Environmental Assessment - epd.punjab.gov.pk Technical submission.pdf · Mr. Abdul Moiz Ms. Bisma...

Environmental Assessment

Submission 5.2

Environmental Approvals/ EIAs Market

Based Instruments for Environmental

Management

Restructuring and Capacity Building of

Environment Protection Department Punjab

Restructuring and Capacity Building of

Environmental Protection Department Punjab

1. Inception Report

2. Gap Analysis Report

3. Restructuring Report

3.1: Training Need Assessment Report

3.2: Restructuring of Environmental Governance in Punjab

4. Legal Report

4.1: Report on Multilateral Environmental Agreements

4.2: Environmental Governance and Monitoring Framework of Punjab

4.3: New and Amended Laws, Rules, Regulations, Guidelines, SOPs, Checklists

5. Technical Report

5.1: Environmental Laboratories, SOPs for Environmental Sampling, Recommendations on

Environmental Quality Standards, Environmental Modelling, Monitoring Framework and

Curriculum

5.2: Environmental Approvals/EIAs, Market-based Instrument for Environmental Management

6. Information and Communication Technology Solutions Report

7. Final Report

DISCLAIMER

Urban Sector Planning and Management Sector Unit (Private.) Limited, (USPMSU) has prepared this

report for purpose of Restructuring and Capacity Building of Environmental Protection Department

(EPD). Extreme care and caution has been observed while developing this document.

No part of this document may be reproduced or transmitted in any form or by any means, electronic or

mechanical, including photocopying, recording or information storage and retrieval system, without

the express permission, in writing, by competent authority.

Authors

Mr. Tapio Reinikainen

Ms. Keinänen Auli

Mr. Ville Hokka

Mr. Abid Hussainy

Mr. Hassan Ilyas

Mr. Abdul Moiz

Ms. Bisma Mir

Ms. Amber Aleem

Technical Review Team

Dr. Nasir Javed

Mr. Alexis Gazzo

The Urban Unit

503-Shaheen Complex, Egerton road, Lahore

Tel: +42 992005316-22

Fax : +42 99205323

Email: [email protected]

Website: www.urbanunit.gov.pk

Table of Contents

Cumulative Environmental Impact Assessment (CEIA) Framework ............................................. 1

Section 1 ................................................................................................................................................. 1

1.1. Introduction ............................................................................................................................ 1

1.2. Definition ................................................................................................................................ 2

1.3. Classifications of CEIA .......................................................................................................... 2

1.4. Need for conducting CEIA ..................................................................................................... 3

1.5. CEIA requirement in EPA Review ......................................................................................... 6

1.6. Challenges in CEIA ................................................................................................................ 6

Section 2 ................................................................................................................................................. 8

2.1. Preparatory framework of CEIA ............................................................................................ 8

2.2. Step 1: Scoping – VECs, Spatial & Temporal Boundaries and Environmental Drivers ........ 8

2.3. Step 2: Establish Baseline on Status of VECs ...................................................................... 10

2.4. Step 3: Assess Cumulative Impacts on VECs ...................................................................... 12

2.5. Step 4: Assess Significance of Predicted Cumulative Impacts ............................................. 14

2.6. Step 5: Management of Cumulative Impacts – Design and Implementation ....................... 15

2.7. Institutional Arrangement ..................................................................................................... 17

Strategic Environmental Assessment (SEA) Framework ............................................................... 21

Section 1 ............................................................................................................................................... 21

1.1. Introduction .......................................................................................................................... 21

1.2. Definitions ............................................................................................................................ 21

1.3. Objectives ............................................................................................................................. 22

1.4. Importance Of Strategic Environmental Assessment ........................................................... 23

Section 2 ............................................................................................................................................... 25

2.1. Legal Framework .................................................................................................................. 25

2.2. Integrating SEA in Policy Plan and Program ....................................................................... 25

2.3. Institutional Aspects of Strategic Environmental Assessment (SEA) .................................. 26

Section 3 ............................................................................................................................................... 26

3.1. SAE approach ....................................................................................................................... 26

3.2. Processes of SEA .................................................................................................................. 26

3.3. Models for linking SEA & the decision process................................................................... 28

Section 4 ............................................................................................................................................... 31

4.1. Stage 1: Establishing the context for the sea ........................................................................ 32

4.2. Stage 2: Implementing the SEA ........................................................................................... 32

4.3. Stage 3: informing and influencing decision making ........................................................... 34

4.4. Stage 4: Monitoring And Evaluation .................................................................................... 34

Annexure 1 ........................................................................................................................................... 34

Annexure 2 ........................................................................................................................................... 35

Annexure 3 ........................................................................................................................................... 36

Systems for Environmental Permits .................................................................................................. 38

1.1. Introduction .......................................................................................................................... 38

1.2. Objectives of Environmental Permitting .............................................................................. 39

1.3. Types of Permitting .............................................................................................................. 40

1.4. Institutional Aspects of Permitting ....................................................................................... 41

1.5. Permit Requirements ............................................................................................................ 42

1.6. Procedural Aspects of Permitting ......................................................................................... 44

1.7. Application for a Permit ....................................................................................................... 47

Technology Transfer ........................................................................................................................... 51

Section 1 ............................................................................................................................................... 51

1.1. Introduction .......................................................................................................................... 51

1.2. Current Status ....................................................................................................................... 51

1.3. Way forward ......................................................................................................................... 52

Section 2 ............................................................................................................................................... 58

2.1. Introduction ......................................................................................................................... 58

2.2. Procedure for choosing BAT ................................................................................................ 58

2.3. Data collection for determining BAT ................................................................................... 60

2.4. BAT Ref Documents & BAT Conclusions........................................................................... 61

2.5. Implementation of BAT ........................................................................................................ 62

2.6. Best Available Techniques for Punjab’s major industries .................................................... 67

Market Based Instruments ................................................................................................................. 86

Section 1 ............................................................................................................................................... 86

1.1. Overview .............................................................................................................................. 86

1.2. Background ........................................................................................................................... 86

1.3. Nature of Externality ............................................................................................................ 91

1.4. Current Measures .................................................................................................................. 92

1.5. Success & Failures ................................................................................................................ 94

1.6. Types of Emission Control Mechanism ........................... Error! Bookmark not defined.95

1.7. Command and control policies ............................................................................................. 95

Section 2 ............................................................................................................................................... 91

2.1. Types Of Market Based Instruments .................................................................................... 91

2.2. Pollution Charge ................................................................................................................... 93

2.3. Trading Permit ...................................................................................................................... 95

2.4. Deposit-Refund System ........................................................................................................ 97

2.5. Product Charge ..................................................................................................................... 98

2.6. Subsidies ............................................................................................................................... 98

Section 3 ............................................................................................................................................. 101

3.1. Overview ............................................................................................................................ 101

3.2. Types of Emission Trading Programs ................................................................................ 101

3.3. Potential Impact of an Emissions Trading Scheme ............................................................ 102

3.4. Vision/ Objective of Emission Trading .............................................................................. 102

Section 4 ............................................................................................................................................. 111

4.1. Design And Implementation ............................................................................................... 111

4.2. Challenges .......................................................................................................................... 112

4.3. Continuous Monitoring to Support ETS ............................................................................. 113

4.4. International Experience with Emissions Trading .............................................................. 114

4.5. Conclusion .......................................................................................................................... 116

4.6. Recommendations .............................................................................................................. 117

Enhanced System for Quality Environmental Assessment Reports and Technical Reviews ..... 118

1.1. Stepwise Suggestions for Enhancing Punjab EIA Process ................................................. 118

Annexure 1 ......................................................................................................................................... 127

Annexure 2 ......................................................................................................................................... 142

Acronyms

AEL Achievable Emission Limit

BAT/BACT

Best Available Techniques/ Best Available Technologies/Best Available Control

Technology

BAT ref EU’s BAT Reference Documents

CP Cleaner Production

ELV Emission Limit Value

EMS Environmental Management Systems

EU European Union

EUREACH EU’s Registration, Evaluation, Authorization and Restriction of Chemicals

GSP Generalised System of Preferences

ISO International Organisation for Standardisation

OECD Organisation for Economic Co-operation & Development

OHS Occupational Health & Safety

PETI Punjab Environmental Technology Institute

CEIA Cumulative Environmental Impact Assessment

EIA Environmental Impact Assessment

EPA Environment Protection Authority

MDBs Multilateral Development Bank

NGOs Non-Governmental Organization

TOR Terms of Reference

VECs Valued Ecosystem Components

CAC Command and Control

ETS Emission Trading Scheme

SIC Standard Industrial Classification

SO2 Sulphur Dioxide

PEQS Punjab Environmental Quality Standards

PPP Polluter Pays Principle

NOx Nitrogen Oxide

MBIs Market-Based Instruments

Executive Summary Environmental Assessments and Approvals (EA) is a decision-making support instrument that aims at

identifying, predicting, evaluating and mitigating the biophysical, social and other relevant

environmental effects of development proposals prior to major decisions being taken and

commitments being made. EA is not only a simple environmental protection tool, but an instrument

for strengthening environmental management processes. This report narrates some new concepts that

are related both directly and indirectly with the environmental assessment and approval system.

The first concept presented in this report is the framework for Cumulative Environmental Impact

Assessment that provides appropriate assessment and management of cumulative impacts and risks

related to business activities. Cumulative impacts are those that result from the successive,

incremental, and/or combined effects of an action, project, or activity when added to other existing,

planned, and/or reasonably anticipated future ones. Considering the effects of multiple impacts on the

environment lies within the domain of Cumulative Environmental Impact Assessment (CEIA), an

approach to environmental impact assessment (EIA). CEIAs are conducted across the actual and

potential impacts of a number of activities or projects that may combine over time and/or space with

appropriate limitations by reference to the action being assessed and its predictive impacts.

Strategic is an attribute that qualifies ways of thinking, attitudes, actions related to strategies. Another

important aspect of environmental assessment that is considered at the Strategic level is Strategic

Environmental Assessments (SEAs). Strategic Environmental Assessment (SEA) originated after

environmental impact assessment (EIA), with inputs from biophysical planning and policy analysis.

The overall purpose of SEA was to ensure that environmental issues would be adequately considered

at early stages of development policy-making and planning (broadly considered).1 The purpose of

SEA is therefore to help understand the development context of the strategy being assessed, to

appropriately identify problems and potentials, address key trends, and to assess environmental and

sustainable viable options that will achieve strategic objectives.

In many parts of the world, one of the successful way to protect and conserve the environment by

proper enforcement of environmental quality standards both at the approval and operational stage is

but adopting the systems of Environmental Permits. Environmental permitting is a key tool to

gradually reduce the environmental burden of industries to the environment. This is done step by

step as new purification and process technologies come available. Environmental permits need to be

renewed periodically. The period of renewal, for example every 3-5 years, is indicated in the

issued permit.

Environmental permits are usually linked with Best Available Techniques (BAT) and cleaner

technologies that aims at a high level of protection for the environment as a whole by stipulating the

operating permits of industries with conditions based on “Best Available Techniques” (BAT). Clean

interventions through cleaner technologies have gotten more attention in Pakistan because of their

intrinsic ability to help meet legislative and environmental standards. It also provides platform for an

exchange of information on BAT. In Punjab it is proposed to have their own BAT committees having

representation of all of the major industries where everyone can exchange information and experience

in technologies applicable to each type of industry. BAT conclusions are part of the BAT reference

document laying down the conclusions on the best available techniques, their description, information

1 Dalal-Clayton B. and Sadler B. 2005. Strategic Environmental Assessment, a sourcebook and reference guide to

international experience. London: Earthscan.

to assess their applicability, the emission levels associated with the best available techniques,

associated monitoring, associated consumption levels and, where appropriate, relevant site

remediation measures.

Whether regulators should impose strict standards or provide incentives for Industries has always

been the centre of debate which has ensued between economists, legislators, administrators, and

businessmen. It is the purpose of this report to help lay out the basic instrument alternatives available

to the regulators, for instance EPA. Hence in order to control pollution, various measures can be

adopted. Recently, the widespread use of MBIs, which are aspects of policy that encourage behaviour

through market signals, rather than through explicit directives regarding pollution control levels or

methods2,have become very popular even amongst Developing countries .One of the prominent MBIs

includes Tradable emission permit schemes which are gaining publicity day by day, due to the

theoretical promise of cost-effectiveness and because they have been used successfully implemented

in a number of countries especially in the United States to reduce sulphur dioxide (SO2) and nitrogen

oxides (NOx) (Coria et all, 2008)3 . Briefly, in this scheme, industries that will under pollute will have

the permit to sell their pollution share to industries that are over polluting and exceeding their quotas.

A systematic approach is required in order to operationalize the use of Trading Permits more

effectively within this fragile institutional context and requires a number of steps on behalf of EPA as

part of its implementation procedure.

To improve the EIA review and approval process of Punjab EPA, and the resulting quality of the

Environmental Assessment Reports, the Punjab EPA IEE/EIA process were assessed together with

selected EIA cases in Punjab (reflected in the Gap Analysis report). To further enhance and

systematize the review process, recommendations were made at each step for improvements into the

current EIA review process of Punjab EPA with the aim to ensure ease of business and at the same

time meeting environmental protection requirements. Main steps involved in the Environmental

Assessment processes are improved and enhanced with the support of ICT based web interface of EIA

module that will help in removing the bottle necks in the current system and key suggestions are made

for enhancing and increasing the efficiency of the IEE/EIA review process of Punjab.

2 Stavins.(2001, November).Experience with Market Based Environmental Policy Instruments

3 Tradable Permits in Developing Countries Evidence from Air Pollution in Santiago, Chile

https://outlook.live.com/owa/?path=/mail/inbox/rp#_ftn1

Chapter 1

Cumulative Environmental Impact

Assessment (CEIA) Framework

Section 1

Introduction

Chapter 1 Cumulative Environmental Assessment (CEIA)

Framework

Environmental Assessment Report Page No

1

Chapter 1

Cumulative Environmental Impact

Assessment (CEIA) Framework

Section 1

1.1. INTRODUCTION

Appropriate assessment and management of cumulative impacts and risks related to business

activities has always been one of the leading risk management challenges faced by the project

developers in emerging markets. Factors such as unpredictability of climate patterns, climate change,

escalating and competing water use demands, decline of species biodiversity, degradation of

ecosystem services, and changing socio-economic circumstances all add complexity to risk

assessment and management.

Considering the effects of multiple impacts on the environment lies within the domain of Cumulative

Environmental Impact Assessment (CEIA), an approach to environmental impact assessment (EIA).

CEIAs are conducted across the actual and potential impacts of a number of activities or projects that

may combine over time and/or space with appropriate limitations by reference to the action being

assessed and its predictive impacts.

Cumulative impacts are those that result from the successive, incremental, and/or combined effects of

an action, project, or activity (collectively referred to in this document as “developments”) when

added to other existing, planned, and/or reasonably anticipated future ones. For practical reasons, the

identification and management of cumulative impacts are limited to those effects generally recognized

as important on the basis of scientific concerns and/or concerns of affected communities.4

Below are some common examples of scenarios where the cumulative impacts from development

activity may warrant further analysis:

1. Air emissions need to be assessed for their potential to change ambient air quality in

surrounding airshed and consequent impacts on human health

2. Noise impacts on nearby sensitive receptors need to be assessed with reference to existing

ambient noise conditions

3. Water discharges from a number of operations have the potential to combine with existing

pollutant loads to increase downstream pollutant concentrations and potentially impact a

water resource or ecosystem

4. Groundwater extraction combines with extraction from surrounding bores to reduce

groundwater input into a sensitive groundwater dependent ecosystem

5. Clearing of native vegetation to establish mining infrastructure happens in a region that has

just been intensely cleared, with consequent concerns that further fragmentation of the

remnant vegetation will reduce connectivity below ecological limits

6. Removal of habitat of a threatened species is required in an area where the existing

threatening processes remain substantially unmitigated and where additional future

4 Affected communities are defined as local communities directly affected by the project (Performance Standard

1, paragraph 1).


