13].
3.5 Legally Binding Approach to Environmental Screening
Literature review indicates that there are two distinct approaches to screening adopted by
various authorities and agencies. Environmental law enforcement agencies generally tend
to provide list of projects where EIA is to be conducted or IEE is to be conducted. This is
almost invariably the case in regional developing countries. Such schedules are then
perceived as legally binding instruments, rather than only guidance and advisory tools.
There are arguments for and against this approach. In developing countries, where general
environmental awareness is low and most decisions are solely based on financials,
leaving the interpretation of guidelines open might be fraught with possible
misrepresentations. This could become further complicated due to non-availability or
non-functionality of a suitable redressal mechanism.
Importantly, the guidelines issued by EPA in 1997 contained good guiding statements at
the beginning of the three schedules that listed the projects requiring EIA, IEE or no
further study. Hence, schedule A states that: “the projects in Schedule A are generally
major projects and have the potential to affect a large number of people. They also
include projects in environmentally sensitive areas. The impacts of such projects may be
irreversible and could lead to significant changes in land use and the social, physical and
biological environment” [14]. In fact, the Schedule C – that is supposed to provide a list
17

of projects not requiring IEE or EIA – does not make any attempt to give any detailed list
of projects, and provides only a few illustrative examples [15].
However, in the next set of guidelines, the Pak-EPA suggests that the proponents should
consult with the responsible authority at the earliest possible time, to confirm the
categorization of the project [16].
Since the Sindh Environmental Protection Act [17] was passed by the provincial
assembly of Sindh in March 2014, and the EIA/IEE regulations were promulgated in
December 2014, the development of these statutes had the benefits of hindsight; the
problems faced by the Sindh EPA in interpreting and enforcing PEPA 1997 could be dealt
with. Furthermore, this process was supported by a four-year internationally funded
project titled National Impact Assessment Program (NIAP). The NIAP brought in
necessary expertise from within and outside Pakistan together and played a key role in
enhancing the capacity of EPAs.
The Sindh EPA recognized that clubbing all projects into two schedules (one for EIA and
one for IEE) is to narrow it down too much. Therefore, the provincial legislation provides
for three schedules; one each for EIA and IEE, and one for environmental checklists.
In the Environmental Protection Rules of Nepal, Clause 3 of Chapter 2 makes it legally
binding on the project proponents to prepare an EIA if their project falls under Schedule I
and IEE if it falls under Schedule II. Both the schedules then provide a list of more than
100 projects where EIA is required and more than 80 projects where IEE is required [18].
In case of Bangladesh, the apex environmental statute is the Bangladesh Environment
Conservation Act 1995, under which a host of rules and regulations have been notified.
Clause 12 of Environment Conservation Act, 1995, states: No industrial unit or project
shall be established or undertaken without obtaining, in the manner prescribed by rules,
an Environmental Clearance Certificate from the Director General. EIAs are reviewed in
Processing Environmental Clearance Certificate. The industrial units and projects are
classified in four categories, chiefly based on their site and impact on the environment.
Following are the four categories [19]:
18

• Green
• Orange – A
• Orange – B
• Red
The Environmental Conservation Rules 1997, promulgated under the Environment
Conservation Act of Bangladesh, provide lists of projects falling under each of the above
four categories. For Orange –B category projects, an IEE is required while for Red
category projects, an EIA is required.
In India, though EIA is in practice since 1976-77, initially it was used only as an
“administrative instrument”. It gained legal backing in January 1994 when EIA
notification was issued under the Environment Act of 1986 [20]. There has been few
modifications in this statute over the past two decades. It makes it mandatory for projects
to take environmental clearance before commencement of construction or operations in
four stages, namely:
• Stage (1) Screening (Only for Category ‘B’ projects and activities)
• Stage (2) Scoping
• Stage (3) Public Consultation
• Stage (4) Appraisal
All projects are required to get environmental clearance by filling out the prescribed
Form-I. This form is essentially an Initial Environmental Examination. Nevertheless, the
legal instrument contains a Schedule, giving list of projects falling in Category A and B,
based on their type and threshold. Category A projects need an EIA and approval from
the Central government. Category B projects also need an EIA, but their approval is
vested in the state or the provincial government. The schedule lists some 39 projects
under 8 separate heads, falling in category A or B or both [21].
19

3.6 Guidance-based Approach to Environmental Screening
The other approach is to expand the three criteria cited above, and encouraging the
proponent to screen the proposed project accordingly. This, of course, needs to be
endorsed by the approving authority based on the logic and rationale presented by the
proponent. This approach is more common in development financing institutions (World
Bank, ADB etc.) and the developed countries (EU etc.).
A look into IFC Social & Environmental Performance Standards provides an insight into
the basis of this approach:
“Depending on the type of project and the nature and magnitude of its risks and impacts,
the Assessment may comprise a full-scale social and environmental impact assessment, a
limited or focused environmental or social assessment, or straightforward application of
environmental siting, pollution standards, design criteria, or construction standards. When
the project involves existing business activities, social and/or environmental audits may
need to be performed to determine any areas of concern. The types of issues, risks and
impacts to be assessed, and the scope of the community engagement can also vary
considerably, depending on the nature of the project, and its size, location, and stage of
development” [22]
The Asian Development Bank screens any potential project under consideration for
financing prior to deciding about whether to go ahead with financing. This screening tool
divides the potential projects into three groups. The intensity and depth of environmental
review is different for each of this group [23].
Project in Category A generally require a detailed and comprehensive assessment in the
form of an EIA. This designation is based on nature of project, its size, and proposed
location. These projects are likely to cause significant changes in existing land use
patterns, changes to the socioeconomic environment of the direct project area and its area
of influence, as well as changes to the physical and biological environment. The category
A projects are deemed to be most environmentally sensitive, or having the highest
potential to cause environmental damage if not managed properly. Therefore, ADB
involves its own personnel in such projects from the very early stage; and they keep a
close vigil from field reconnaissance to the review of environmental assessment report.
20