Framework


2

developments have been foreshadowed, with consequent concerns that the combination of

these pressures will result in a decline in numbers to below those required to sustain a viable

population

1.2. DEFINITION

“Cumulative Environmental Impact Assessment (CEIA) is the process of (a)

analyzing the potential impacts and risks of proposed developments in the context of

the potential effects of other human activities and natural environmental and social

external drivers on the chosen VECs over time, and (b) proposing concrete measures

to avoid, reduce, or mitigate such cumulative impacts and risk to the extent possible”

The key analytical task is to discern how the potential impacts of a proposed development might

combine, cumulatively, with the potential impacts of the other human activities and other natural

stressors such as droughts or extreme climatic events. Valued Ecosystem Components (VECs) are

immersed in a natural ever-changing environment that affects their condition and resilience. VECs are

integrators of the stressors that affect them. For example, periodic extremes of precipitation (droughts

or floods), temperature (extreme cold or heat), or fluctuations in predators all affect the condition of

biological VECs. Today and into the future, global warming (climate change) can be expected to have

substantial impacts on the condition of VECs. Specifically, CEIAs are typically expected to:

Assess effects over a larger (i.e., “regional”) area that may cross jurisdictional boundaries;

Assess effects during a longer period of time into the past and future;

Consider effects on valued ecosystem components (vecs)5 due to interactions with other

actions, and not just the effects of the single action under review;

Include other past, existing and future (e.g., reasonably foreseeable) actions; and

Evaluate significance in consideration of other than just local, direct effects.

1.3. CLASSIFICATIONS OF CEIA

There are various definitions of CEIA that appear in guidelines, assessment and approval

requirements and legal findings. In most instances, and in line with the one size does not fit all

concept, the most appropriate definition will be determined by the specific circumstance of the project

and study to be undertaken in light of the relevant framework requirements applicable. Outlined

below are four major ‘types’ of CEIA approaches currently in use.

i. Cumulative impact of combined elements of a single project/activity

In this type, the approach is to consider the combined effects of all elements of a single project on

multiple environmental values. Cumulative impacts must arise (either directly, indirectly or as a

consequence) from the action referred, i.e. without consideration of other actions.

ii. Contributing impacts of a single project/activity on an existing baseline or current health of

the system

This definition accounts for the combined effects of a proposed project and previous actions, i.e.

provides a historical context. This enables an ongoing and adjusted baseline and condition trend of the

5 Valued Ecosystem Component (VEC): Any part of the environment that is considered important by the proponent,

public, scientists and government involved in the assessment process. Importance may be determined on the basis of cultural

values or scientific concern.

(Hegmann, G., C. Cocklin, R. Creasey, S. Dupuis, A. Kennedy, L. Kingsley, W. Ross, H. Spaling and D. Stalker. 1999.

Cumulative Effects Assessment Practitioners Guide. Prepared by AXYS Environmental Consulting Ltd. and the CEA

Working Group for the Canadian Environmental Assessment Agency, Hull, Quebec.)


Framework


3

impacted entity to be evaluated over time. An example of this might be a project that will result in the

loss of 10 ha of particular vegetation type, of which 10,000 ha has already been cleared within the

region.

iii. Cumulative impact of multiple projects/ activities on a single environmental value or asset

This assesses the impact of several, or all, relevant projects on a single environmental element. To

date this approach has predominantly been used in regions, catchments or defined locations to

measure and manage elements such as dust, air quality, noise or water. Its use on elements of

biodiversity (flora and fauna) is less common.

iv. Cumulative impact of multiple projects/ activities on multiple/all environmental values/assets

(with each value/asset assessed separately or by system)

Broadest definition of cumulative impact and aligns with commonly seen definition of “successive,

incremental and combined impacts of past, present and (reasonably) foreseeable actions”.6 Numerous

technical issues and potential limits in setting scale (spatial, temporal) and scope (what other projects

to consider). This approach is relatively straightforward in primarily greenfield scenarios or a defined

precinct where proposed projects are known. It can be extremely difficult on a broad regional or

global scale, particularly if data are unavailable. Regional and State planning schemes and

assessments are often better placed to manage the effects of multiple actions across a broad scale.

It is important to mention here that not all CEIAs are the same and no particular approach is better or

worse than any other; rather the different approaches will better fit a particular scenario based on

scale, context and timing. Aligning the assessment methodology with the capacity to deliver answers

appropriate to the circumstances is a key element of ensuring that the approach taken is ‘fit for

purpose’

1.4. NEED FOR CONDUCTING CEIA

Cumulative environmental impact assessment and management is appropriate whenever there is

concern that a project or activity under review may contribute to cumulative impacts on one or more

VECs.

This concern may be pre-existing or a consequence of the potential cumulative impacts of the

development and other projects or actions, human activities, or exogenous factors (e.g., natural

drivers). CEIA is also appropriate whenever a given development is expected to have significant or

irreversible impacts on the future condition of one or more VECs that also are, or will be, affected by

other developments. The other developments may already exist, be reasonably predictable, or be a

mix of existing and reasonably anticipated developments. In circumstances where a series of

developments of the same type is occurring, or being planned, the need for CEIA can be fairly

obvious.7 For example:

When a series of mining developments occur within an area where they will impact the same

vecs (perhaps common water bodies or watercourses, wildlife populations, community health,

community loss of access to assets, or multiple land takings);

6 Environmental Protection Authority 2012 Annual Report, EPA, Perth, Western Australia. 7 Cumulative impacts can occur (a) when there is “spatial crowding” as a result of overlapping impacts from various actions

on the same VEC in a limited area, (e.g., increased noise levels in a community from industrial developments, existing roads,

and a new highway; or landscape fragmentation caused by the installation of several transmission lines in the same area) or

(b) when there is “temporal crowding” as impacts on a VEC from different actions occur in a shorter period of time than the

VEC needs to recover (e.g., impaired health of a fish’s downstream migration when subjected to several cascading

hydropower plants).


Framework


4

When a series of hydroelectric developments occur within the same river or within the same

watershed with cumulative impacts in common on flora and fauna, on downstream water

availability or quality, on watershed sediment dynamics, on navigation, on local

communities’ livelihoods, or on adjacent land uses because of increased access from

associated roads; or

When a series of oil drilling activities occur within an area where they will impact the same

vecs (perhaps common water bodies or watercourses, wildlife populations, community health,

community loss of access to assets, or multiple land takings);

When a series of agricultural developments occur that will cumulatively impact land use

patterns, having cumulative impacts on downstream water availability (from withdrawal of

water for irrigation), on downstream water quality, or on local community livelihoods;

A better practice of CEIA is not limited to assessing the impacts of developments of the same type.

For example, CEIA might be needed for the development of a mine in association with increased

access from road construction that will bring further induced development (perhaps in association

with developments in adjacent forest management, hydroelectric power developments, agriculture or

other activities, all of which may affect local communities, wildlife, or water availability and quality).

In some cases, CEIA may be needed to assess and manage the impacts of several new projects,

activities, or actions that are being developed or planned. In other situations, CEIA of a single new

development may be appropriate when it occurs in an area where concerns exist about cumulative

impacts—concerns that are either well documented or identified through consultation with affected

communities and other stakeholders. It is also important to note that while reviewing the projects, one

should be clear if everything needs to be assessed, for what time period should cumulative impacts be

evaluated, if any other action should be considered etc. In some situations, different components of

the same development8 are assessed in separate EIAs, and the cumulative impacts from these

components should be subject to CEIA. The key point in determining the need for CEIA is that one or

more VECs will be cumulatively impacted by different developments, whatever they may be.

Cumulative impacts may also be identified and acknowledged in the EIA process, and the measures

proposed for managing the incremental contribution of a given project can be covered by the project’s

environmental management plan (EMP). For instance, methods for assessing the incremental

contribution to airshed degradation from the emissions of a new thermoelectric generation plant are

well established in the scientific community and are typically an integral component of a good EIA

process. Similarly, the determination of greenhouse gas emissions and their management within the

climate change context are well-recognized global practices. Neither of these cases would require a

separate CEIA process; the inclusion of standard pollution prevention and control measures as an

integral component of EMP would typically suffice.

The Figure below illustrates which projects should be included or excluded for CEIA.

8 Including associated facilities and other related infrastructure such as roads, ports, railroads, bridges, or

terminals


Framework


5

No Yes

No

Yes

Exclude

Include

Fig. 1.1: Broad process for determining projects for inclusion in cumulative environmental impact

assessment

CEIA initiation

What projects to include?

Certain and reasonably

foreseeable and spatially and

temporarily relevant?

For each projects: are potential

impacts likely to be material? Exclude from CEIA

May be included in later

assessments if status changes

Confirm scope and projects for

inclusion with regulator

Gather data: Obtain information

from regulator, third party and

publicly available

Conduct CEIA

Further projects need to

conduct their own CEIA

(updating and confirming

previous assessments)

If there is insufficient data on

project impacts, exclude

project or if necessary include

with justifiable assumptions

on impacts


Framework


6

1.5. CEIA REQUIREMENT IN EPA REVIEW

The following is terms of reference examples which can be used as an example as to how to

operationalise the CEIA in the existing EIA process , through EPA observing the TOR in the EIA

study of a particular project or projects

1. The EIA should identify and address cumulative influences, where there are estimated project

affects coupled with existing impacts of other activities (which includes both current and

future developments by the proponent and other parties in the region and area). The EIA must

also address the potential cumulative impact of the proposed action on ecosystem resilience.

Where relevant to the potential impact, a risk assessment must be conducted and documented.

2. Forecast the demand for potable and raw water for the operational period (in ML per annum)

and discuss this in relation to the resource capacity and current use with particular reference to

the cumulative impacts on water resources.

3. Discuss potential direct/indirect (including downstream) and cumulative impacts to fauna as a

result of the proposal, and provide quantitative data on impacts of the proposal to species of

conservation significance.

4. Conduct an assessment of the likely impacts of the development on the environment,

focussing on the specific issues identified below, including: an assessment of the likely

impacts of all stages of the development, including any cumulative impacts.

5. Where relevant, this section must contain an assessment of the potential cumulative impacts

of the proposal, based on existing and other formally proposed developments in the region,

which have not been addressed in previous sections. Interactions between biophysical, socio-

economic and cultural impacts of the proposal should be discussed.

6. Cumulative impacts on the environmental values of land, air and water and cumulative

impacts on public health and the health of terrestrial and water ecosystems must be discussed

in the relevant sections. This assessment may include air and water sheds affected by the

Project and other proposals competing for use of the local air and water sheds.

1.6. CHALLENGES IN CEIA

Cumulative Environmental Impact Assessment is a complex process that entails many challenges, as

does the implementation of an effective strategy to manage cumulative impacts and risk for multiple

projects, actions, and activities. Some of these key challenges are;

Information on proposed developments may be limited by commercial considerations.

Identifying and describing “predictable future development” and “external natural and social

stressors” in sufficient detail to assess their social and environmental impacts and effects can

be fraught with difficulty.

Stakeholders may assign different priorities to VECs.

VEC baseline conditions and acceptable thresholds are often unavailable because of lack of

data or agreed scientific methodologies.

Attribution of impacts is a process dominated by uncertainties, and getting individual project

sponsors to accept responsibilities and impact management is not always a straightforward

task.

Exercising leverage over government and over other developers can be an overwhelming task

for private developers, which often may produce negligible results.

Engaging stakeholders in discussing strategic cumulative impacts, when the discussion is

promoted by a specific developer sponsor, tends to be confusing and could be

counterproductive.

Project sponsors may not share data collaboratively or define mitigation strategies jointly.


Framework


7

CEIA requires interactions with numerous organizations and individuals from government, third

parties, affected communities, and other stakeholders. Numerous groups have an interest in CEIA

because of its wider geographic scope and focus on impacts from multiple developments. The type of

interactions that project proponents should have with interested parties will vary, depending on the

development and its location. Deciding why, when, and how to interact with government(s), third

parties, and affected communities is not straightforward; it requires considerable thought and

expertise.9 To determine the appropriate type and scope of interactions requires an understanding of

constraints on both governance and participants’ capacity.

1.6.1. Reasonable and shared expectations

At the outset of a CEIA it is vital that all stakeholders (proponents, regulators and active interested

third parties) have the same expectations of the likely outcomes, processes and limitations of the

assessment. Establishing these expectations can be achieved by utilising various tools including:

Developing clear, comprehensive written terms of reference specific to the assessment to

be undertaken – remembering that one size does not fit all

Supporting the terms of reference with a published rationale for the methodology, scope

and data specifications to be used

Conducting workshops and in-person briefings with key stakeholders to obtain input and

reach a mutual level of understanding

Clearly identifying the limitations and boundaries of the assessment at commencement

and in the production of results/conclusions.

9 For guidance, please refer to these IFC documents on good practice and guidance on stakeholder engagement,

participatory monitoring, and grievance mechanisms:

www.ifc.org/HB-StakeholderEngagement

www.ifc.org/GPN-Grievance

http://www1.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/publi

cations/publications_gpn_socialdimensions__wci__1319578072859

www.ifc.org/HB-WaterFootprint

http://www1.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/publi

cations/publications_handbook_doingbetterbusiness__wci__1319576642349

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Section 2

Preparatory Framework of CEIA


Framework

Environmental Assessment Report Page No 8

Section 2

2.1. PREPARATORY FRAMEWORK OF CEIA

CEIAs build on what has been learned and applied in EIA practice for many years. However,

assessment practitioners need to know in what ways assessing cumulative effects are different. This

Chapter of the Guide identifies and discusses unique tasks in CEIAs for each of the five steps in a

basic EIA framework (from CEAA 1994): Scoping, Analysis, Mitigation, Significance and Follow-

up. This framework itemizes the typical steps followed by practitioners in completing EIAs. The

information box below identifies each of the CEIA tasks for these steps.

Table 1.1: CEIA assessment framework

Basic EIA Task to complete for CEIA

1. Scoping Identify regional issues of concern

Select appropriate regional VECs

Identify spatial and temporal boundaries

Identify other actions that may affect the same VECs

Identify potential impacts due to actions and possible effects

2. Analysis of Effects Complete the collection of regional baseline data

Assess effects of proposed action on selected VECs

Assess effects of all selected actions on selected VECs

3. Identification of Mitigation Recommend mitigation measures

4. Evaluation of Significance Evaluate the significance of residual effects

Compare results against thresholds or land use objectives

and trends

5. Follow up Recommend regional monitoring and effect management

Keep in mind that the process for CEIA must be flexible; the steps may not proceed in sequence and

may need to be implemented iteratively, with some steps revisited in response to the results of others.

For example, in the issue identification (scoping) step, consideration of potential effects is often

repeated, with the findings and analysis refined each time, until a final list of issues is produced. The

steps for preparation of CEIA are described as under;

2.2. STEP 1: SCOPING – VECS, SPATIAL & TEMPORAL BOUNDARIES AND

ENVIRONMENTAL DRIVERS

Objectives:

Identify and agree on VECs in consultation with stakeholders.

Identify other past, existing, or planned activities within the analytical boundaries.

Assess the potential presence of natural and social external influences and stressors (e.g.,

droughts, other extreme climatic events).

Determine the time frame for the analysis.

Establish the geographic scope of the analysis.

Chapter 1 Cumulative Environmental Assessment (CEIA) Framework


Key Considerations

Whose involvement is key?

Which VEC resources, ecosystems, or human values are affected?

Are there concerns from existing cumulative impacts?

Are there any other existing or planned activities affecting the same VEC?

Are there any natural forces and/or phenomena affecting the same VEC?