ADB also advises proponents to engage an environmental specialist from the early stage
to determine the scope of the EIA necessary for compliance with the ADB’s
environmental policies. Bank personnel are involved in this category of project from early
field reconnaissance through EIA review.
Projects in Category B typically require an IEE, but not an EIA. The size or scale of the
project generally proves to be core criteria for classifying a project in category A or B,
despite similarity in the nature of the project. Hence large power plant projects are
included category A while medium-sized power plant projects fall under category B.
Nevertheless, any project proposed to be located in an environmentally sensitive area,
falls under category A and requires an EIA, irrespective of its scale. Due to smaller size,
and in some cases simpler type, the environmental impacts from category B projects are
expected to be generally less severe. As a result, it is easier to prescribe and implement
environmental mitigation measures for these projects. As in case of Category A projects,
it is advisable that the proponents engage an environmental specialist to assist in
formulating the Terms of Reference for the IEE so that the IEE report will comply with
Bank policies.
Category C is for projects that do not require an environmental assessment, because under
normal conditions, these projects are unlikely to have adverse environmental impacts.
The categorization procedure in use at the World Bank is explained in the World Bank’s
Operational Manual under Operational Directive 4.01 [24]. The number and
nomenclature of the categories remains the same as in ADB. However, the IEE is part of
the project screening step in the World Bank’s categorization procedure. Hence, the
Category B projects also require an environmental impact assessment, but its depth is
shallower and reliance on secondary data is easily tolerated. This practice of making IEE
a mandatory part of the screening process differentiates the World Bank procedures from
that of the ADB, and loosely aligns it with the environmental procedures currently used in
India. The categories are defined below.
Project Category A: Same as Category A of the ADB, projects in this category typically
require an EIA. The similarity extends to the potential environmental aspects and impacts,
including the likelihood to affect land use patterns, socio-economic environment, as well
21

as changes to the physical and biological environment. A typical example of such projects
is water storage dams etc.
Project Category B: In terms of potential impacts, this category is also similar to
Category B of the ADB. However, the term IEE is not used. The environmental
assessment / review for projects falling under this category usually requires a level of
effort less than that of a full-fledged EIA study.
Project Category C: Same as in the case of ADB, the projects that do not require an
environmental assessment owing to their negligible potential to cause environmental
impacts, fall under this category.
The International Finance Corporation is another development finance institution. It is a
member of the World Bank group, but it has developed and established its own set of
environmental guidelines. IFC also defines three categories for its direct investment
projects, almost in line with the ADB and the WB:
Category A includes projects having potential to cause significant adverse social or
environmental impacts. These impacts are expected to be irreversible, diverse, or
unprecedented.
Category B includes projects having potential to cause adverse social or environmental
impacts, but to a limited extent and relatively easy to mitigate. Such projects generally
have localized impacts that are few in number and / or largely reversible.
Category C includes projects with minimal or no adverse social or environmental
impacts. Projects in this category do not normally entail any sizable physical intervention.
Its example includes certain financial intermediary (FI) projects with minimal or no
adverse risks.
An important point to note here is the clear mention of the word ‘social’. Though it is
universally accepted that the term environmental impact does include impacts on the
social, economic, and cultural environment as well, but by clearly spelling it out, IFC is
22

using this categorization for at least two distinct objectives: firstly, this categorization
guides the depth of the ensuing environmental assessment; secondly, it points to the
public disclosure requirement within IFC’s institutional policy framework. Therefore, in
accordance with Section 12 of the Disclosure Policy, public consultation needs to be
carried out disclosing project specific information to the public and general stakeholders
prior to presenting category A projects to its Board of Directors for approval [25].
United Nations Development Programme (UNDP) has also developed a separate manual
on Social and Environmental Screening Procedures [26]. It requires all projects, funded
through UNDP, to be screened, except for the following:
• Projects with a short budget (under US$500,000) are not subject to environmental
assessment, provided that they comply with other institutional requirements of the
UNDP
• Multilateral projects where other financing partners are involved and UNDP serves
only as the Administrative Agent; such projects may or may not undergo
environmental assessment depending on the policy of the major donor agencies
involved, but UNDP environmental policies are not applicable here.
• Projects chiefly concerned with dissemination and communication; where outputs are
normally comprised solely of report preparation; coordination of event (training /
workshop / meeting / conference etc.), or development of communication materials
and dissemination of results (e.g. documentaries, publications, etc)
The EU has also issued an Environmental Screening Guide to streamline the process of
screening the proposed projects. Again, there is a financial threshold, which is set at 1 M
pounds. However, like UNDP and other development agencies, this guide also notes that
“Below the £1 million threshold screening is also required where there are potential
environmental impacts. It will be difficult to decide whether there are potential impacts
unless you screen, and so it is strongly recommended that screening be carried out even
below this threshold. For example, DFID support to policy development may be below
this threshold but could have significant environmental implications” [27].
Besides guiding about the depth and intensity of the environmental assessment through
the above categorizations, generally the development institutions also have another
category: projects that are disallowed. Such projects are not financed, supported or
23

approved, whichever the case maybe. The potential harmful environmental impacts are
the most important factors in assigning any project to such category. The nomenclature
used for this category is the Exclusion List. For example, IFC’s Exclusion List includes
the following projects [28]:
• Production or trade in any product or activity deemed illegal under host country laws
or regulations or international conventions and agreements.
• Production or trade in weapons and munitions.
• Production or trade in alcoholic beverages (excluding beer and wine).
• Production or trade in tobacco.
• Gambling, casinos and equivalent enterprises.
• Trade in wildlife or wildlife products regulated under CITES.
• Production or trade in radioactive materials.
• Production or trade in or use of unbonded asbestos fibers.
• Purchase of logging equipment for use in primary tropical moist forest.
• Production or trade in pharmaceuticals subject to international phase outs or bans.
• Production or trade in pesticides/herbicides subject to international phase outs or bans.
• Drift net fishing in the marine environment using nets in excess of 2.5 km. in length.
Generally, the development finance institutions are flexible in their approach towards the
excluded projects. IFC applies a ‘reasonableness test’ in such cases where the activities of
the project company are deemed to have a significant development impact, but
circumstances of the host country require adjustment to the Exclusion List. The core
reasons for categorizing a project under the Exclusion List generally do not include
financial viability, but these include cultural, health or ecology related concerns.
24