This step is critical to successful CEIA because it establishes the scope of the analysis of cumulative

impacts and a successful CEIA is contingent upon careful scoping. The key issues to be considered

include but not limited to setting boundaries, problem identification, agreement on environmental

values/assets, It identify the totality of stresses that determine the condition of VECs selected for

CEIA. It is important to identify the sources of stress—past developments whose impacts persist,

existing developments, and foreseeable future developments, as well as any other relevant external

social and/or environmental drivers (e.g., wildfires, droughts, floods, predator interactions, human

migration, and new settlements). In addition to other human activities, natural drivers that exert an

influence on VEC condition should be identified and characterized.

Guidance for identifying reasonably predictable projects recommends reference to local, regional, or

national development plans and generally recommends that a short time horizon be considered owing

to uncertainty about longer term developments. Where development plans are not available, guidance

recommends that emphasis be given to identifying other projects in the planning stage or formal

approval process (e.g., through preparation of EIA documents or permit submissions). The CEIA

should clearly justify the reasoning behind the temporal boundary used for the assessment, as well as

all the different developments and external stressors included in the analysis.

The output of scoping includes identification of the VECs for which cumulative impacts will be

assessed and managed, and the spatial and temporal boundaries for the assessment. This scope is

likely to extend beyond a project’s direct area of influence (DAI) as typically defined in EIAs.

Information to consider in establishing the scope of CEIA includes the following:

VECs known or suspected to be affected by the development (based on prior sectoral

assessments or the project’s EIA). (Appendix-1 contains an illustrative list of potential

VECs)

Known cumulative impact issues within the region.

Concerns for cumulative impacts identified in consultation with stakeholders, including

potentially affected communities (these may exist at distance from the planned development).

Regional assessments prepared by governments, multilateral development banks, and other

stakeholders.

CEIAs prepared by sponsors of other developments in the region.

Information from NGOs.

Boundaries are expanded to the point at which the VEC is no longer affected significantly or the

effects are no longer of scientific concern or of interest to the affected communities. For example, in

the case of biodiversity values, habitat ranges or migration pathways are often used as boundary-

defining variables. By contrast, if landscape fragmentation is at stake in a transportation project, the

likely extension of secondary and tertiary roads, along with population growth, are well-established

risk factors to consider. Priority should be given to those VECs that are likely to be at the greatest risk

from the development’s contribution to cumulative impacts. Scenario analysis may be an appropriate



approach for examining the potential cumulative impacts that could be associated with such

development.

In cases where no data are available from third parties about existing or planned developments, the

developer may promote the benefits of CEIA to third parties and encourage them to provide

information on existing developments and future plans; obtain whatever data government authorities

have regarding existing and planned developments; and, in the absence of specific information about

projects and their impacts, use generic information about the other projects, their inputs, and their

effects for typical developments of similar size.

Identification of the key participants should be completed early in this step and updated as needed as

the overall process proceeds. Best practice involves an open, participatory, transparent, and

meaningful consultation with affected communities and other relevant interested parties as early in the

scoping phase as possible. Critical to the success of scoping is that it appropriately characterizes the

context for the analysis.10

2.3. STEP 2: ESTABLISH BASELINE ON STATUS OF VECS

Objectives:

Define the existing condition of VEC.

Understand its potential reaction to stress, its resilience, and its recovery time.

Assess trends.

Key Considerations

What is the existing condition of the VEC?

What are the indicators used to assess such condition?

What additional data are needed?

Who may already have this information?

Baseline data provides a benchmark against which potential impacts can be estimated. One of the

greatest challenges in conducting CEIAs is gathering and accessing useful baseline information on

third party projects and their impacts.

Conducting all the necessary baseline studies and monitoring to inform a CEIA especially working

with lengthy data sets can be expensive and time consuming. In almost all cases CEIAs heavily rely

on access to existing data often held by third parties (for example, government agencies, universities

and other consultants). Baseline data can provide detailed explanation on the cumulative impact of

existing activities in the region and may be used to inform impact prediction and identify priority

areas for management and mitigation.

CEIA models that take an adaptive management approach may be a means of enabling impacts to be

managed in the absence of up-front comprehensive information that is not necessarily required.

However, the availability of relevant data is critical for the success of a CEIA, and the methodology to

be used to determine VEC baseline conditions should be defined as early as possible. Data

requirements should be determined early on during the scoping phases of the CEIA process. A

developer may use existing information when such information provides a sufficient basis for a

complete assessment of cumulative impacts. However, if the existing information contains significant

10

Baxter, W., W. A. Ross, and H. Spaling. 2001. “Improving the practice of cumulative effects assessment in

Canada.” Impact Assessment and Project Appraisal 19(4): 253–62.



gaps that prevent the performance of an adequate assessment of cumulative impacts, it should obtain

the information needed using internationally recognized methodologies.

Typically, the new baseline data to be collected for a CEIA will not be as detailed as that generated

during an EIA, because of the larger area covered and/or changes in the type of data required for the

different scale of the assessment. Data that are needed focus on the most important VECs. Collection

of new baseline data tends to be limited and targeted to indicators that would allow determination of

any changes in VEC conditions. Practitioners must have a clear understanding of the final use of the

data, to be able to technically defend the analysis. It is not good practice to embark on costly

collection of new baseline data without careful consideration of the expected cumulative impact to be

assessed for specific and well-defined VECs. For instance, during an EIA, intensive and detailed field

surveys of soil, vegetation, and fauna may be required in order to assess direct impacts of a given

development on biodiversity and land use. In contrast, because CEIA may require expanding the

geographical boundary to thousands of hectares, the analysis may rely on satellite imagery or existing

vegetation or fauna studies on broader scales.

In some cases, the collection of data for some VECs, such as water quality, air quality, and noise

levels, provides a baseline condition that integrates the collective effects of all existing developments

and exogenous pressures. Baseline (historical) information on the condition of VECs establishes the

“big picture” context for thinking about changes in VEC condition, can help developers avoid the

pitfalls associated with shifting baselines,11

and can be used in a variety of ways.

The determination of the trend of change in the baseline condition of a given VEC over time may

indicate the level of concern for cumulative impacts. If there is a history of a long or steep decline in

VEC condition, it may be inferred that there is an increased likelihood that a threshold is being

approached. Threshold levels (tipping points), at which a VEC’s response to additional impacts may

change abruptly, are often not known with any degree of certainty. A simple analysis of the overall

change in condition relative to a baseline can at least provide some indication of the change that has

already occurred; however, this analysis must be approached with caution if the baseline condition is

recent and thus possibly representative of an already shifted baseline.

If sufficient information is available to establish the natural range of variation in a given VEC

condition, it can be used for comparison with the estimated future state and assessing significance.

When compared with information about the past time trend in development pressure, it may also

provide some insight into VEC sensitivity to stresses. Good indicators of condition are important.

Historical trend analysis should be approached with some caution because some indicators can be

very stable, essentially hiding impact responses. Consistent use of indicators is important.12

Estimating the past condition of a VEC is often a challenging task, requiring the collection of

historical information about the VEC which can be difficult to obtain. Various sources of information

can be explored—reports from governments, NGOs, and MDBs; prior EIAs; knowledge from resident

communities; or scientific literature.13

11

Pauly, Daniel. 1995. “Anecdotes and the shifting baseline syndrome in fisheries.” Trends in Ecology and

Evolution 10 (10): 430–430. 12

Bérubé, Michel. 2007. “Cumulative effects assessment at Hydro-Québec: what have we learned?” Impact

Assessment and Project Appraisal 25(2): 101–109. 13

Ibid at 9



Table 1.2: Example of typical environmental values include in CEIAs

Environmental

Component

Regional issue of

concern

Environmental value/

sensitive receptor Example of indicators

Air Effects of particulate,

SOx and NOx emissions

on human health

Residential areas,

schools and hospitals

near emissions stack

Exceedance of Air

quality standards

Surface water Over-extraction resulting

in altered flow regimes

Other water users within

the consumptive pool

Exceedance of

sustainable yield/

reduced water security

for other licensees

Ground water Over-extraction resulting

in lowering of aquifer

water level

Groundwater dependent

ecosystems

Spring flows to

groundwater dependent

ecosystem

Vegetation Loss of threatened

species from land

clearing, reduced

population viability

Threatened species and

associated habitat

Regional population of

the threatened species

Fauna Bird mortality from

consumption of

contaminated water at

retention pond

Granivorous birds in the

region (high dietary

water needs)

Regional populations of

the identified species

Resource use Alienation of land,

restriction of access

Local Aboriginal

community, recreational

fishers, harvested

species

Stakeholder concerns/

complaints

2.4. STEP 3: ASSESS CUMULATIVE IMPACTS ON VECS

Objectives:

Identify potential environmental and social impacts and risks.

Assess expected impacts as the potential change in condition of the VEC (i.e., viability,

sustainability).

Identify any potential additive, countervailing, masking, and/or synergistic effects

Key Considerations

What are the key potential impacts and risks that could affect the long-term sustainability and/

or viability of the VEC?

Are there known or predictable cause-effect relationships?

Can these impacts and risks interact with each other?



Analysis of cumulative impacts on VECs involves estimating the future state of the VECs that may

result from the impacts they experience from various past, present, and predictable future

developments. The objective is to estimate the state of VECs as it results from the aggregated stresses

that affect them. In this context, in addition to the stresses imposed by developments, the assessment

should encompass the potential range of environmental variation that may influence VEC condition

and not be based solely on expected average conditions (e.g., change in climate patterns and/or

predictability).

In CEIA, impacts are measured not in terms of the intensity of the stress added by a given

development but in terms of the VEC response and, ultimately, any significant changes to its

condition. It is also important to determine what constitutes a significant impact. Broadly, in

determining what might be considered a significant impact, the following should be considered:

The current state or status of the environmental value

The ecology, nature and use of the value (e.g. is it mobile or sedentary, is it a resource for

other users)

Existing threats to the value

Resilience and ability to recover

The local and regional context (e.g. is the value in decline regionally, is it represented in

protected areas etc.)

The levels of acceptable change

The likelihood and magnitude of impacts, including certainty, timing, scale, size and duration

The methods used for analysis are specific to the characteristics of the VEC (e.g., different methods

are appropriate for analysis of impacts on physical, environmental, biotic, and social VECs, and their

resilience). A wide spectrum of methods has been used for CEIA; these methods generally can be

characterized as impact models, numerical models, spatial analysis using geographical information

systems (GIS), and indicator-based approaches.14

As discussed previously, CEIA analysis is futures oriented. The impact of the project is not assessed

as the difference between the expected future condition of VECs and that of a past baseline condition.

It is assessed as the difference between the estimated future condition of VECs in the context of the

stresses imposed by all other sources (projects and natural environmental drivers) and the estimated

VEC condition in the context of the future baseline plus the development under evaluation.15

Of

concern is not just estimation of the development’s impact, but estimation of the future condition of

VECs in the context of all stresses—which is the cumulative impact—and can be evaluated in

reference to an established threshold level of acceptable condition, if known, or in reference to a past

baseline.

The estimate of the cumulative project impact, together with EIA results, indicates the need for

project-specific mitigation. By contrast, the estimated overall cumulative impact indicates the need for

mitigation to be implemented by the various project owners or proponent parties to ensure that their

respective contributions to the overall condition of the VECs is coherent and/or compatible with what

is mandated or required by government-led—or government-agreed—regional cumulative impact

management initiatives, or as a minimum compliant with ambient quality standards for the desired

use.

14

See Box 18 and Table 4.1 of “Sample Guidelines: Cumulative Environmental Impact Assessment for

Hydropower Projects in Turkey.” World Bank, 2012. https://www.esmap.org/node/2964. 15

Ibid at 10



2.5. STEP 4: ASSESS SIGNIFICANCE OF PREDICTED CUMULATIVE IMPACTS

Objectives:

Define appropriate “thresholds” and indicators.

Determine impact and risk magnitude and significance in the context of past, present, and

future actions.

Identify trade-offs.

Key Considerations

Do these impacts affect the sustainability and/or viability of the resource and/or VEC?

What are the consequences and/or trade-offs of taking the action versus no action?

The analysis of cumulative impacts should focus on assessing impacts on selected environmental

values. Several approaches are available to assist in determining cumulative effects. These do not

necessarily differ markedly from individual project EIA, except for the consideration of impacts from

more than one project. There is no one single approach to always be used, nor necessarily one type of

approach for specific effects or types of actions. The appropriate method is the one that best provides

an assessment of the impacts on the environmental values being examined.

Significance determination is a normal component of EIA and CEIA and occurs near the end of the

assessment process. Significance is typically evaluated after project mitigation measures are factored

in. Any potential cumulative impact that warrants additional mitigation and/or monitoring beyond that

identified in the EIA should be considered significant. A key good practice for the appropriate

determination of impact significance and overall agreement among affected communities and other

relevant stakeholders is to strengthen mitigation measures and monitoring programs, focusing on

expected probable cumulative impacts.

The significance of a cumulative impact is evaluated not in terms of the amount of change, but in

terms of the potential resulting impact to the vulnerability and/or risk to the sustainability of the VECs

assessed. This means evaluating cumulative impacts in the context of ecological thresholds.

Determining ecological thresholds for biological and social VECs has proven to be difficult. In many

cases, such thresholds may not be clearly identified until they are actually crossed, at which point

recovery may take a long time with considerable cost or may simply not be possible. Consequently, a

precautionary approach that explicitly considers uncertainty in ecological and sociological

relationships is essential when thresholds of acceptable VEC condition are being established.16

Moreover, the degree of significance of the impact will be more subjective (and case specific) and can

depend on many of the following:

How close the existing situation is to the threshold

Whether exceedances of thresholds are short-term, one-off or continuing

Resilience of the value or the system, including ability to recover

Effectiveness of mitigation

Size of study area

Incremental contribution of effects from action under review

Relative contribution of effects of other actions

Relative rarity of species

Significance of local effects

16

Databases of ecological thresholds can be found at http://www.resalliance.org.

http://www.resalliance.org/



Magnitude of change relative to natural background variability

Defining thresholds is an essential component not only for the assessment of significance of

cumulative impacts but also for the design of management strategies. To be able to determine the

significance of cumulative impacts, some limits of acceptable change in VEC condition are needed to

which incremental effects can be compared. In practice, if the cumulative impacts of all combined

developments on a VEC do not exceed a limit or threshold, the development would be considered

acceptable. Thresholds are limits beyond which changes resulting from cumulative impacts become of

concern; they are typically expressed in terms of carrying capacity, goals, targets, and/or limits of

acceptable change. These thresholds reflect and integrate scientific data, societal values, and concerns

from affected communities. A threshold can be the maximum concentration of a certain nutrient in a

body of water beyond which an algal bloom will occur, the concentration of pollutant in an airshed

beyond which health of nearby communities could be adversely affected, or a maximum amount of

linear infrastructure in a landscape before visual impacts become unacceptable.

An alternative is to identify the limits of acceptable change, in consultation with the scientific

community and the affected community. This approach focuses on the identification of VEC

conditions that are deemed acceptable to stakeholders. The advantage of this approach is that once

acceptable VEC conditions have been agreed upon, the appropriate combination of levels of use and

management strategies required to sustain those conditions can be determined. Similarly, when

carrying-capacity levels or specific thresholds cannot be determined, trend analysis can be very

helpful to determine whether a desired VEC condition or limit of acceptable change for a VEC is

likely to be achieved or whether unacceptable VEC conversion and/or degradation is likely to occur.

Finally, in the absence of defined thresholds or in the face of an inability to determine limits of

acceptable change, practitioners should first acknowledge this lack or inability as part of the CEIA

process, and use their best efforts to suggest appropriate thresholds or limits, based on available

scientific evidence and in consultation with stakeholders, government agencies, and technical experts.

2.6. STEP 5: MANAGEMENT OF CUMULATIVE IMPACTS – DESIGN AND

IMPLEMENTATION

Objectives:

Use the mitigation hierarchy.