CHAPTER – 4
DISCUSSION
4.1 Current Screening Schedules
The current categorization for environmental screening, as used by the environmental
protection agency Sindh, is given in the schedules I, II and III of the Sindh EPA Review of
EIA / IEE Rules. It is attached with this thesis as Annex. The three schedules collective
present 11 different categories, under which a large number of potential projects are listed.
In the current schedules, for most categories the chief parameter is the scale or size of the
proposed project, determining whether an EIA is required or an IEE could be sufficient.
Specific size has been mentioned for some 12 projects in Schedule I and 10 projects in
Schedule II. Where specific size is not mentioned, financial threshold has been used as an
indicator of scale; financial size criteria is mentioned for 10 projects in the IEE schedule,
and 04 projects in the EIA schedule. Indirect scale implication could also be found for
many projects in all three schedules. The second most important parameter for this
determination comes out to be the nature of the project. For the location based criteria,
there is a clear and sweeping statement for projects located in environmentally sensitive
areas: all such projects will need to undergo an EIA, irrespective of their scale or nature.
The effort to use a combination of all these parameters is also evident.
According to the respondents of interviews conducted for this assignment, the three
schedules are a good improvement over the previously existing two schedules of PEPA-
1997. As previously mentioned in this thesis, the Sindh EPA was able to make good use of
the hindsight available in the form of more than a decade and a half. According to the
experts, this is a clear indication that Sindh EPA has learnt from experience and is willing
to apply this learning to move the agenda of environmental improvement forward. The
Sindh EPA officials affirmed that their institution looks forward to every opportunity to
further update and fine-tune the provincial environmental legislation. They see it as a
“live” document and wish to better it whenever the opportunity presents itself.
25

The following tables attempt to reproduce these schedules from the current provincial and
previous federal statues in a format enabling a comparative view of the categories EIA and
IEE. Since there was no category for projects requiring environmental checklist in the
previous federal legislation, a comparison is not possible for that category:
Table 5: Comparison of SEPA Schedule I & PEPA Schedule I (Projects Requiring
IEE)
Categories
Projects requiring IEE under
SEPA (Schedule I)
PEPA (Schedule I)
Agriculture,
Livestock and
Fisheries
Poultry, livestock, stud and fish
farms
Poultry, livestock, stud and fish
farms with total cost more than
Rs.10 M
Packaging, formulation, cold
storage and warehouse of
agricultural products.
Projects involving repacking,
formulation or warehousing of
agricultural products
Energy
Hydroelectric power (less than
50 MW)
Hydroelectric power generation
less than 50 MW
Thermal power (less than 100
MW)
Thermal power generation less
than 200 KW
Coal power plants (less than 50
MW)
Transmission lines less than 11
KV, and grid stations
Transmission lines less than 11
KV, and large distribution
projects
Waste-to-energy generation
projects including bio-mass less
than 25 MW
Waste-to-energy generation
projects
Solar project
Wind project
Oil and gas transmission systems
Oil and gas extraction projects
including exploration,
production, gathering systems,
separation and storage
Oil and Gas
projects
O&G 2D/3D Seismic survey and
drilling activities
O&G extraction projects
including exploration and
production (outside any
protected / environmentally
sensitive area)
LPG storage facilities
26

Categories
SEPA (Schedule I)
PEPA (Schedule I)
LPG, CNG filling station and
petrol pumps
Manufacturing and
processing
Ceramics and glass units (cost
less than Rs. 500 m)
Ceramics and glass units with
total cost more than Rs.50
million
Food processing industries with
total cost less than Rs. 200 m
Food processing industries
including sugar mills, beverages,
milk and dairy products, with
total cost less than Rs.100 million
Pharmaceutical units.
Marble units
Carpet manufacturing units
Rice mills, ghee/oil mills
Brick kilns
Stone crushing units
Man-made fibers and resin
projects with total cost less than
Rs. 200 M
projects with total cost less than
Rs.100 million
Manufacturing of apparel, textile
garments unit , including dyeing,
bleaching and printing, with
total cost less than Rs. 50
million
Manufacturing of apparel,
including dyeing and printing,
with total cost more than Rs.25
million
Wood products with total cost
more than Rs.100 m
Wood products with total cost
more than Rs.25 million
Steel re-rolling mills
Recycling plants
Mining and
mineral processing
Commercial extraction of sand,
gravel, limestone, clay, sulphur
and other minerals not included
in Schedule II with total cost
less than Rs.100 million
Commercial extraction of sand,
gravel, limestone, clay, sulphur
and other minerals not included
in Schedule II with total cost less
than Rs.100 M
Crushing, grinding and
separation processes
Crushing, grinding and
separation processes
Smelting plants with total cost
less than Rs100 m
Transport Flyovers, underpasses and
bridges having total length less
than 500 meters
Federal or Provincial highways
(except maintenance, rebuilding
or reconstruction of existing
27

Categories
SEPA (Schedule I)
PEPA (Schedule I)
metalled roads) with total cost
less than Rs.50 M
Ports and harbor development for
ships less than 500 gross tons
Water
management,
dams, irrigation
and flood
protection
Dams and reservoirs (with
storage volume less than 25
million cubic meters and surface
area less than 4 square
kilometers)
Dams and reservoirs with storage
volume less than 50 million cubic
meters of surface area less than 8
square kilometers
Small-scale irrigation systems
and drainage system (total cost
less than Rs. 100 M)
Small-scale irrigation systems
with total cost less than Rs.50
million
Irrigation and drainage projects
serving less than 15,000 hectares
Water supply and
filtration
Water supply schemes and
filtration plants – new or
maintenance / up-gradation of
existing (total cost less than Rs.
100 m)
treatment plants with total cost
Waste disposal
and treatment
Handling, storage or disposal of
Solid and non-hazardous waste
(annual capacity less than
10,000 tons)
Waste disposal facility for
domestic or industrial wastes,
with annual capacity less than
10,000 cubic meters
Sewage treatment facility (total
cost less than Rs. 200 M)
Industry specific Waste water
treatment facility for Industrial
effluent (small scale plant)
Urban
development (and
tourism and
communication)
Housing schemes less than 10
acres
Housing schemes
Multi-story buildings having
residential and commercial setup
on the total plot size is less than
2000 sq. yards
Hospitals with capacity of 50
beds, health care
unit/laboratories with 500 OPD /
day
28

Categories
SEPA (Schedule I)
PEPA (Schedule I)
Construction of Educational,
Academic institutions on land
less than 10 acres.
Public facilities with significant
off-site impacts (e.g. hospital
wastes)
Urban development projects
Other projects
Any other project for which
filing of an IEE is required by
the Agency under sub-regulation
(2) of Regulation 6
Any other project for which filing
of an IEE is required by the
Federal Agency under sub-
regulation (2) of Regulation 5
Table 6: Comparison of SEPA Schedule II & PEPA Schedule II (Projects Requiring
EIA)
Categories
Projects requiring EIA under
SEPA (Schedule II)
PEPA (Schedule II)
Energy
Hydroelectric power (above 50
MW)
Hydroelectric power generation
over 50 MW
Thermal power (above 100 MW)
Thermal power generation over
200 MW
Coal power projects (above 50
MW)
Transmission lines (11 KV and
above) and electricity distribution
projects.
Transmission lines (11 KV and
above) and grid stations
Nuclear power plants Nuclear power plans
Wind energy projects (located in
any sensitive / protected area)
Petroleum refineries
Oil and Gas Petroleum refineries
29

Categories
SEPA (Schedule II)
PEPA (Schedule II)
projects
LPG and LNG Projects
(including LNG Terminals, re-
gasification units) except LPG
filling stations
O&G transmission systems
O&G gathering system,
separation and storage.
Manufacturing
and processing
Cement plants Cement plants
Chemical manufacturing
industries
Chemicals projects
Fertilizer plants Fertilizer plants
Steel Mills
Sugar Mills and Distilleries
including beverages, dairy milk
and products, slaughter houses
and related activities with total
cost more than Rs. 200 m
including sugar mills,
beverages, milk and dairy
products, with total cost of
Rs.100 million and above
Industrial estates (including
export processing zones)
Industrial estates (including
export processing zones)
projects with total cost of Rs 200
M and above
projects with total cost of
Rs.100 M and above
Pesticides (manufacture or
formulation)
Pesticides (manufacture or
formulation)
Petrochemicals complex Petrochemical complex
30

Categories
SEPA (Schedule II)
PEPA (Schedule II)
Synthetic resins, plastics and
man-made fibers, paper and
paperboard, paper pulping, plastic
products, textiles (except
apparel), printing and publishing,
paints and dyes, oils and fats and
vegetable ghee projects, with
total cost more than Rs. 10 m
Synthetic resins, plastics and
man-made fibers, paper and
paperboard, paper pulping,
plastic products, textiles (except
apparel),printing and
publishing, paints and dyes, oils
and fats and vegetable ghee
projects, with total cost more
than Rs.10 million
Tanning and leather finishing
projects
Tanning and leather finishing
projects
Battery manufacturing plant
Mining and
mineral
processing
Mining and processing of coal,
gold, copper, sulphur and
precious stones
Mining and processing of coal,
gold, copper, sulphur and
precious stones
Mining and processing of major
non-ferrous metals, iron and steel
rolling
Mining and processing of major
non-ferrous metals, iron and
steel rolling
Smelting plants with total cost of
Rs. 100 m and above
of Rs.50 million and above
Transport Airports Airports
Federal or Provincial highways or
major roads (including
rehabilitation of existing roads)
Federal or Provincial highways
or major roads (except
maintenance, rebuilding or
reconstruction of existing roads)
with total cost of Rs.50 million
and above
Ports and harbor development
Ports and harbor development
for ships of 500 gross tons and
above
Railway works Railway works
Flyovers, underpasses and
bridges having total length of
31

Categories
SEPA (Schedule II)
PEPA (Schedule II)
more than 500 m
Water
management,
dams, irrigation
and flood
protection
Dams and reservoirs (with
storage volume of 25 million
cubic meters and surface area of
4 square km and above)
Dams and reservoirs with
storage volume of 50 million
cubic meters and above or
surface area of 8 square
kilometers and above
serving 15,000 hectares and
above
serving 15,000 hectares and
above
Flood Protection
Water supply and
filtration
Large Water supply schemes and
filtration plants
treatment plants with total cost
of Rs.25 million and above
Waste disposal
and treatment
Handling, storage or disposal of
hazardous / toxic / radioactive
waste
Waste disposal and/or storage of
hazardous or toxic wastes
(including landfill sites,
incineration of hospital toxic
waste)
Waste disposal facilities for
municipal or industrial wastes
(total annual capacity of 10,000
tons and above)
Waste disposal facilities for
domestic or industrial wastes,
with annual capacity more than
10,000 cubic meters
Waste water treatment facility for
industrial or municipal effluents.
Urban
development (and
tourism and
communication)
Housing schemes above 10 acres
Residential/commercial high rise
Buildings / apartments from15
stories and above.
Land use studies and urban plans
(large cities)
Land use studies and urban
plans (large cities)
Large scale public facilities.
32

Categories
SEPA (Schedule II)
PEPA (Schedule II)
Large-scale tourism development
projects
Large-scale tourism
development projects with total
cost more than Rs.50 M
Environmentally
Sensitive Areas
All projects situated in
environmentally sensitive areas
All projects situated in
environmentally sensitive areas
Other projects
Any other project for which filing
of an EIA is required by the
Agency under sub-regulation (2)
of Regulation 5.
Any other project for which
filing of an EIA is required by
the Federal Agency under sub-
regulation (2) of Regulation 5
Any other project likely to cause
an adverse environmental effect
Any other project likely to
cause an adverse environmental
effect
In the previous Federal statute (EIA / IEE Regulations 2000) [29], there were 10
categories, and the listed projects were also less in number. The new provincial statute has
carried forward the 10 categories previously established in the federal law, and added
another important category of ‘Oil & Gas projects’. This has enabled a neater and clearer
arrangement of the projects in the list.
An important thing to note is that the SEPA schedules tend to put more stringent
requirements in many cases. Though a few interview respondents pointed out that the
financial threshold values have been doubled in almost all cases, others countered by
arguing that the cumulative inflation of 17 years (1997 to 2014) warrants more than
doubling. In some other cases, e.g. dams and reservoirs, EIA is now required if the project
has half the capacity compared to the previous one.
There are a couple of appreciable improvements in SEPA schedules, when compared to
PEPA. For one, it provides a larger list of projects, covering more ground. Secondly, and
equally importantly, for the new entries in the lists, it has lessened the previous tendency
of using financial threshold as the main parameter to determine the assessment level
requirements. The new schedules have removed financial thresholds and instead inserted a
more direct measure of scale. Hence, for example, any housing schemes planned over an
area of less than 10 acre will need an IEE but if it is more than 10 acres, an EIA will be
required.
33