Design management strategies to address significant cumulative impacts on selected VECs.

Engage other parties needed for effective collaboration or coordination.

Propose mitigation and monitoring programs.

Manage uncertainties with informed adaptive management.

Key Considerations

How can cumulative impacts be avoided, minimized, and/or mitigated?

How can the effectiveness of proposed management measures be assessed?

What are the triggers for specific adaptive management decisions?

The management measures needed to prevent cumulative impacts will depend on both the context in

which the development impacts occur (i.e., the impacts from other projects and natural drivers that

affect the VECs) and the characteristics of the development’s impacts. Since cumulative impacts

typically result from the actions of multiple stakeholders, the responsibility for their management is

collective, requiring individual actions to eliminate or minimize individual development’s



contributions. At times, cumulative impacts could transcend a regional threshold and therefore

collaboration in regional strategies may be necessary to prevent or effectively manage such impacts.

Where cumulative impacts already exist, management actions by other projects may be needed to

prevent unacceptable cumulative impacts.

Management of cumulative impacts therefore, does not rest solely with developments that come later

in the development sequence. Ignoring possible cumulative impacts during project development

carries the risk of having unanticipated constraints imposed at a later time. As a result, managing

cumulative effects in a CEIA requires, as a start, the same type of mitigation and monitoring that

would be recommended in an EIA. Mitigating a local effect as much as possible is the best way to

reduce cumulative effects. Mitigating and managing an individual project’s impacts as far as possible,

even when the project itself does not result in significant impacts, is an appropriate way to reduce

cumulative impacts across a region.

The analysis phase of the project CEIA may indicate the need and/or potential for additional

mitigation measures beyond those identified in the project EIA. The design of such additional

mitigation measures for the development, if needed, is an early part of the work in this step of

managing cumulative impacts. Iteration of the analysis (Step 3), significance evaluation (Step 4), and

management (mitigation) design (this step) may be needed.

If specific project mitigation that will prevent unacceptable cumulative impacts can be identified and

implemented, then the developer may not need to initiate collaborative engagement of others in

impact management. When prevention of unacceptable cumulative impacts by project mitigation

alone is not possible, collaborative engagement in regional management strategies will be necessary.

It may help to reduce the risk of additional unanticipated management commitments at a later time, as

regional development proceeds. Specific actions that may be needed to effectively manage cumulative

impacts include the following:

Project design changes to avoid cumulative impacts (location, timing, technology).

Project mitigation to minimize cumulative impacts, including adaptive management

approaches to project mitigation.

Mitigation of project impacts by other projects (not under control of the proponent to further

minimize impacts on VECs).17

Collaborative protection and enhancement of regional areas to preserve biodiversity.18

19

Collaborative engagement in other regional cumulative impact management strategies.

Participation in regional monitoring programs to assess the realized cumulative impacts and

efficacy of management efforts.

The first two points are clearly the responsibility of the project, the third point is the responsibility

of other project proponents to address their contribution to cumulative impacts (some of which

may be discovered during the project CEIA process), and the last three points involve

17

Hydro-Québec found this to be particularly important in CEIA practice (Bérubé, Michel. 2007. “Cumulative

effects assessment at Hydro-Québec: what have we learned?” Impact Assessment and Project Appraisal 25(2):

101–109.) 18

McKenney, Bruce A., and Joseph M. Kiesecker. 2010. “Policy Development for Biodiversity Offsets: A

Review of Policy Frameworks.” Environmental Management 45: 165–76. 19

Kiesecker, Joseph M., Holly Copeland, Amy Pocewicz, and Bruce McKenney. 2009a. “Development by

Design: Blending landscape planning with the mitigation hierarchy.” Frontiers in Ecology and the Environment

8: 261–66.



collaborative engagement with other stakeholders, including project proponents, government

agencies, affected communities, conservation groups, and expert groups.

To summarize briefly, the figure below shows the general stages of CEIA.

Figure 1.2: General stages of CEIA

2.7. INSTITUTIONAL ARRANGEMENT

As per the proposed institutional arrangement based on the result of this restructuring exercise, the

cumulative environmental impact assessment (CEIA) will be the function of Environmental

Protection Agency (EPA). One of the prime function of EPA is environmental assessments and

approvals, so apart from initial environmental examinations (IEEs) and environmental impact

Scoping

•Definition of temporal and spatial extent of the project

• Identification of information requirements

•Establishment of Project governance

Data and Information

gathering

•Commissioning of technical studies

•Development of common baseline information

Analysis and review

•Analysis of cumulative impacts in relation to key environmental factors

•Use of both quantitative and qualitative methods

•Expert and peer review

•Preparation of assessment documentation

Consultation

•Consultation with the Public,key stakeholders and regulators

Finalization

•Development of further information if required to address comments from consultation phase

•Finalization of assessment documentation

Implementation

•Development of strategies and management plans

• Implementation of agreed outcomes



assessments (EIAs), CEIA which is actually the more advanced and complex version of EIA will also

be the responsibility of EPA.

2.7.1. Roles and Responsibilities of Stakeholders

A wide range of roles and responsibilities are possible. The principles and purpose for involving

different parties in CEIA should not change, no matter what the circumstances of government, third

parties, or affected communities are. The principles are meaningful engagement of affected

communities, involvement and collaboration with governments, and interaction with third parties. At

a minimum, interactions with government, third parties, and affected communities should accomplish

the purposes that relate to a client’s project-specific CEIA. For a description of roles and

responsibilities of key stakeholders, please refer to Table 2.3 in that section.

Establishing and maintaining a constructive relationship with government and other stakeholders over

the life of a project is an integral part of CEIA. Table 2.3 provides specific details about the place for

and objectives of interactions. However, limitations in capacity can inhibit governments and other

stakeholders from participating as needed in a proponent’s CEIA process. Where government capacity

is low, interactions should occur at a minimum in those areas identified in Table 2.3; but where

capacities are greater it is useful to increase the number and/or scope of such interactions.

2.7.2. Legal Requirements

CEIA is not always specifically mentioned in EIA statutes. Where not expressly referenced it may

still be a relevant consideration for EPA, on the basis of the definitions and objectives of the

legislative regimes, which reference concepts such as ecologically sustainable development. Hence,

conducting CEIA should be reflected in the PEPA 1997(amended 2012).In addition, an expectation

for assessment of cumulative impacts is often created through guidance documents prepared by EPA,

some of which have legal effect.



Table 1.3: Roles and Responsibilities of stakeholders in CEIA

Roles and Responsibilities Purpose

Environmental Protection Department

Establish policy and legal framework for resource management and

cumulative impact management.

Establish and lead regional planning structures and collaborative

mechanisms for managing and mitigating (e.g., aggregated offset

strategies) resource developments and cumulative impacts.

Implement permitting process that considers cumulative impacts of

all developments and pressures, and conforms to values and limits,

given regional plans and national frameworks.

Design and conduct CEIA study of geographic area which includes

the baseline (historical) conditions and predicts the future baseline,

based on the carrying capacity of the VECs

Issues approvals to individual private sector projects to be developed

on the basis of this information.

Lead development and implementation of regional cumulative

impact monitoring program that analyzes development pressures and

impacts at regional scale and compares results to values and/or

acceptable limits for resource development.

Defines values and acceptable limits for resource development.

Defines locations for acceptable types and limits of developments.

Identifies contribution of each development to cumulative impacts in

region, gives public and proponent assurance that proposed developments

are within acceptable limits set by legal framework and regional plans and

processes.

Gives information on state of VECs in region and assurance that

cumulative impact values and development objectives are being met;

provides database for project-level CEIA, and makes sure this information

is freely and publicly available.

Private Sector Project Proponent

Design and conduct CEIA study of the incremental impacts of the

project building on the CEIA study conducted by the government.

Monitor and manage cumulative impacts and risks related to the

development for its life span.

Provide project-level cumulative impact monitoring data to regional

Gives financial institutions and decision makers information about

cumulative impact for evaluating the project.

Conforms to CEIA commitments and/or permit conditions; manages

development to prevent it from causing VECs to reach limits.

Gives the government project-related cumulative impact data it needs to

manage the uncertainty of impact predictions and prevent VECs from

reaching limits.

cumulative impact monitoring program.

Support regional planning structures and collaborative mechanisms

for managing cumulative impacts to prevent their limits from being

reached; actively participate as needed in collaborative systems with

government, private sector, and public.

Enables effective monitoring and management of cumulative impacts at

appropriate scale; supports collaborative multistakeholder solutions for

CEIA.

Third Parties (existing and future developments and/or resource

users)

Similar to proponent, but covering existing or future developments

Assess and manage cumulative impacts of existing developments.

Assess and manage cumulative impacts of any future developments;

prepare EIA and CEIA for permit decision makers if needed.

Collect and provide data for regional cumulative impact monitoring

program.

Participate in regional planning structures and collaborative.

mechanisms for managing CEIA at regional or larger scales.

Provides project proponents and other developers, decision makers, and

regional monitoring program with details about impacts of existing

developments.

Provides proponent and other developers, government, and other

stakeholders with details about proposed developments (i.e., project

description, impact analysis, EIA/CEIA).

Provides project-level data needed for regional cumulative impact

monitoring program.

Enables effective regional management of cumulative impacts; supports

collaborative, multistakeholder process.

Affected Communities and Public

Public participates in value setting for policy and/or legal

frameworks and regional resource management plans.

Affected communities participate in CEIA of individual projects.

Public participates in collaborative management of cumulative

impacts.

Ensures regional resource development limits and conditions reflect public

values.

Allows values of affected people to be reflected in scoping and valuation

of project-level CIAs.

Fosters public ownership of cumulative impact management objectives and

results.

Strategic Environmental Assessment

(SEA) Framework

Section 1

Introduction

Chapter 2 Strategic Environmental Assessment (CEIA)

Framework


Chapter 2


(SEA) Framework

Section 1

1.1. INTRODUCTION

Strategic is an attribute that qualifies ways of thinking, attitudes, actions related to strategies. Many

definitions and understandings of strategy exist, but they all relate to long-term objectives. This

guidance follows a strategic thinking model which is understood as having a vision over long-term

objectives (the distant points we want to reach), flexibility to work with complex systems

(understanding systems, the links and lock-ins, and accepting uncertainty), adapting to changing

contexts and circumstances (changing pathways as needed) and be strongly focused on what matters

in a wider context (time, space and points of view)20

In line with the above, an understanding of SEA has been argued over the last decade which takes

SEA as an environmental assessment instrument with a strategic nature, conceived as a flexible

framework of key elements, acting strategically in a decision process to enable a facilitating role,

ensuring an added-value to decision-making. SEA also provides a practical and direct means of

progressing MDG 7 on Environmental Sustainability (agreed at the UN General Assembly in 2000).

Secondly, SEA also helps further the Johannesburg Plan of Implementation agreed at the World

Summit on Sustainable Development in 2002, which stressed the importance of “strategic frameworks

and balanced decision making for advancing the sustainable development agenda”21

Basically, Strategic Environmental Assessment (SEA) originated after environmental impact

assessment (EIA), with inputs from biophysical planning and policy analysis. The overall purpose of

SEA was to ensure that environmental issues would be adequately considered at early stages of

development policy-making and planning (broadly considered).22

1.2. DEFINITIONS

The term “SEA” reportedly was first used in a draft report to the Commission of the European

Communities23

. Since then, various definitions of SEA have been proposed, however, among them

most widely quoted definitions are:

“a strategic framework instrument that helps to create a development context

towards sustainability, by integrating environment and sustainability issues in

20 Maria do Rosário Partidário, (2012), Strategic Environmental Assessment Better Practice Guide Methodological guidance

for strategic thinking in SEA. Publisher: Portuguese Environment Agency and Redes Energéticas Nacionais (REN), SA

Design and Layout. 21 DAC guidelines and reference series applying strategic environmental assessment good practice guidance for development

co-operation, OECD publishing, 2006 22 Dalal-Clayton B. and Sadler B. 2005. Strategic Environmental Assessment, a sourcebook and reference guide to

international experience. London: Earthscan. 23 Wood, C. M., and Djeddour, M., 1989. The environmental assessment of policies, plans and programmes. Volume 1 of

interim report to the European Commission on Environmental Assessment of Policies, Plans and Programmes and

Preparation of a Vade Mecum. Manchester: EIA Centre, University of Manchester.

Chapter 2 Strategic Environmental Assessment (SEA)

Framework


decision-making, assessing strategic development options and issuing guidelines

to assist implementation”24

“SEA is a process directed at providing the authority responsible for policy

development (the ‘proponent’) (during policy formulation) and the decision

maker (at the point of policy approval) with a holistic understanding of the

environment and social implications of the policy proposal, expanding the focus

beyond the issues that were the original driving force for new policy25

”

“The formalised, systematic and comprehensive process of evaluating the

environmental effects of a policy, plan or programme and its alternatives,

including the preparation of a written report on the findings of that evaluation,

and using the findings in publicly accountable decision-making.26,27

”

The purpose of SEA is therefore to help understand the development context of the strategy being

assessed, to appropriately identify problems and potentials, address key trends, and to assess

environmental and sustainable viable options (i.e. that act cautiously or prevent risks and stimulate

opportunities) that will achieve strategic objectives.

1.3. OBJECTIVES

SEA, in a strategic thinking approach, has three very concrete objectives:

1. Encourage environmental and sustainability integration (including biophysical, social,

institutional and economic aspects), setting enabling conditions to nest future development

proposals;

2. Add-value to decision-making, discussing opportunities and risks of development options and

turning problems into opportunities;

3. Change minds and create a strategic culture in decision-making, promoting institutional

cooperation and dialogues, avoiding conflicts.

Through these objectives, SEA can contribute to:

Ensure a strategic, systemic and broad perspective in relation to environmental issues within a

sustainability framework;

Contribute to identify, select and discuss major development options towards more

sustainable decisions (intertwining biophysical, social, institutional and economic issues);

Detect strategic opportunities and risks in the options under analysis and facilitate the

consideration of cumulative processes;

Suggest follow-up programmes, through strategic management and monitoring;

Ensure participative and transparent processes that engage all relevant stakeholders through

dialogues, and foster more integrated decisions in relation to the array of relevant points of

view.

24

Maria do Rosário Partidário, (2012), Strategic Environmental Assessment Better Practice Guide Methodological guidance

for strategic thinking in SEA. Publisher: Portuguese Environment Agency and Redes Energéticas Nacionais (REN), SA

Design and Layout. 25

Brown, A. L. and Therivel, R., (2002), Principles to Guide the Development of Strategic Environmental

Assessment Methodology, Impact Assessment and Project Appraisal, 18 (3): 183-190. 26

Therivel R., Wilson E., Thompson S., Heaney D. and Pritchard D. (1992), Strategic Environmental

Assessment, Earthscan, London. 27

Therivel R. and Partidario, M. R. (eds) (1996), The practice of Strategic Environmental Assessment,

Earthscan, London.


Framework


International experience and the literature on SEA have agreed to IAIA (International Association for

Impact Assessment) 2002 SEA performance criteria, deemed to be axiomatic of SEA good practices.

These performance criteria are;

Integrated

Sustainability-led

Focused

Accountable

Participative

Iterative

1.4. IMPORTANCE OF STRATEGIC ENVIRONMENTAL ASSESSMENT

There are several reasons why SEA is important;282930

1. Promotes and helps to understand sustainability challenges, incorporating an integrated

perspective earlier in policy-making and planning processes;

2. Supports strategic decision-making, setting enabling development conditions;

3. Facilitates identification and discussion of development options and provides guidelines to

help development to follow sustainability trajectories;

4. Informs planners, decision makers and affected public on the sustainability of strategic

decisions, ensuring a democratic decision making process, enhancing the credibility of

decisions;

5. Encourages political willingness, stimulates changes to mentalities and create a culture of

strategic decision-making.

In its understanding as a strategic thinking model, SEA applies to the strategic component of decision-

making processes in (i) public policies, (ii) sectorial development plans and programmes, (iii)

territorial development plans and programmes (iv) and also to major structural investment projects

that have long-term strategic objectives (such as new international airports, new forms of energy

production (ethanol, wind-based, water-based) in relation to their strategic concept). However more

than the assessment of development proposals, SEA is an important instrument to help face

development challenges generated by:

a) Adaptation and mitigation to climate changes;

b) Poverty eradication and overcome of social and regional inequalities;

c) Enhancement and maintenance of biodiversity values, ecosystem services and human well-

being;

d) Social and territorial cohesion;

e) Promotion of regional development potential;

f) Innovation and cultural diversity of the population;

g) Promotion of environmental quality, landscape and cultural heritage and sustainable use of

natural resources.

28

Partidário M.R. 1999. Strategic Environmental Assessment - principles and potential. In Petts J. (Ed)

Handbook of Environmental Impact Assessment, London: Blackwell. 29

CSIR (Council for Scientific and Industrial Research) 2000. Strategic Environmental Assessment in South

Africa– guideline document, Department of Environmental Affairs and Tourism, Pretoria. http://www.csir.co.za. 30

IAIA (International Association for Impact Assessment) 2002. Performance Criteria for Strategic

Environmental Assessment www.iaia.org.

EXAMPLE OF NOT USING SEAS IN PAKISTAN – CASE STUDY

Thermal Power Generation Policy, Pakistan:

ISSUE

In the mid-1990s, in response to rapidly expanding industrial activity and an increasing population,

Pakistan’s Government decided to stimulate increased power generation. The Independent Power

Plants Policy provided incentives for investments in thermal power generation. No SEA was made;

instead investors had to submit an EIA without considering potential cumulative effects. Investors were

given the freedom to choose the site, the technology and the fuel and many of these plants were

installed with little or no pollution control devices. Leading energy experts and the Water and Power


Framework


Section 2

Legal Requirements for Strategic

Environmental Assessment (SEA)


Framework


Policy

Plan

Programme

Projects

Strategic

Environmental

Assessment (SEA)

Environmental

Impact

Assessment (EIA)

Section 2

2.1. LEGAL FRAMEWORK

The SEA Framework will be issued as Directive by EPA. This will be applied to a wide range of

public plans and programmes (e.g. on land use, transport, energy, waste, agriculture, etc). It is

mandatory that Plans and programmes in the sense of the SEA Directive must be prepared or adopted

by an authority (at Provincial, Departmental, regional or local level) and be required by legislative,

regulatory or administrative provisions.

An SEA is mandatory for plans/programmes which are prepared for:

Agriculture

Forestry

Fisheries,

Energy,

Industry,

Transport,

Waste/ water management,

Telecommunications,

Tourism,

Town planning or land use and which set the framework for future development consent of

projects lower and above Rs. 2 billion.

2.2. INTEGRATING SEA IN POLICY PLAN AND PROGRAM

There is a hierarchy of levels in decision making comprising projects, programmes, plans and policies

(see Fig. 2.1). Logically, policies shape the subsequent plans, programmes and projects that put those

policies into practice. Policies are at the top of the decision-making hierarchy. As one moves down

the hierarchy from policies to projects, the nature of decision-making changes, as does the nature of

environmental assessment needed. Policy-level assessment tends to deal with more flexible proposals

and a wider range of scenarios. Project-level assessment usually has well defined and prescribed

specifications.

Fig. 2.1: SEA: Up-streaming environmental considerations


Framework

Environmental Assessment Report Page No 25 (a)

2.3. INSTITUTIONAL ASPECTS OF STRATEGIC ENVIRONMENTAL

ASSESSMENT (SEA)

As per the proposed institutional arrangement based on the result of this restructuring exercise, the

strategic environmental assessment (SEA) will be the function of Environmental Protection Agency

(EPA). One of the prime function of EPA is environmental assessments and approvals, so apart from

initial environmental examinations (IEEs) and environmental impact assessments (EIAs), SEA which

is actually the more advanced and complex version of EIA with a broader scope will also be the

responsibility of EPA.

Fig. 2.2: Proposed Institutional Arrangement of SEA

Section 3


(SEA) Approach, Processes and Models


Framework


Section 3

3.1. SEA APPROACH

SEA can be described as a family of approaches which use a variety of tools, rather than a single,

fixed and prescriptive approach. A good SEA is adapted and tailor-made to the context in which it is

applied. This can be thought as a continuum of increasing integration: at one end of the continuum,

the principle aim is to integrate environment, alongside economic and social concerns, into strategic

decision making; at the other end, the emphasis is on the full integration of the environmental, social

and economic factors into a holistic sustainability assessment.

3.2. PROCESSES OF SEA

Two main types of SEA process has been identified, these includes:31

EIA based SEA Approach

Non-EIA based SEA Approach

3.2.1. EIA-based SEA Approach

EIA-based SEA approach is a structured and rigorous process of predefined steps for plans and

programmes, prepared by public planning authorities and at time private bodies32

. EIA-based SEA

approach share three main common characteristics:

They are related to the preparation of an approvable document, whether a plan or a

programme.

Their main aim is to provide information on the environmental effects, or consequences of

proposed plans, programmes (or policies).

Their standard methodological approach follow the typical EIA process steps of screening,

scoping, assessment, mitigation, decision and monitoring.33

3.2.2. Non-EIA based SEA/ Policy Appraisal Approach

Non-EIA based SEA approach is a more flexible assessment process for policies, prepared by public

planning authorities and at times private bodies34

. It is not about (reactively) assessing the

environmental impacts of proposed plans, policies and programmes (PPP) but it is about:

Evaluating alternative visions and development intentions incorporated in policy, planning or

programme initiatives, ensuring full integration of relevant biophysical, economic, social and

political considerations. A decision-centred approach that gives more attention to the

institutional context and attempts to integrate the environmental considerations into all stages

of the decision-making.

Facilitating strategic transformation by influencing selected “strategic decisions”.35

31

Cherp A. Watt A. and Vinichenko V. 2007. SEA and strategy formation theories – from three Ps to five

Ps.Environmental Impact Assessment Review 27: 624–644. 32

Thomas B. Fischer. 2007. Theory and practice of Strategic Environmental Assessment: towards a more

systematic approach. EPublished by Earthscan, London. 33

Partidário M. Augusto B. Vicente G and Lobos V. 2009. Learning the Practice of Strategic-Based SEA.

Accra. 29th Annual Conference of the International Association for Impact Assessment. 34

Thomas B. Fischer. 2007. Theory and practice of Strategic Environmental Assessment: towards a more

systematic approach. EPublished by Earthscan, London.


Framework


Table 2.1: A comparison of EIA-based and Non-EIA based/ policy appraisal approaches to SEA

EIA-based Approach Non-EIA based/ Policy Appraisal Approach

Screen to trigger SEA and identify likely

scope of review needed

List the objectives of the proposal and

summarize the policy issue, identifying

constraints and trade-offs

Scope to identify key issues and alternatives,

clarify objectives and to develop terms of

reference for SEA

Specify the range of options for achieving the

objectives, including the do nothing option

Compare alternatives including n action

options to clarify implications and trade-offs

Identify and list all impacts on the environment

and consider mitigation measures to off set them

Involve the public early – e.g., at the scoping

stage – and with sufficient information

Assess the significance of the impacts in relation

to other costs and benefits

Analyse impacts, evaluate alternatives, and

identify mitigation and follow up measures

Value costs and benefits, including those based

on monetary values, ranking or physical

quantities

Document the findings including

recommended terms and conditions for

implementation

State the preferred option with reasons for doing

so

Review the quality of the SEA report to check

the information is sufficient & relevant for

decision making

Monitor and evaluate the results, making

appropriate arrangements for doing so as early

as possible

Carry out follow up measures as necessary to

monitor effects, check on implementation etc.

Source: UNECE (1992) Source: UK Department of Environment (1991),

UK DETR (1988)

35

Clark R. 2000. Making EIA Count in Decision-Making. In Partidário M.R. and Clark R. Perspectives on

SEA.Boca Raton, Lewis: 15-27.


Framework


3.3. MODELS FOR LINKING SEA & THE DECISION PROCESS

Several aspects need to be considered when deciding on how to link SEA and the planning process.

Having a separate but well-articulated coordination may be better than a totally separate or totally

integrated coordination, because the interconnectedness of the SEA and planning processes is crucial

for their overall success. Totally separated coordination would make such connection more difficult.

The same happens to reporting and teams.

It is very important that SEA and policy-making/planning processes share several activities, such as

fact-finding, information, stakeholder’s engagement and public participation. Different models on

how SEA and the policy-making/planning processes may link were identified some years ago36

and

serve as an illustration of possible linkages.

The first two models (i.e. 1st Model: Single opportunity model and 2

nd Model: Parallel model) relate

more closely to the EIA-based SEA approaches, the parallel model (2) being the most frequently

used. Models 3rd

and 4th relate to more integrated and strategic approaches in SEA. While the

integrated model (3) may eventually represent the best SEA model in the long-term, the decision-

centred model (4) seems to be the most flexible and adaptable. An illustration of four models is

shown below in Fig. 3.1:

36 Partidário M.R. 2004. Designing SEA to fit decision-making. 24th Annual Conference of the International Association for

Impact Assessment. Vancouver.

Fig. 2.3: Models for linking SEA and the decision process (Patidário, 2007)


Framework


3.3.1. 1st

Model: Single Opportunity Model

In the 1st model (single opportunity model), SEA only has limited ability to influence (more like an

environmental review/ audit) the consideration of alternatives, and so meaningful changes in spatial

strategy may be difficult.

3.3.2. 2nd

Model: Parallel Model

The second model (parallel model) has been considered as the most frequently used model, in which

SEA is undertaken in parallel to the planning process. SEA specialists works separately but in close

coordination with the planning team that requires effective communication. It is very important that

activities and assessment details will be shared by both team for effective SEA. This option does not

necessarily prolong the elaboration of the plan, but it does requite effective communication between

the planning team and the SEA team. For example, the leader of the SEA may participate as an

observer on planning team sessions, and vice versa.

3.3.3. 3rd

Model: Integrated Model

In the third option, SEA is fully integrated into the formulation of the planning process. SEA experts

are considered to be an integral part of the planning team. They draft key questions, and jointly carry

out various assessments with planners. It indicates how this linkage would work. This option requires


Framework


effective internal communication with the planning team, and SEA experts need a clear mandate and

role. The advantage is that environmental issues are considered alongside economic and engineering

considerations, meaning that final land use plans are fully “integrated”.

3.3.4. 4th

Model: Decision-centred Model

The new concept of SEA i.e. decision-centred approach is not about assessing the environmental

impacts of proposed plans, rather it gives more attention to the institutional context and attempts to

integrate the environmental considerations into all stages of the decision-making process. Moreover, it

also facilitates the strategic transformation by influencing selected “strategic decisions37

”

37

Nilsson, M. and Dalkmann, H. (2001). Decision Making and Strategic Environmental Assessment.

Journal of Environmental Assessment Policy and Management, 3, 305-327.


Framework


Section 4

Stages of Strategic Environmental

Assessment (SEA)


Framework


Section 4

SEA guidelines and procedures have been developed with the aimed at strengthening plan and

programme development and are based on an adaptation of the steps characteristic for EIA. Practical

experience with these approaches suggests that good practice SEA should involve four stages as

shown in Fig. 4.1. Each stage can be further subdivided into steps/tasks.

1. Establishing the context for the SEA

• Screening

• Setting objectives

• Identifying Stakeholders

2. Implementing the SEA • Scoping • Collecting baseline data • Identifying Alternatives • Identifying how to enhance opportunities and mitigation

impacts • Quality assurance • Reporting

3. Informing and influencing Decision-making • Making recommendations (in dialogue with stakeholders)

4. Monitoring and Evaluation • Monitoring decisions taken on the PPP • Monitoring implementation of the PPP • Evaluation of both SEA and PPP

Fig. 2.4: Basic Stages in SEA


Framework


4.1. STAGE 1: ESTABLISHING THE CONTEXT FOR THE SEA

4.1.1. Screening

An early step in the SEA process is “screening” to decide whether an SEA is appropriate and

relevant. In this process, preparatory tasks are initiated and examined the need of SEA. Integral to this

will be establishing the objectives of the SEA: how does it intend to improve the planning process;

what is its role of concerned organization?38

4.1.2. Stakeholder Consultation

SEA is a participatory process. It allows civil society, including the private sector and relevant

stakeholders that will be affected by the proposed Policy, Plan or Program (PPP), to contribute inputs

to strategic decision making. Therefore, screening should include careful stakeholder analysis to

identify stakeholders and prepare a communication plan to be used throughout the SEA. It is

important to identify and engage those stakeholders who are the most exposed to environmental

degradation and ensured the involvement of both men and women.

4.2. STAGE 2: IMPLEMENTING THE SEA

4.2.1. Scoping

A scoping process should establish the content of the SEA, the relevant criteria for assessment (e.g.

goals set out in the Provincial Sustainability Development Strategy or relevant plan or policy). These

should be set out in a scoping report. A pragmatic view needs to be taken on how much can be

achieved given the time-scale, available resources, and existing knowledge about key issues.

An open and systematic process should be followed. The SEA should actively engage key

stakeholders to identify significant issues associated with the proposal and the main alternatives.

Based on these issues, and the objectives of the SEA, decision criteria and suitable indicators’ of

desired outcomes should be identified. Scoping may also recommend alternatives to be considered,

suitable methods for analyses of key issues and sources of relevant data. Scoping procedures and

methods, such as matrices, overlays, and case comparisons, can be used to establish cause-effect links

between different specific plans or programmes or to identify the environmental implications of more

general policies or strategies.

4.2.2. Collect Baseline Information

SEA needs to be based on a thorough understanding of the potentially affected environment and social

systems. This must involve more than a mere inventory, e.g. listing flora, fauna, landscape and urban

environments. Particular attention should be paid to important ecological systems and services, their

38

Implementation of SEA Directive (2001/42/EC), Guidelines for Regional Authorities and Planning

Authorities, November 2004.


Framework


resilience and vulnerability, and significance for human well-being. Existing environmental protection

measures and/or objectives set out in international, national or regional legislative instruments should

also be reviewed.

The baseline data should reflect the objectives and indicators identified in the “scoping report”. For

spatial plans, the baseline can usefully include the stock of natural assets including sensitive areas,

critical habitats, and valued ecosystem components. For sector plans, the baseline will depend on the

main type of environmental impacts anticipated, and appropriate indicators can be selected (e.g.

emissions-based air quality indicators for energy and transport strategies). In all cases, the

counterfactual (or no-change scenario) should be specified in terms of the chosen indicators.

4.2.3. Consideration of Alternatives

In conducting SEA, Responsible Authorities must appraise the likely significant environmental effects

of implementing the plan or programme and any reasonable alternatives. It is normal practice when

developing a plan or programme to propose different ways of fulfilling its objectives. In the UK the

term “options” is often used. Each alternative can be tested against the SEA objectives, with positive

as well as negative effects being considered, and uncertainties about the nature and significance of

effects noted. This will often be an iterative process, with the alternatives being revised as part of the

SEA to enhance positive effects and reduce negative ones.

4.2.4. Potential Impacts

Identifying the potential direct and indirect or unintended effects of policy proposals and decision-

making processes, as well as options for, and alternatives to PPPs is naturally more difficult than in

the case of specific projects.

The range of options or variables under consideration is often harder to define with certainty because

the transmission channels through which effects may be experienced may be very complex, involving

many aspects which are difficult to predict and analyse. This makes the indirect effects of paramount

importance in the assessment. Certain measures can help to frame this issue, for example, the use of

best versus worse case scenarios. Cumulative effects present particular challenges and may require

expert consideration. There is no single best method for impact analysis. Approaches should be

selected that are appropriate to the issues at stake. The identification and evaluation of suitable

options may be assisted by future “scenario building” and “back-casting methodologies”.