Having established that, it is also abundantly clear that there are many areas where the
current screening process could be improved. Some of these improvement possibilities are
discussed in the next sections of this thesis.
4.2 Freedom of Interpretation
The first issue highlighted during the interviews was the limitation of using the schedules
as legally binding instruments. There was a general consensus amongst the respondents
that awareness about environmental issues has improved much over the time the PEPA
1997 came into force. At that time, it was required that not much is left for independent
interpretation by the proponents or the consultants, due to a general lack of environmental
awareness. Therefore, the Environmental Protection Agency took it upon itself to clearly
identify which projects should undergo an EIA and where an IEE could be sufficient.
However, the level of awareness is much better on all sides now, therefore, the
requirements could be made open to some interpretation. As mentioned in Section 3.5 of
this thesis, even the guidelines issued in 1997 by the Pak-EPA contained good guiding
statements at the beginning of the lists of projects requiring EIA or IEE. This made it
possible to interpret as to the spirit of the law, so that any projects that are incidentally
omitted from this list, could be treated accordingly. The respondents pointed out that this
is not the case in the Sindh EIA / IEE Regulations, where Rule 3 and 4 just indicate the
schedules. The schedules, in turn, do not have any guiding statements, and only provide
lists of projects.
It is evident that not all possible projects could be listed in the schedules, and there always
is a likelihood of some project propping up that is not included in any of the schedules.
This situation does arise often, according to the consultants and proponents interviewed. It
generally leads to quite a bit of confusion as to what level of assessment should be
conducted. Narrated by one of the interviewees, a recent example is the construction of a
diesel storage depot by an OMC (Oil Marketing Company) near the city of Shikarpur in
the upper Sindh. It is not listed in any of the current three schedules. In the absence of a
clear guiding statement anywhere in the law, the proponent was forced to contact EPA for
a clear advice. Unfortunately EPA has very limited resources, and takes a long time in
responding to such queries even after consistent follow-up. This resulted in undue delays,
and the project went into cost overruns.
34

Similarly, there are many instances where the schedules require EIA for a project, while in
reality this exercise does not yield any new meaningful information. As an example, one
respondent pointed out a recent case where a 14 km gas pipeline from an existing
wellhead to an existing industrial unit was to be laid. The line ROW (right of way) was
already secured as it was alongside an existing line of the same dimensions. The oil and
gas transmission systems have been included in schedule II where an EIA is required,
whereas in the above case, no new information or major environmental impact could be
foreseen by conducting a full blown EIA. In the absence of any guiding principles given in
the statute, it becomes very difficult to logically handle this case. We should also consider
the fact that cost of an EIA is generally 3 – 4 times that of IEE if not more. Add to this the
rampant corruption in the Government departments, and the situation becomes really
complex.
Two opposing arguments were presented during interviews regarding this aspect. Most
project proponents were of the view that leaving the interpretation only to EPA leads to
very stringent requirements put forward by them. This, coupled with the perceived
corruption in the Government institutions, makes most proponents very skeptical about the
appropriate use of screening schedules. On the other hand, EPA officials contend that if
the interpretation is kept open, all types of objections are raised by public. They sought the
example of the LNG terminals in this respect. For the first proposed LNG terminal, EPA
itself was not experienced and hence it took a long time to reach a decision. But by the
time the next LNG terminals came, enough information and experience was available with
EPA to come up with a decision early, and with less stringent conditions. However, this
did not go down well with the proponents of the first one, and they accuse the EPA of
biased approach towards the two similar projects discouraging the former one and
favoring the latter one.
Therefore, it could be suggested that spirit of the law, rather than the letter, should be
followed. It is highly desirable to include a guiding principle at the head of each of the
three schedules. The guiding principles could be borrowed from any of the development
institutions. The text available in the guidelines issued by Pak-EPA in 1997 also still holds
true, and it could also be used as the guiding statements.
35

4.3 Core Parameters for Categorization
The second issue highlighted during the interviews, and also revalidated through literature
review, is that some of the core parameters are perceived to be not taken into account
while developing the schedules.
Some of the respondents do not agree with the current lists because these have limited
focus on the assimilation capacity of the receiving environment. Though the schedules do
mention that projects in the declared environmentally sensitive areas will need an EIA,
there is no mention of, for example, a thickly populated area. Hence a cement plant will
need an EIA no matter if it is being set in proximity of Kotri, or at a deserted and
uninhabited place in the vast expanses of Thano Bola Khan. For industrial development
specially, this is already a bone of contention. An industrial zone is a development that is
designed to lead to sub-developments. Industrial zones are, naturally, subject to detailed
EIAs. Therefore, many respondents argued, individual industrial units coming up in
designated industrial zones complying with their original zoning plans should be subjected
to environmental assessment of a cursory level. This is not currently reflected in the SEPA
2014. Hence, a textile garment unit being set up in Korangi Creek Industrial Park is
subject to the same level of environmental scrutiny as a unit built and operating in the
proximity of residential areas (e.g. New Karachi).
Another respondent expressed the opinion that due weightage has not been given to
technological advancement. For example, in case of wastewater treatment plants, modern
plants could treat a very big volume of effluent with a high level of efficiency, while the
older technology could only offer 30-40 % efficiency. Therefore, besides the treatment
capacity of treatment plant, the treatment technology could also be a deciding factor as to
whether an EIA is to be conducted or an IEE is sufficient. However, a counter argument is
that more sophisticated technology can lead to higher frequency of failure, in view of the
limited capacity of infrastructure and human resources available in Pakistan. In case of
failure, modern plants tend to cause greater degree of harm, and therefore, they need to be
more minutely studied before implementation. But then again, latest technology generally
comes with better environmental safeguards built-in. Hence the argument of considering
technology could not be easily rejected.
36

4.4 Financial Threshold
The third and another interesting issue is that of the financial threshold. Financial
threshold has been used as an indicator of scale of a project – and thus its potential
environmental impacts – in the screening schedules of EPA. However, it should be noted
that the current legislation uses this method – rather than specific size of capacity – in case
of a total of 14 projects, down from the 17 in the previous federal legislation. Furthermore,
these 14 are out of a much larger list of projects, compared to the previous one.
One respondent, who has been part of the environmental statutory regime in Pakistan, says
that the financial threshold criteria is not a valid one in our circumstances. He argues that
if two industrial plants of same capacity are built, the one with better technology and
lower waste generation potential will almost certainly be more expensive. Hence applying
the financial threshold criteria means that we will have an EIA for a plant that is expected
to have lower environmental impacts to begin with, while for the plant with potentially
more environmental impacts, an IEE would be legally sufficient.
This argument is particularly relevant for the industrial development, for newer
technology is more expensive but more resource efficient hence more environmentally
sustainable. Furthermore, even in the new technology, there are often options to
incorporate environmental safeguards. An example is the industrial boiler. An economizer
is an equipment that makes use of the heat emitted by a boiler due to combustion, and pre-
heats the boiler feed water, thereby reducing the change of temperature required from the
boiler. With the same basic technology, boilers of the same capacity are available with or
without economizer. While economizer does increase the capital expenditure, it definitely
brings down the environmental emissions and puts much less burden on the fuel resources
when compared to a boiler without economizer. This improves environmental
performance but simultaneously increases the capital cost.
An EPA representative agrees with it only partially though. He says that applying cost
threshold criteria is still a good idea to infrastructure and other projects where technology
is not an element with importance. He uses the example of development agencies in
support of his argument, where a financial threshold is applied to ensure that projects with
lower total cost do not have to assign a substantial sum of their budgets towards
environmental assessment costs. Interestingly, the current schedules apply the financial
threshold criteria more on the industrial development than on the infrastructure projects.
37

Another confusion in the ambit of financial threshold is the cost of land. In many projects,
cost of land is the single biggest contributor in the total project cost. In case of industrial
units, there are many instances when the land is acquired as a whole piece and then
various industrial components are put in place. There is no clarity to apportion the land
cost in such cases. Similarly, in many public sector projects, development is carried out on
Government lands with low or no price tag attached to it. Nonetheless, this does not
reduce the potential environmental burden of the proposed project. In fact, in some cases
where the land cost is low, the environmental and social impacts are likely to be more
intense, in terms of receiving environment and community. A case in point is Thar Desert
where cost of land is very low. Hence, making a road there is not very costly. But that
ecosystem is very fragile and the social system there is also very peculiar, inhabited by
highly marginalized communities. Therefore, subjecting a project to less stringent
environmental scrutiny on the basis of upfront cost does not seem to be an appropriate
approach in such cases.
4.5 Clarity on Jurisdiction
The fourth issue emanates from the devolution of the subject of environment from federal
to provincial level. As author Firoza Pastakia mentions, the PEPA 97 operated at the
federal level, overriding any contradicting provisions in other federal or provincial laws.
Even under those clearer circumstances, the issue of jurisdiction did prop up every now
and then. When some development project was proposed on the Bundal Island located at
the mouth of the Port Qasim Navigation Channel in 2009, there was a number of
claimants over the jurisdiction of this piece of land, including Pakistan Navy, Maritime
Security Agency, Port Qasim Authority, Korangi Creek Cantonment Board and the City
District Government Karachi. Even the provincial forest department laid a claim, based on
the fact the part of the island came under cover of mangrove forests. Arising out of this
confusion, the next question was who would be responsible to review and approve the
environmental assessment of the proposed project. Here again, both Sindh EPA and the
Federal EPA has claims over the jurisdiction.
SEPA 2014 is a provincial law, and hence all federal laws can override it in case of any
contradiction in the legal provisions. More important in terms of the current study is the
fact that PEPA 97 used to govern all activities that have the potential to cause
environmental damage, including those exclusively under the purview of federal
government e.g. nuclear power plants. Under post-18th
amendment scenario, there are
38

many subjects where federal government retains its exclusive authority, and hence, they
are out of the ambit of provincial environmental law. However, this technicality has also
been not clearly defined in the current provincial statutes. Some of the areas where federal
laws hold sway over the provincial laws are:
– Major ports
– Shipping
– Mining
– Highways
– Nuclear energy
– Oil & Gas
– Railways
Experts suggest that besides the three schedules, there should also be an exclusion list,
enlisting projects that fall under federal jurisdiction. This will be different than the
exclusion lists of the development financial institutions that provide lists of projects the
particular institution does not finance as a policy. The EPA exclusion list should be
ambivalent, neither supporting nor opposing in its tone towards the themes that come
under the federal purview. The interviewees think that this will also save Sindh EPA from
a lot of hassle. They noted that the environmental approval granted by the Sindh EPA to a
proposed nuclear power project being set up by a Chinese company near the KANUPP
brought about much criticism from various quarters, particularly the civil society and
others. This criticism would not have been directed towards the Sindh EPA, had it
maintained its neutrality over a matter that actually does not come under its mandate.
4.6 Integration of Environmental Checklist into the Act
The introduction of environmental checklist in Schedule III, to cover projects that are
likely to have only insignificant environmental impacts, was hailed by most respondents
as a very good step. It will support in portraying the true sense of the environmental
legislation, they argued, by depicting that lower potential of damage to environment needs
lower level of environmental planning at the outset. However, they point out that
seemingly, this concept has come in only as an afterthought. This is evident by studying
39