4.2.5. Identify Opportunities and Mitigation

It is important to focus on realising the positive opportunities of the planned activities and minimising

any negative risks. Opportunities will generally enhance achievement of the MDGs and other

development challenges. The aim is to develop “win-win” situations where multiple, mutually

reinforcing gains can strengthen the economic base, provide equitable conditions for all, and protect

and enhance the environment. Where this is impossible, the trade-offs must be clearly documented to

guide decision makers.

A mitigation hierarchy should be followed for identified negative impacts: first avoid; second

reduce; and third offset adverse impacts – using appropriate measures. Caution should be exercised if

the analysis indicates a potential for major, irreversible, negative impacts on the environment. Often

this may suggest selecting less risky alternatives. For less-threatening situations, standard mitigation

measures can be used to minimize an adverse impact to “as low as reasonably practicable” (ALARP

level).


Framework


4.2.6. Draft Report on the Findings of SEA

Once the technical analysis is completed, the results and rationale for conclusions need to be reported.

While a technical report may be necessary, it must be presented in an understandable format and

appropriate language(s). This will often require short summaries and graphic presentations rather than

a long report. A succinct, non-technical summary should be included. This will be of particular use in

explaining the findings to civil society, which needs to be well informed in order to submit comments.

4.2.7. Prepare Final SEA Report

Typically, this would include sections/chapters on:

The key impacts for each alternative.

Stakeholder concerns including areas of agreement and disagreement, and recommendations

for keeping stakeholders informed about implementation of recommendations.

The enhancement and mitigation measures proposed.

The rationale for suggesting any preferred option and accepting any significant trade-offs.

The proposed plan for implementation (including monitoring).

The benefits that are anticipated and any outstanding issues that need to be resolved.

Guidance to focus and streamline any required subsequent SEA or EIA process for subsidiary,

more specific undertakings such as local plans, more specific programmes and particular

projects.

4.3. STAGE 3: INFORMING AND INFLUENCING DECISION MAKING

Presentation of the draft and final reports are important to influence key decisions. A clear,

understandable and concise Briefing Note or Issues Paper can help to ensure that decision makers are

fully aware of key environmental issues linked to the PPP. From the outset, through steering

committees, other structures and public engagement mechanisms, decision makers and stakeholders

have opportunities to shape the outcome of the SEA, e.g. identification of issues, choice of indicators,

scope of work, and selection and evaluation of proposed development options and alternatives.

4.4. STAGE 4: MONITORING AND EVALUATION

The significant environmental effects of the implementation of plans and programmes must be

monitored to identify any unforeseen adverse effects and to enable appropriate remedial action to be

taken. Decisions on what to monitor and how to do it need to be considered early in the SEA process

and throughout the course of preparing the plan or programme.


Framework


ANNEXURES

Annexure 1

INDICATIVE LIST OF PLANS AND PROGRAMMES SUBJECT TO

THE SEA DIRECTIVE

This is an indicative list of types of plan and programme in the Punjab which are subject to the SEA

Directive in some or all cases. It is not possible to give a definitive list because of the number of plans

and programmes in existence and the varying extent to which the Directive’s criteria apply, either to

types of plan or programme or to individual plans or programmes within a type. The list will be kept

up to date on the EPD website and used for reporting to Environmental Council on the

implementation of the Directive, as required under PEPA Act 2018.

LAND USE AND SPATIAL PLANNING

The Directive applies to plans and programmes in the following categories:

Structure Plans

Local Plans

Development Plans

The Spatial Development Strategy

Area Plans

National Park Plans

Minerals Plans

Waste Plans

LFS Plans

Area Waste Plans

Local Air Quality Action Plans

Local Housing Strategies

Local Transport Plans

Municipal Waste Management Strategies

Regional Development Strategy

Regional Economic Strategies

Regional Transportation Strategy

Other provincial, regional and local government plans and programmes

Environmental Protection and Management

Areas of Natural Beauty Management Plans/Protected Areas

National Park Management Plans


Framework


Ravi River Basin Management Plans and Programmes of Measures

Annexure 2

STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA) REPORT

FORMAT

Possible structures and contents of the Environmental Reports

Structure of Report Information to include

Non-technical

summary

Summary of the SEA process

Summary of the likely significant effects of the plan or programme

Statement on the difference the process has made to-date

How to comment on the report

Methodology used Approach adopted in the SEA

Who was consulted, and when

Difficulties encountered in compiling information or carrying out the

assessment

Background Purpose of the SEA

Objectives of the plan or programme

SEA Objectives and

Baseline and Context

Links to other international, national, regional and local plans and

programmes, and relevant environmental objectives including how

these have been taken into account

Description of baseline characteristics and predicted future baseline

Environmental issues and problems

Limitations of the data, assumptions made etc

SEA objectives, targets and indicators

Plan/ Programme

issues and alternatives

Main strategic alternatives considered and how they were identified

Comparison of the significant environmental effects of the alternatives

How environmental issues were considered in choosing the preferred

strategic alternatives

Other alternatives considered and why they were rejected

Any proposed mitigation measures

Plan or Programme

policies

Significant environmental effects of the policies and proposals

How environmental problems were considered in developing the


Framework


policies and proposals

Proposed mitigation measures

Uncertainties and risks

Implementation Links to other tiers of plans or programmes and the project level

(environmental impact assessment, design guidance etc.)

Proposals for monitoring

Annexure 3

RELATIONSHIP BETWEEN THE STRATEGIC ENVIRONMENTAL

ASSESSMENT (SEA) TASKS


Framework


Chapter 3

Chapter 3 Systems for Environmental

Permits


Systems for Environmental Permits 1.1. INTRODUCTION

In many countries in the world, environmental permitting is a key tool to gradually reduce the

environmental burden of industries to the environment. This is done step by step as new purification

and process technologies come available. Environmental permits need to be renewed periodically. The

period of renewal, for example every 3-5 years, is indicated in the issued permit.

All companies, which are polluting or have a risk to cause damage to the environment – existing and

future industries, irrespective of their year of establishment, should have an environmental permit for

their operations, otherwise they should be closed down. Without provisions for environmental

permitting it is impossible to manage environment sustainably. Therefore inclusion of that

provision to Punjab environmental legislation is of paramount importance. Lifetime of an

industrial plant can be even hundred years or more. The current legislation excludes factories, which

are established earlier than promulgation of PEPA from all environmental control measures

including EIA. This is a serious gap in legislation as older industries are often the most polluting

ones.

Environmental permitting is the most important tool in controlling pollution in most of the

countries. In the EU the directive 2010/75/EU on industrial emissions (Integrated pollution

prevention and control) aims to simultaneously control environmental impacts of industries to all

compartments of nature as “different approaches to controlling emissions into air, water or soil

separately may encourage the shifting of pollution from one environmental medium to another

rather than protecting the environment as a whole. In Punjab, it is proposed to have an

environmental permitting system for the operational phase of development projects. It is, therefore,

appropriate to provide for an integrated approach to prevention and control of emissions into air,

water and soil, to waste management, to energy efficiency and to accident prevention”. This

approach is also applied in the environmental permitting procedure.

In many countries environmental permits are linked with Best Available Techniques (BAT) that aims at

a high level of protection for the environment as a whole by stipulating the operating permits of

industries with conditions based on “Best Available Techniques” (BAT). It also provides platform

for an exchange of information on BAT. In Punjab it is proposed to have their own BAT committees

having representation of all of the major industries where everyone can exchange information and

experience in technologies applicable to each type of industry. BAT conclusions are part of the BAT

reference document laying down the conclusions on the best available techniques, their description,

information to assess their applicability, the emission levels associated with the best available

techniques, associated monitoring, associated consumption levels and, where appropriate, relevant site

remediation measures.

Permits must contain emission limit values (ELVs) ensuring that emissions do not exceed BAT-

associated emission levels (BAT-AELs). These limits are then used as conditions in environmental

permit procedures.

In Punjab it is proposed that environmental permitting and BAT shall be reflected in Punjab

Environmental Protection Act and legislation. Those industrial activities needing an environmental

permit are listed in the environmental protection Act. BAT shall be used in an activity needing an

environmental permit and operator must make an own assessment of the use of BAT in the permit


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application. Emission limit values have to comply with BAT Conclusions - however operator may

choose the way and the technique how emission limit values are achieved.

1.2. OBJECTIVES OF ENVIRONMENTAL PERMITTING

The overall goal of environmental permitting is to protect human health and the environment by

defining (in a transparent, accountable manner) legally binding requirements for individual sources of

significant environmental impact in order to protect human health and the environment. Typically,

permits establish limits for pollutant emissions into air and water and for generation and management

of waste, together with any other environmental conditions that are specific to an individual

installation. If properly designed, permit conditions also provide incentives for the regulated

community to protect the environment in an effective and cost-efficient way, and ensure that private

and public interests are equally respected. In addition, they may provide reference levels to calculate

environmental charges or taxes to be paid by industries.

Fig. 3.1: A simplified example of environmental permitting procedure


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The role of the permitting system and the functions required of it must be considered in the context of

the overall environmental regulatory system. The overall system is generally seen as a cycle that starts

with policy planning and the setting of environmental standards and objectives, together with

establishment of legislation and regulations in order to give them legal effect. It is the legal

framework that gives force to the interacting activities of permitting, compliance control and

promotion, and enforcement. Assessment of the success of the system in achieving its objectives may

then be fed back to the appropriate part of the system by way of a commitment to continuous

improvement of the overall system. Therefore, permitting is only one, albeit key, element of the

environmental regulatory system, and reaching environmental objectives requires attention to all

elements and to the way they interact with each other.

1.3. TYPES OF PERMITTING

There are two types of permitting;

1. Single medium permitting

2. Integrated permitting

1.3.1. Single-medium permitting

Single-medium permitting – the traditional regulatory approach – derives from the way that

environmental regulation developed as specific environmental problems (for air, water protection,

waste management, etc.) needed to be addressed. As a result, an operator of an industrial installation

may be required to obtain a large number of environmental authorisations from a variety of separate

authorities that do not necessarily operate in a coordinated or cooperative way.

In this form of control, the limits for environmental impacts of installations are set so as to protect

the environmental medium (water, air or land) into which they discharge to a defined level

represented by Punjab Environmental Quality Standards. Under a single-medium permitting system,

polluting substances may be transferred from one environmental medium into another. Also, dilution

and dispersion of releases to the environment in order to solve a local environmental quality

problem may lead to environmental harm at greater distances. The consequent need to view the

environment as a whole and to minimise pollution through optimal design and operation of an

installation has led to the emergence of an integrated approach to environmental regulation.

1.3.2. Integrated permitting

Integrated permitting means that emissions to air, water (including discharges to sewer) and land, as

well as a range of other environmental effects (the use of energy, water and raw materials) must all

be considered together. It also means that regulators must set permit conditions so as to achieve a high

level of protection for the environment overall. Integrated permitting is based on the concept of

“Best Available Techniques” (BAT) which balances the benefits to the environment against the costs

to the operator and emphasises pollution prevention rather than end-of-pipe control.

Its main features are as follows:

Permitting of industrial installations on a case-by-case basis considering local conditions.

An integrated approach to issuing permits: the procedure for granting permits should be fully

coordinated where more than one competent authority is involved, in order to guarantee

integrated consideration by all institutional stakeholders.


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Public participation and access to information: the public should be given an opportunity to

comment on permit applications before the competent authority reaches its decision and have

access to the permit-related information after the permit has been awarded.

An integrated approach to protecting the environment as a whole, avoiding the inadvertent or

unconsidered transfer of pollutants from one media to another.

The use of Best Available Techniques (see Box 1.1) which, among other things, take into

account the consumption of water and other raw materials and the efficient use of energy.

The focus on pollution prevention and reduction rather than end-of-pipe control.

Accident prevention and minimisation of the consequences of accidents.

The return of the site to a satisfactory condition when the installation is closed.

1.4. INSTITUTIONAL ASPECTS OF PERMITTING

Integrated permitting requires a streamlined application process, improved transparency and coordination

between stakeholder agencies, and public participation. It is essential to determine the administrative level

appropriate for permitting of certain categories of facilities: provincial level for large industrial

installations subject to integrated permitting, and provincial or municipal level for small and medium-

sized installations.

In a future state, Environmental Protection Authority (EPA) would be an enforcement body which acts as

an environmental permit authority and takes care of Environmental permitting, SEA’s EIA’s and

IEE’s. It would also be responsible for environmental inspections related to the above. The system

should be more like a “One-stop shop”, where the applicant deals with competent authority that ensures

coordination with all other stakeholder agencies, increase the consistency and predictability of the

permitting process and reduce the administrative burden on both government and industry. The EPA may

Fig. 3.2: Proposed Structure of EP&CCD


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need to establish permitting committees to exchange information and coordinate decisions with different

internal units regulating air, water, and waste, and with other competent authorities. Permit registers and

intra-agency or interagency electronic networks should be developed to facilitate such coordination. The

procedures for producing a permit will be dependent upon how permitting is reflected in the legislation

under which it is to be issued and upon the nature of links with other legislation and associated authorities.

1.5. PERMIT REQUIREMENTS

The fundamental requirements for environmental permitting are as follows;

1.5.1. Clear and Enforceable Permit Requirements

A permit must contain conditions that are unambiguous and, most importantly, enforceable. The key

to simple, effective and consistent permitting is to base permit conditions on statutory requirements

and technical guidance that have been developed in cooperation with all stakeholders and are

available to all, including the public.

1.5.2. Comprehensive Scope of an Integrated Permit

Integrated permit conditions should either confirm the operator’s proposals or specify any further

requirements. An integrated permit should contain conditions covering the following issues:

i. Operational Matters. Conditions related to operational matters must be based on BAT,

and described in relevant technical guidance, and cover the use of raw materials and water;

techniques for prevention and control of pollution releases; waste management; energy use

and efficiency; emergency preparedness; self-monitoring systems; and site remediation after

decommissioning.

ii. Emission Limit Values. ELVs should be set based on the combined approach for emissions

to the atmosphere, discharges to surface waters, to the sewer or wastewater treatment plant,

and to the ground (unless the latter are banned by law).

iii. Improvement Programme. When the permitting authority accepts an argument from the

operator of an existing installation that it cannot afford an immediate move to a BAT, an

improvement programme to achieve the BAT should be stipulated in the permit.

iv. Records. A permit should contain conditions for making, keeping, and providing access to

appropriate records, including monitoring results and a log record of any failures that had,

or could have had, an effect on the environment.

v. Reporting and Notifications. The permit should specify reporting requirements for the

installation, including parameters to report and frequency of reports, and arrangements for

notifying the permitting authority about such events as exceedance of ELVs, accidents,

temporary or permanent cessation of operations.

vi. Payment of Environmental Taxes and Charges (if applicable).

a. If the operator must pay taxes or charges for its polluting activities or the use of

natural resources (including water abstraction), the requirements for making such

payments should be specified as permit conditions.

vii. Validity and Provisions for Renewal and Variation. The permit should specify the date of

its entry into force and the validity period (in accordance with relevant legislation). It should

also instruct the operator as to when he should apply for renewal or revision of the permit, and

when the competent authority has a right to initiate its revision.


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1.5.3. Combined Approach to Setting Emission Limit Values in Integrated Permits

Setting ELVs in integrated permits should be based on a combination of the environmental quality

standards (EQS) approach and the technique- based approach. An EQS (for water or air) provides a

minimum environmental requirement, and any ELVs set in permits should not cause the EQSs to be

exceeded. The technique-based approach goes further, requiring better environmental performance

through pollution prevention, if it can be achieved at a reasonable cost. Technique-based ELVs may

be derived from a consideration of BAT for an installation, in accordance with the relevant

technical guidance, or fixed in a regulation (statutory ELVs). Where compliance with an EQS

requires stricter ELVs than would be derived from consideration of BAT, the EQS should take

precedence and the stricter ELVs must be included in the permit.

The combined approach requires sound management decisions on the part of an environmental

permitting authority, based upon careful case-by- case evaluation, to ensure that the ELVs that are

ultimately included in an integrated permit satisfy both the BAT and EQS criteria and comply with

any applicable statutory ELVs.

1.5.4. Availability of Technical Guidance

Consistency of approach to integrated permitting and to the setting of appropriate permit conditions

depends on the availability of relevant technical guidance on what constitutes BAT. The operator in

formulating his application and the regulatory authority in assessing it should both be informed by the

same guidance on BAT. Without technical guidance, there would be substantial room for repeated

disagreement between operators and regulators with respect to the identification of BAT, and

judgements could vary widely between permitting authorities.

1.5.5. Discretion of the Permitting Authority

Permitting authorities should be provided (in the legislation) with sufficient discretion to identify

integrated permit conditions as there is no simple algorithm for determining BAT in any specific

case, even in the presence of technical guidance. Informed judgement by experienced regulators is a

crucial element of the permitting process. BAT guidance is neither prescriptive nor exhaustive, nor

does it take account of local environmental conditions, so permitting authorities always have to

make site-specific decisions. However, permitting officers must justify these decisions in writing.

1.5.6. General Binding Rules for SMEs with Significant Environmental Impact

Standard permit conditions can be stipulated for distinct categories of installations with similar

production processes through so-called general binding rules (GBRs). GBRs should include both

statutory ELVs based on “state-of-the-art” techniques for that category of installations and

requirements for certain operational matters, as well as monitoring, record- keeping and reporting

conditions. GBRs should also stipulate simplified application forms requiring operators to

demonstrate compliance with the standard requirements.

The following criteria should apply before consideration is given to the use of GBRs:

GBRs must cover a sufficient number of installations in a particular category to make the

development of GBRs cost- effective (this is a matter of judgement by the regulator).

The current status of technology and techniques in that category of installations must not be

fast moving, as GBRs cannot be updated frequently.

Installations must have a similar impact on the environment.


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1.5.7. Registration of Installations with Low Environmental Impact

The preferred regulatory option for installations that intrinsically have no potential to cause

significant environmental impact would be simple registration with local or environmental authorities,

proving their low environmental impact. Such installations by their very nature have only negligible

impact on environment and do not have to rely on pollution control measures to minimise that impact.

Regulating them more extensively is unlikely to add benefit for the environment.

1.6. PROCEDURAL ASPECTS OF PERMITTING

1.6.1. Transparent Permitting Procedure

Developing and issuing an environmental permit should involve the following general stages:

i. Pre-application activities, focused on helping the applicant understand the nature of his

obligations and general contents of an application.

ii. Preparation and submission of application by the operator, following standard guidance

and/or form.

iii. Receipt and Initial check of application by the regulatory authority to ensure that the

application is valid, i.e., conforms to the legal requirements.

iv. Consideration of commercial confidentiality or national security request with respect to

making public some parts of the application, to be justified by the operator and approved by

the regulator.

v. Consultation on application of the permitting authority with other authorities and the

public in order to gather facts and opinions that would contribute to the assessment of the

application.

vi. Assessment of the application and determination of permit conditions, using technical

guidance and requirements of relevant legislation.

vii. Issuance of a permit or notification of refusal, subject to administrative and judicial

appeal.

viii. Permit variation, surrender or revocation, procedure broadly similar to those of initial

issuance

It is important to set time limits for each stage of the procedure. Time limits will lead to reduced costs

for applicants and make government agencies more accountable and responsive.

i. Stage 1: Pre-application Activities

The environmental permitting authority and the operator may hold pre-application discussions before the

operator makes a formal application. Other parties may join these discussions. Operators and regulators

may use the discussions to clarify whether a permit is likely to be needed at all, and if so, what type of

permit is required. This step may also require a decision as to which is the appropriate regulatory authority

or whether any special provision applies by reason of the low environmental impact from the installation.

Pre-application discussions should be focused primarily on helping the applicant understand the nature of

his obligations and what needs to be included in an application.

The permitting authority may also give operators general advice on how to prepare their applications, and

tell them what guidance is available. The regulator must not imply any advance agreement as to the

outcome of any application at this stage, nor appear to be giving the operator guidance that might be

construed as technical instructions for plant selection or construction. This might prejudice the eventual


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determination of the permit or any appeal against its conditions. In view of this possibility, it may be

desirable for the regulatory authority to have clear working instructions for staff setting out the boundaries

of exchanges with operators at this stage and emphasizing the need for proper recording of any such

exchanges.

ii. Stage 2: Preparation and Submission of Application by the Operator

Following any pre-application discussions, the operator is responsible for making a permit application that

covers the full range of activities that are required to be permitted. The application needs to assess the

possible effects of the operations, to explore ways of improving them and to make proposals for the

regulator’s consideration. It also needs to demonstrate how he would manage his installation in a way that

will meet all the requirements of the legislation and associated regulations.

There may be an administrative fee required for the consideration of the application, which may depend on

the size of the installation (a smaller fee would be payable for a revision of an existing permit).

iii. Stage 3: Receipt and Initial Check of Application by Regulatory Authority

The regulatory authority should check permit applications as soon as they are received, or at least within a

few days from receipt, in order to ensure that the application is valid. An application is valid if it is

complete in a legal sense. This means that all of the necessary questions must be answered, and it must be

submitted on a standard application form. Until an application is deemed valid, it is not legally an

“application,” just a submission from an operator.

It is also appropriate to conduct an initial technical check of the application to consider whether the

information submitted meets the test of basic adequacy to be accepted as an “application.” A basic

principle is that the information submitted should provide at least a reasonable starting point for a

determination in order to be considered valid. Regard should also be had to any relevant technical guidance

and the extent to which the operator has taken account of it in preparing the application.

If the application is deficient in some respect, the regulator may have to request additional information,

thus delaying the determination of the permit. If the regulatory authority judges that an application is not

valid for some reason, it should return it within a certain number of days.

iv. Stage 4: Consideration of Commercial Confidentiality or National Security

In dealing with some permit applications it may be necessary, before doing anything else, to ensure that the

regulatory authority does not reveal any information to third parties, or include it in the publicly accessible

permit register, if that would prejudice the commercial interests of the applicant. In such cases, the operator

needs to demonstrate in a commercial confidentiality request that the revealing of specified information, or

its inclusion in a public register, would prejudice his commercial interests to an unreasonable degree. It is

necessary to set a time limit for regulatory consideration of any such claim.

In some cases, similar issues may arise in connection with matters of national security, where similar

arrangements need to be made.

v. Stage 5: Consultation on Application by the Permitting Authority with Other Authorities and

the Public

Following receipt of a valid application, the regulatory authority should consult other stakeholders in order

to gather facts and opinions that would contribute to the determination of the application. For example,

depending upon the requirements of national legislation and institutional arrangements, the regulatory

authority may need to consult other authorities with related responsibilities or interests (e.g., other relevant


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departments of the environmental agency, the environmental inspectorate in particular, health authorities,

sectoral ministries, local authorities, etc.).

Also, apart from being good practice in general, countries that have ratified international conventions, are

obliged to make statutory provision for public access to environmental information and for hearing and

taking account of public views, both domestically and internationally. For the purpose of consulting the

general public, it is appropriate to maintain a permit register accessible to the public, where applications,

permits and associated information may be placed, subject to consideration of commercial confidentiality

or national security. It remains then only to advertise the fact that a new application has been received and

that the regulator will welcome public views.

vi. Stage 6: Assessment of Application and Determination of Permit Conditions

When the regulatory authority is satisfied that all relevant information concerned with an application has

been assembled, including the consultation responses from the general public and from other authorities,

the application should be assessed and a determination of the permit conditions made. The regulatory

effort invested and the nature of the permit conditions must be proportionate to the complexity of the

installation and its environmental effects.

The procedures for making this judgement, and for setting related permit conditions are likely to vary from

country to country, as are the eventual technical judgements and associated permit conditions. It is

common practice, however, to refer both applicants and regulators to publicly available technical guidance.

After assessing the application, the regulatory authority must either determine permit conditions, having

regard to all the requirements of the relevant legislation and regulations, or decide to refuse the permit.

This step of the overall permitting procedure is likely to require careful coordination and oversight, and

their efficient delivery would benefit from the availability of clear work instructions for regulatory

authority staff.

vii. Stage 7: Issue of Permit or Notification of Refusal

Upon receipt of final consultation responses and if satisfied, the regulatory authority should finalise the

conditions of the permit and send it formally to the operator. The permit should state its effective date and

validity period. Environmental permits in OECD countries are most often valid for five to seven years (as

compared to very short validity periods of one to three years in EECCA countries). For Punjab it is

proposed that the validity of environmental permitting is for three to five years. In some countries (e.g., in

Sweden), permit conditions remain in force until other factors (see the following section) trigger a revision.

Longer validity periods simplify the permitting system and reduce the administrative burden on both the

government and industry.

If the regulatory authority is not satisfied after assessment of the application, it must refuse the permit and

notify the operator to that effect, giving reasons for the refusal.

The provisions for appeal against decisions of the regulatory authority will also depend on the national

legal framework, particularly on the degree of discretion afforded by the law to the regulatory authority.

Appeal authorities and practical arrangements for appeal are a matter of choice for individual countries. An

appeal may be considered through written representations or through a hearing, at the discretion of the

appeal authority. Obviously, the procedures for consideration of appeals should be designed for the higher,

appeal authority and not for the permitting authority.

viii. Stage 8: Permit Variation, Surrender or Revocation


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The procedures for variation (revision) of a permit are broadly similar to those for its initial issue.

Permits must be revised at the operator’s initiative if changes are envisioned to the regulated process

or if there are changes to the operator’s ownership or contact information. A permit revision may be

initiated by the competent authority if the applicable environmental quality objectives and/or

standards have been modified.

The operator may surrender the permit voluntarily if he ceases the activity for commercial or other

personal reasons, but has to do so through a formal application to the regulatory authority.

Revocation or temporary suspension of a permit are likely to be used only where exhaustive use of

other enforcement tools has failed to protect the environment. The permitting authority or some other

legal authority may have powers to suspend or revoke a permit, in whole or in part, by serving a

formal notice on the operator. The permit would then cease to authorise operation of the installation,

or an activity within it, depending upon what is specified in the notice. Any post-operation

requirements, such as site restoration, however, may remain in force.

1.7. APPLICATION FOR A PERMIT

It is the responsibility of the operator of an industrial installation to know the law that applies to his

installation and to apply for a permit (if one is required) in time (taking into account the time

necessary to process the application – about 6 months). Nevertheless, regulatory authorities would

normally be expected to support industry by providing information and guidance where appropriate.

This might even include pre-application discussion in order to clarify what type of permit is required

and what information needs to be presented in the application for it. In any case, however, the

operator should understand the requirements of the relevant legislation and have studied any permit

application forms and associated instructions, as well as any relevant technical guidance, before

preparing an application.

An application for an integrated permit will have to provide sufficient information for the regulatory

authority to write the permit according to the requirements of relevant national legislation. The

information likely to be required generally includes the following.

1.7.1. Identity of the Installation

Information is required for clear identification of the installation to be permitted, together with

information about any other permits that exist for that installation. The latter information is necessary

for administrative purposes and also for ensuring that any interactions with other permits and

respective regulatory authorities are handled effectively during the permitting procedure.

1.7.2. Identity of the Operator

Information is required on the identity, contact details and legal status of the operator in order to

establish clearly who is responsible for securing compliance with the permit and who is liable in case

of enforcement action for any non-compliance.

1.7.3. Scope of Installation and Initial Condition of Site

A clear description is required of all the relevant activities and facilities comprising the installation to

be permitted. Also, for the purpose of ensuring that decommissioning and site remediation are

properly carried out when the installation is shut down, it is necessary to have a report on the initial

condition of the site for comparison purposes.

1.7.4. Proposed Operational and Management Techniques


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The application must demonstrate that the techniques to be employed at the installation are BAT. The

techniques to be addressed might typically include the following:

Use of raw materials and water

Prevention and control of emissions and waste

Waste management

Energy use and efficiency

Emergency preparedness

Monitoring systems

Decommissioning and remediation

Environmental management system

Guidance on what is BAT for these techniques should be available to applicants in either sector-based

or cross-sectoral technical guidance. Applications that propose techniques that deviate from those

generally accepted as representing BAT for the sector will need to justify the proposals in terms of the

circumstances of the specific installation and present a detailed programme of improvements and

upgrading. At the same time, operators should be free to propose innovative techniques that would

achieve better environmental performance than those included in the technical guidance.

1.7.5. Proposed Emissions

Information must be provided on all the emissions resulting from operation of the installation using

the techniques proposed above, and it must be demonstrated that they comply with the relevant sector-

based BAT benchmarks, on which permit ELVs will be based. These benchmarks should be available

in technical guidance for the relevant industrial sector or, failing that, indicative values should be

available in general sector guidance.

1.7.6. Impact of Emissions on the Environment

Information should be given on the results of assessment of any potentially significant environmental

impacts of the above emissions. The purpose of this assessment is to demonstrate that the impacts will

be acceptable, by way of compliance with relevant EQSs. Inability to demonstrate such acceptability

may lead to a rejection of the application.

1.7.7. Other Relevant Information

Regardless of the structure of any application form or specified requirements, any applicant should

feel free to submit any other information in support of his application, provided the information is

relevant and to the point. The need for such information would, typically, be appropriate for

discussion at the pre-application stage.

1.7.8. Non-technical Summary

Where there is a requirement for applications to be placed on a public register, it may be appropriate

to require applicants to submit a non-technical summary of the application. This should follow the

structure of the application and be in sufficient detail and in such language as to allow members of the

public to understand the proposal and to make a sensible response. Typically, such a summary for a

complex application might be about 10 pages and about 2 pages for a simple one.

1.7.9. Declaration

Any application should be signed and dated by the operator, with a declaration that the information

supplied is correct. The application should specify the date by which a permit is requested. In case of


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renewal, this date should obviously be the expiration date of the old permit. The application

requirements described above are typical of those for integrated permitting. Simplified requirements

may be applied to small and medium-sized installations, but the application would have to include

information to show that the installation complied with the defined threshold for such simplified

procedure.

Generally, an applicant has a right to claim protection of information judged to be commercially

confidential or subject to considerations of national security. The claim for commercial confidentiality

should be made with the application but the information proposed for protection should be submitted

on separate pages and appropriately marked in order to facilitate its exclusion from any public

register. A claim for protection of information on the grounds of national security should be made

separately and no reference to it should be made in the main application.

Chapter 4

Technology Transfer

Section 1

Framework for transfer and adoption of

Cleaner Technologies, especially Low-

cost, Sector Specific Technologies

Chapter 4 Technology Transfer


Chapter 4

Technology Transfer

Section 1

Framework for transfer and adoption of cleaner technologies, especially low-cost, sector specific

technologies.