the Sindh Environmental Protection Act in some detail. Sub-section (1) of section 17
makes it binding upon the proponents of any project to carry out and file “an Initial
Environmental Examination or Environmental Impact Assessment” and get approval from
the Agency. There is no mention of Environmental Checklist here. Perhaps more
importantly, there is no mention of environmental checklist in sub-section (4) of section
17 of the Act, which sets out the time limits for invoking the “deemed approval”. This
clause binds the Environmental Protection Agency (Sindh) to convey its decision within
two months in case of IEE, and within four months in case of EIA, otherwise the project is
deemed to be approved. But no time frame has been given to EPA in case of
environmental checklist. The interview respondents opined that this is an important
omission. They were of the view that given the various limitations faced by the EPA,
including limited HR capacity, the EPA tends to give priority to larger proposals. This
approach is appropriate as well, because larger projects may cause larger damage to the
environment. However, it also results in unnecessary delay in granting approvals to the
micro projects where only environmental checklist was needed and filed. This discourages
the proponents of smaller projects to get in the ambit of the law, defeating the very
purpose of introducing the concept of environmental checklist.
4.7 List of Projects NOT Requiring Environmental Assessment
Another issue is to complete the cycle by defining which projects do not require any level
of environmental assessment. Previously, the environmental guidelines issued by the Pak-
EPA had three schedules: one each for EIA, IEE, and projects where no environmental
assessment is required. But when the Pak-EPA issued the EIA / IEE Regulations in year
2000, it included only two schedules and done away with the third one. The current SEPA
has taken a step in the right direction by introducing environmental checklist, thereby
making sure that almost 100% of activities that has the potential to cause environmental
impact are not only covered, but covered with the appropriate level of assessment.
However, it has continued the practice of omitting with the schedule identifying activities
where no environmental assessment is required. In this regard, using the previous schedule
C of Pak-EPA after due amendments could be a good solution.
4.8 Errors & Omissions
Finally, there are certain errors and omissions that were pointed out during the interviews.
These might be due to an error in judgment, or typographical error. For example, petrol
40

and CNG filling stations have been classified in Schedule I, requiring IEE, while an
environmental checklist could be a more apt option. Another example is bracketing of
textile garment units with dyeing / printing units and then applying a financial threshold
on it. Textile wet processing is a resource-intensive activity, specially in terms of water
usage. Whereas, textile garments manufacturing does not require use of many natural
resources. It is evident that textile garment units have minimal environmental impacts
whereas textile wet-processing has significant environmental impacts. Therefore, such
units should not be bracketed under the same category with the same financial threshold.
Interestingly, in Schedule II, it clearly excludes the textile apparel, meaning that
technically apparel units upto the defined financial threshold could file an IEE, but apparel
units above that threshold are outside the legal ambit. Similarly, Schedule I includes
multistory buildings mentioning the plot size but not mentioning the number of
permissible stories, whereas schedule II also includes multistory buildings, this time
defining the number of stories permitted but without any mention to the plot size.
Some of the respondents were of the opinion that only the really large projects must be
asked to go for an EIA. They think that the current list of projects requiring EIA is far too
long, and it essentially undermines the spirit of the EIA process. By strengthening the IEE
requirements, many projects from Schedule II could be taken to Schedule I. EIA should be
mandatory only where the scale of the project is very large, involuntary resettlement is
part of the project and / or the project is located in an environmentally sensitive area.
41

CHAPTER – 5
CONCLUSIONS & RECOMMENDATIONS
It is a known fact that enforcement of the law, rather than its development, pose a greater
challenge in Pakistan. However, as could be seen in the deliberations of the previous
chapter, a well-formulated legal instrument could be instrumental in smoother legal
enforcement. Therefore, this thesis attempts to list out certain policy level measures, that
could improve the quality of the current environmental schedules, automatically but
indirectly supporting its true implementation.
Nevertheless, being an exploratory study, this thesis could not formulate any
recommendations in terms of concrete design and built-in objectively verifiable indicators.
This thesis also does not intend to take up the task of formulating any list of suggested
changes in the existing schedules, respecting the fact that this task should only be carried
out through a consultative process in a group of environmental professionals and
stakeholders.
Following are the suggestions – points to ponder – that came out through discussions with
various experts and review of literature sources during the course of this assignment:
• Though the SEPA schedules are good starting points, there is a need to further
improve it to overcame various limitations.
• There is need to build trust between various stakeholders, to ensure sanctity of the
process and integrity of the system.
• The schedules should be revised after extensive consultation with pertinent
stakeholders, as was the case with the development of Sindh Environmental Protection
Act 2014.
42

• There should be certain guiding statements, either at the top of the three schedules, or
defined within the text of legislation itself, to ensure justified interpretation and to
account for any project that may not be listed.
• Spirit of the law, rather than the letter, should be followed. This is particularly
important while interpreting various clauses of the SEPA 2014.
• Core parameters for categorization (e.g. technology, population of the project area,
biological conditions of receiving environment etc.) should be clearly spelt out.
• There is a need to revisit the financial threshold criteria by a team of experts. It should
be applied to only projects with low level of technology.
• Subjects that are directly governed by the Federal Government should be removed
from the SEPA schedules
• List of projects that do not require any environmental assessment should also be
clearly established.
• The schedules must be rechecked in terms of current entries and errors and omissions
must be corrected.
• To reap the intended benefits of the concept of environmental checklists, it should be
clearly mentioned in the main text of the Act.
• Timeframe for environmental approval of projects falling under the Schedule III
should be clearly established.
43

List of References:
1. Senecal, P. et al. Principle of Environmental Impact Assessment Best Practice.
(online) International Association for Impact Assessment in cooperation with
Institute of Environmental Assessment, UK, January 1999, (Accessed November
12, 2015). Available from: http://www.iaia.org/publicdocuments/special-
publications/Principles%20of%20IA_web.pdf
2. Ayaz, Saaudullah. Discussion Paper on Institutional Framework and
Coordination Mechanism for Environmental Impact Assessment in Pakistan,
Islamabad: National Impact Assessment Program, March 2013
3. DFID Environment Guide – A guide for environmental screening. Department for
International Development, UK. June 2003
4. Khan, Asif Shuja, Stepping forward towards better environment – The past,
present and future, (Online), April 2002. (Accessed November 12, 2015).
Available at:
http://unpan1.un.org/intradoc/groups/public/documents/APCITY/UNPAN004682.
pdf
5. Khan, Azheruddin. Past, Present & Future of NEQS Implementation in Pakistan.
Sustainable Development – Bridging the Research / Policy Gaps in Southern
Context; Vol-I: Environment, (p-89), Islamabad: Sustainable Development Policy
Institute, Oxford University Press, 2005
6. Alrai, IRFAN SAEED, Environmental Regulatory Framework in Pakistan.
Islamabad: NEAP-SP, UNDP/ Government of Pakistan, 2003
7. Pastakia, F. Environmental Protection and the 18th
Amendment – Impacts of
Constitutional Amendments on Environmental Protection Legislation, Analysis of
Laws in Force, and Assessment of Implementation Issues. Islamabad: National
Impact Assessment Programme, 2012
8. International Finance Corporation. Guidance Notes: Performance Standards on
Social and Environmental Sustainability [online]. April 2010. [Accessed 3
November 2015]. Available from:
http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_si
te/ifc+sustainability/our+approach/risk+management/performance+standards/envir
onmental+and+social+performance+standards+and+guidance+notes#2006
9. Hveem, H. & Beas, M. The Trade-Environment Debate: Pre-negotiation,
Negotiated Agreement, and Implementation. In: O.K. Fauchald & M. Greaker, ed.
Environmental Assessment of Trade Agreements and Policy. Copenhagen: Nordic
Council of Ministers, 1998, pp.21-35.
10. Government of Saskatchewan. How does screening by the Environmental
Assessment Branch differ from an environmental assessment? [online]. 2013.
[Accessed 4 November 2015]. Available from:
http://www.environment.gov.sk.ca/Default.aspx?DN=78f75774-d028-403d-9f05-
9df428005678
11. Aslam, F. EIA in Pakistan – Overview, Implementation & Effectiveness. TRITA,
LWR Masters Thesis, June 2006
12. Pakistan Environmental Protection Agency. Policy and Procedures for the Filing,
review and approval of environmental assessments. October 1997.
13. Pastakia, F. Environmental Protection and the 18th Amendment – Impacts of
Constitutional Amendments on Environmental Protection Legislation, Analysis of
Laws in Force, and Assessment of Implementation Issues. Islamabad: National
Impact Assessment Programme, 2012
44

14. Pakistan Environmental Protection Agency. Policy and Procedures for the Filing,
review and approval of environmental assessments. October 1997. Annex I,
Schedule A
15. Ibid. Annex I, Schedule C
16. Pakistan Environmental Protection Agency. Guidelines for the Preparation and
review of Environmental Reports. October 1997
17. Sindh Environmental Protection Agency. The Sindh Environmental Protection Act
2014. March 2014
18. Government of Nepal. Environmental Protection Rules 2054. 1997
19. Sobhan, M.A. Sharing Experiences of EIA in Bangladesh. Dhaka: Department of
Environment, Bangladesh. 2012
20. Kumar, A. EIA notification and its Implementation in India. (Online), October 2012.
(Accessed November 12, 2015). Available at:
http://www.sciencebeing.com/2012/10/eia-notification-and-its-implementation-in-
india/
21. Government of India, Ministry of Environment & Forests. Environmental Impact
Assessment Notification S.O. 1533. September 2006
22. International Finance Corporation. Performance Standards I – Social &
Environmental Management System. April 2006.
23. Asian Development Bank. Environmental Considerations in Bank Operations
Section 21. 1993.
24. The World Bank. Operational Directive 4.00 & 4.01. 1993
25. International Finance Corporation. IFC’s Policy on Social & Environmental
Sustainability. 2012
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Procedures [online]. January 2015. [Accessed 3 November 2015]. Available from:
http://www.undp.org/content/dam/undp/library/corporate/Social-and-Environmental-
Policies-and-Procedures/UNDP-Social-Environmental-Screening-Procedure-
1January2015.pdf
27. Department for International Development, Government of the UK. DFID
Environmental Guide – A guide to environmental screening. June 2003
28. International Finance Corporation. Environmental & Social Review Procedures.
April 2006
29. Pakistan Environmental Protection Agency. Review of IEE & EIA Regulations
2000. SRO 339(1)/2001. 2001
45

Bibliography
Following literature resources were reviewed, besides the reference given in the list of
references, for developing a general understanding about the research topic and its related
issues:
1. Qadar S., and Dogar A. R., Pakistan’s Environmental Laws & Their Compliance,
Lahore Law Times Publications, 2002.
2. Asian Development Bank, EIA Report of Jalalpur Irrigation Project, NESPAK,
Lahore. 2015
3. Government of Pakistan, National Environmental Policy, Islamabad. 2005
4. Sustainable Development Policy Institute, Sustainable Development: Bridging the
Research / Policy Gaps in Southern Context. Volume I: Environment. Islamabad:
Oxford University Press. 2005
5. Government of Pakistan, The Pakistan National Conservation Strategy. Islamabad.
1993
6. American Society of Technical Measurements, Environmental Site Assessment
Standards. 1998
7. USEPA Website: www.epa.gov
8. Pakistan EPA Website: www.environment.gov.pk/
9. Sindh EPA Website: www.sindh.gov.pk/dpt/Environment/
10. International Standardization Organization (ISO). ISO 14001:2004 standards.
2004
11. Planning & Development Department, Government of Sindh. Sindh Vision 2030.
National Management Consultants. 2007
12. Westat, J.F. The User Friendly Handbook of Project Evaluation. National Science
Foundation. Arlington: 2002
13. Pakistan Environmental Protection Agency. Sectoral Guidelines for
Environmental Reports. 1999
14. Punjab Environmental Protection Agency. Punjab Environmental Protection Act.
2012
15. Balochistan Environmental Protection Agency. Balochistan Environmental
Protection Act. 2012
16. Sindh Environmental Protection Agency. Sindh Environmental Protection Act.
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17. Caribbean Development Bank. Guidance Manual: Environmental Screening
Checklists & Guidelines for BNTF7 Programme. 2015
46

Annexure – 1
IEE / EIA Regulation 2014
47

GOVERNMENT OF SINDH
SINDH ENVIRONMENTAL PROTECTION AGENCY
Karachi dated the 16th
December, 2014.
NOTIFICATION
NO.EPA/TECH/739/2014:- In exercise of the powers conferred by section 37 of the
Sindh Environmental Protection Act, 2014, the Sindh Environmental Protection Agency,
with the approval of Government, is pleased to make the following regulations, namely:-
1. Short title and commencement
(1) These regulations may be called the Sindh Environmental Protection
48

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