1.1. INTRODUCTION

Balancing environmental benefits with economic incentives has been quite a long race now. Over

time, the globe has experienced a transition in production trends and thereby a shift in focus for

focusing simply on economic development to carrying out economic activities in a sustainable

manner. The emphasis being given to environment aims to ensure sufficient resources available for

future generations and preservation of nature. As a result, clean technologies have gone through

multiple phases of development. What started with dilute and dispersion approach in 1950s moved

towards end-of-pipe technology in 1970s. Market based instruments made an entry in 1972 by OECD,

proposing payment of tax for polluting the environment. Furthermore, the pollution prevention pay, or

famously 3P principle, caught attention in North America. The OECD defines cleaner technology as:

“Technologies that extract and use natural resources as efficiently as possible in all

stages of their lives; that generate products with reduced or no potentially harmful

components; that minimize releases to air, water and soil during fabrication and use

of the product; and that produce durable products which can be recovered or recycled

as far as possible; output is achieved with as little energy input as is possible”.39

On the other hand, Cleaner production can be defined as:

“Continuous use of industrial processes and products to prevent the pollution of air,

water and land, reduce wastes at source, and minimize risks to the human population

and the environment”

In both cleaner technology and cleaner production, major objective is to minimize the pollutant

outputs and harmful/non-renewable inputs being used. One of the easier ways to ensure cleaner

production is through the implementation of Cleaner technologies. As we enter a phase of complex

environmental problems, coupled with an exponential increase in industrial development, the

incorporation of Cleaner production in the industrial processes and activities is a need of time. This

need is further reiterated due to the focus on sustainable development and market competitiveness.

1.2. CURRENT STATUS

Clean interventions through cleaner technologies have gotten more attention in Pakistan because of

their intrinsic ability to help meet legislative and environmental standards. The cleaner production

39

Biotechnology for Clean Industrial Products & Processes towards Industrial Sustainibility

http://www.oecd.org/sti/biotech/1895218.pdf

http://www.oecd.org/sti/biotech/1895218.pdf



initiatives, including the 3 cleaner production centers in Pakistan have focused on conducting

environmental and energy audits to identify gaps for improvement, suggest appropriate measures,

providing technical assistance to industries, and raising awareness on cleaner production. Existing

Cleaner technology initiatives, like Cleaner production centers have successfully demonstrated their

ability to bring effective outcomes, increasing efficient and create mutually supporting relationships

with managers and staffs at firms they have served. However, the technical assistance programs have

operated without a specially designed national strategy or plan.

Currently there are 3 cleaner production centers in Pakistan namely Cleaner Production Center in

Sialkot, Cleaner Production Institute in Lahore and National Cleaner Production Center in

Rawalpindi. Although the current initiatives have provided a good start towards the objectives of

Cleaner technologies, a main challenge being faced in Pakistan like many other developing countries,

is to change the long-term culture of a larger cluster of stakeholders contributing to significant waste

discharges.

Each of Punjab’s three CP centers have the capacity to educate and incentivize the firms they serve to

adopt CP practices.

The Cleaner Production Centre (CPC), which is based in Sialkot, has only worked with

leather tanneries in the Sialkot area, and much of its work has been with SMEs. It was started

using funds provided by the Government and bilateral aid from Norway and its continuing

operation depends on securing funding from donors and/or the government.

The Cleaner Production Institute (CPI), with offices in Lahore, Faisalabad and Karachi,

serves several industrial sub-sectors: leather tanning, textile processing, sugar, and pulp and

paper. The CP projects it recommends are often executed by consultants, particularly the

National Environmental Consulting Pvt. Ltd, a private for-profit firm that is legally

independent of CPI. The Center was started using funds provided by the Embassy of the

Kingdom of the Netherlands and has had a long-term relationship with the Embassy. As in the

case of CPC, the Cleaner Production Institute continues to rely on donor funding.

The National Cleaner Production Centre-Foundation (NCPC-F), which is located at the

Attock refinery in Rawalpindi, focuses on providing CP support to the oil and gas sub- sector

and, to a lesser extent, to other sectors. It has the broadest geographical coverage of the three

centers and operates primarily in Punjab and Sindh. Unlike the other two CP centers, NCPC-F

is not dependent on donor or government funding. Although it was initially started with

money from UNEP and the United Nations Industrial Development Organization (UNIDO),

since 2005, it has been financially self-sufficient. It obtains its revenues by selling

environmental services; e.g., monitoring of industrial waste discharges, and the preparation of

environmental impact assessments and energy audits.

1.3. WAY FORWARD

There is no doubt that the concept of technology transfer, primarily through CP shall require an active

public-private sector partnership. Under the new proposed structure, Institute of Environmental

Technology & Training (IETT) shall promote investment in local manufacturing of cleaner equipment

useful in Punjab’s major industries and help them identify funding sources and suppliers for advanced

cleaner technologies. The Best Available Techniques(BAT) Technical Committee shall also be able to

contribute in this regard.



The institute shall be active in 3 regions: South, Centre and North, covering the respective regional

domain. Moreover, IETT shall oversee industries to increase their scope of activities to include

instructing firms on:

CP measures and cleaner technological advances that are most appropriate and relevant,

Ongoing integration of environmental and energy audits and related CP approaches into

firms’ daily operations to make continual improvements,

Creating a formal EMS structure and getting majority of industries certified to ISO 14001,

and

Remaining up-to-date on sector-specific requirements imposed by countries when importing

or exporting.

As an effort to encourage the incorporation and awareness on cleaner technologies, IETT shall have

three main objectives:

Provide technical advice to and promote information sharing among industries and CP

centers;

Seek funding from technology transfer mechanism under MEAs and engage in international

exchanges of information with other national/provincial CP centers; and

Participate, under the leadership of MoI, in expanding efforts to diffuse CP-related concepts

and technologies as well as information on EMS and ISO 14001 to firms in Pakistan.

The following shall be among other additional functions to be carried out by IETT under new

structure:

1. Forming links with universities to have cleaner technologies, technology transfer and EMS

integrated into curricula, particularly at business schools and environmental engineering

programs in Pakistan. In this regard, IETT can have a center set-up at universities like Lahore

University of Management Sciences (LUMS), National University of Sciences & Technology

(NUST), Punjab University etc. National and/or international research funding could be

sought from R&D organizations for the purpose of bringing innovative research &

entrepreneurship for final year projects at public/private sector universities. The center shall

also act as a platform for lab-scale and pilot-scale testing of innovative projects and if needed,

separate funds can also be allocated in the R&D budget; 2. Organizing roundtables and conferences for staffs of industry associations and national CP

centers to encourage networking and information sharing across centers and industry

associations from different sectors; and

3. Creating and providing access to databases with advanced clean technologies, CP measures

solutions and case studies that can serve as models of best practices.

Other than cleaner technologies, basic CP measures that may represent feasible and relatively low-

cost measures for firms to adopt and use as part of ongoing operations can be good housekeeping

practices (i.e. avoiding spillages and reusing materials); improved chemical storage practices;

improved worker safety practices; and monitoring the use of chemicals, electricity and water.

One of the challenges facing two of the three existing centers—Cleaner production center in Sialkot

and CPI Cleaner Production institute in Lahore – is that they depend heavily on external funding40

.

40

Cleaner Production and Institutional Development in Pakistan,

http://www.lead.org.pk/attachments/mtd/mtd50/attachments/fellow_case_study.pdf

http://www.lead.org.pk/attachments/mtd/mtd50/attachments/fellow_case_study.pdf



National Cleaner Production Center in Rawalpindi operates with a comparatively better business

model and does not rely on donor or government funding. Existing and new CP centers would benefit

from creating advisory boards. These boards could help centers in: creating sound financial plans and

business models to sustain and expand operations; and guiding centers on how best to further assist

firms in integrating CP, EMS, and ISO 14001 certification into routine business operations and long-

term plans. Advisory board members could include key stakeholders such as: the provincial EPAs for

the provinces in which the center operates, the industry associations for the sectors served by the

center, and representatives from private consulting firms that may be impacted by the CP centers

activities. The advisory board shall meet regularly to advise the national/provincial center leadership

on the types of activities and programs the CP centres should prioritize. Additional funding should

also be obtained to support expansion of existing centers and the creation of new centers to reach

firms and industrial sectors not currently served.

A sample checklist is proposed can act as a Knowledge Performance Indicator (KPI). This could help

with regard to monitoring of the status of Cleaner technologies across different departments, including

industries is shown in Table 4.1. This would assist in identifying gaps and eventually working on

them for an effective framework of cleaner technologies.

Table 4.1: KPIs for performance of Cleaner technology transfer

Sr. No. Factors

Ranking (assumed in

this case)

H: High, M: Medium, L:

Low

1. Infrastructure for Clean technologies, including technical

competency of staff H

2. Availability of Clean technology tools H

3. Adequacy of capital investment for Clean technologies H

4. Enforcement of environmental regulations M

5. Advantages on implementing clean technologies H

6. Clean technologies as a competitive edge H

7. Customers orientation on clean technologies L

8. Diffusion rate of clean technologies H

9. Road map for Clean technologies M

10. Government support H

11. Investment by Government H

12. Business environment for clean technologies L

13. Research & Development activities in Clean technologies H

14. Commitment level of Industrial units on clean technologies H

The UNFCCC technology transfer framework defines five key elements for meaningful and effective

actions in technology transfer: (1) technology needs and needs assessment; (2) technology



information; (3) enabling environments; (4) capacity building, and (5) mechanisms to facilitate

institutional and financial support to technology cooperation, development and transfer41

.

Additionally, Table 4.2 lists some mechanisms to promote clean technology development and

transfer, adapted from the UN’s guideline on Technology development and transfer.42

Table 4.2: Innovative mechanisms to promote Clean Technology Development and Transfer

Mechanism Rationale Feasibility at IETT

Publicly-supported centers for

technology development and

transfer

Green revolution model of

technology diffusion; makes

technologies available to

developing countries without

IPR protection

Enough funding shall need to

be sustained from multiple

sources to exploit the full

potential

The centers shall target both

mitigation & adaptation

technologies

Technology funding mechanism

to enable participation of

developing countries in

international R&D projects

Resultant Intellectual Property.

Rights could be shared; patent

buyouts could make privately

owned technologies available to

developing countries

Sufficient incentive for

sharing by developed country

private sector technology

leaders shall need to be

ensured along with proactive

participation of IETT

Patent pools to streamline

licensing of inventions needed to

exploit a given technology

Developing country licensees

won’t have to deal with multiple

patent holders

Government regulations

shall need to be checked

along with the available

incentives to patent holders

Global R&D alliance for

research on key adaptation

technologies

Model of research on neglected

tropical diseases

Active partnership with

potential international

funding/R&D agencies

needed. Educational

institutes already working

with such alliance can

contribute, wherever,

however needed

Global clean technology venture

capital fund

Fund located with a multilateral

financing institution which will

also have the rights to

intellectual property

Funding pathways available

under several Multilateral

Environmental Agreements

(MEAs) to which Pakistan is

signatory can be utilized.

Likewise, the possibility of

41

Technology Transfer Framework http://unfccc.int/ttclear/tec/tech-transfer-framework.html 42

Technology Development & Technolog Transfer

https://sustainabledevelopment.un.org/content/documents/tec_technology_dev.pdf

http://unfccc.int/ttclear/tec/tech-transfer-framework.html

https://sustainabledevelopment.un.org/content/documents/tec_technology_dev.pdf



utilizing provincial

Sustainable Development

Funds can be explored

Eco-Patent Commons for

environmentally sustainable

technologies

Approach initiated by the private

sector to make certain

Environmentally Sound

Technologies available royalty-

free on a “give- one, take-one”

model

Although the private sector

is motivated by such

voluntary mechanisms, but

IETT can provide incentives

(e.g. during monitoring,

specific color label) to

companies working with

such patents.

For environmental friendly

labels/products/certifications,

partnership with companies

issuing such

labels/certifications can be

helpful such as SGS,

Rainforest alliance etc

More favorable tax treatment in

developed countries for private

sector, R&D performed in

developing countries

More pro-active, technology-

push approach by developed

country governments

This can be really beneficial

in Pakistan and specifically

Punjab, under supervision of

IETT provided the political

constraints are already

considered. Universities like

LUMS, NUST, PU can act as

a hub for the R&D being

conducted

Technology prizes Reward innovation without

awarding IPRs to innovators

A well-specified research

objective shall be needed

along with the advanced

capacity of staff to analyze

the feasibility of competing

research projects. The Best

Available Techniques(BAT)

technical committee can

contribute in this regard

1.3.1. Recommended actions

Support for Environmental Institutions — IETT shall receive the budget and staff needed to

carry out key coordination functions on environmental matters with provinces and

international bodies. In addition, other units at the provincial level shall be strengthened at

levels needed to undertake their new roles pursuant to the 18th

Amendment.



Extension of Cleaner Production (CP) Activities — The work of current CP centres should be

expanded; new CP centers should be created, including the 3 provincial centers for CP(North,

South, Central); centers should improve the transfer of information to firms about integrating

both CP and ISO 14001 into business operations; and all centers should have advisory boards

to guide them on how to operate on a sustainable financial basis and help firms integrate CP,

PEQS compliance and ISO 14,001 certification into their business strategies.

Common effluent treatment plants (CETPs) — End-of-pipe treatment can complement CP in

the short-term to help firms enhance environmental performance, become certified to ISO

14001 and hence become more competitive internationally. Thus, priority should be given to

constructing and operating CETPs in industrial clusters.

Punjab Environmental Quality Standards (PEQS) — In the short term, the aforementioned

measures concerning CP and CETPs will not be enough to allow many firms to meet existing

PEQS and become certified to ISO 14001. The PEQS can perhaps be relaxed on an interim

basis so that they can be met using relatively inexpensive waste treatment methods. The

interim standards should prioritize protecting human health and avoiding major nuisance

conditions. More rigorous permanent standards can be implemented after CETP construction

is under way. Implementation of Best Available Techniques(BAT) shall complement this

process as well

Public Information Disclosure — IETT can foster the creation of an environmentally

informed citizenry by distributing information regarding firms’ violation of environmental

regulations and regarding the health impacts of environmental degradation. Other countries

have piloted innovative public disclosure programs: Indonesia has a “Program for Pollution

Control, Evaluation, and Rating,” commonly referred to as “PROPER,” that uses a color-

coded rating scheme to inform citizens of the environmental performance of firms; and a

Chinese non-governmental organization (NGO), the Institute for Public and Environmental

Affairs, has created the China Water Pollution Map and the China Air Pollution Map to allow

citizens to conduct computer searches that identify violators of environmental regulations in

their communities.

Section 2

Guidelines and a set of Available

Pollution Control Technologies for major

industries in the province limited to a

total of five



Section 2

2.1. INTRODUCTION

Best available techniques (BAT) are defined as the “latest stage of development (state of the art) of

processes, of facilities or of methods of operation which indicate the practical suitability of a

particular measure for limiting discharges, emissions and waste.” Within this terminology:

"Techniques" includes both the technology used and the way in which the

installation is designed, built, maintained, operated and decommissioned;

- "Available" means those developed on a scale which allows implementation in

the relevant industrial sector, under economically and technically viable

conditions, taking into consideration the costs and advantages, whether or not the

techniques are used or produced inside the Member State in question, as long as

they are reasonably accessible to the operator;

- "Best" means most effective in achieving a high general level of protection of

the environment as a whole.43

The terms Best Available Technologies, Best Available Control Technologies and Best Available

Techniques are interchangeably used, when referring to BAT. In the US’ framework, “Best Available

Technology” is used44

while in EU’s Directive, the term “Best Available Techniques” is used.45

While

techniques may seem a generic term that would embody the technologies but nevertheless, both have

the same targets.

In determining whether a set of processes, facilities and methods of operation constitute the best

available techniques in general or individual case, the usual requirement to perform a BAT analysis is

kept as part of the permitting approval process. It is incumbent upon the regulatory permit reviewer to

understand emission control technologies in order to objectively evaluate the BAT to be implemented

by the industries.

2.2. PROCEDURE FOR CHOOSING BAT

Choosing the Best Available Technique in any environmental media(air, water, wastewater) for its

respectable application follows a systematic approach. The appropriate technique/technology would

be the one that has the least environmental impact but sometimes it is not feasible to use the most

effective pollution control option because of the economic, energy or technical impacts that it might

impose. A top-down approach, shown in Figure 1, is used in North America in this regard which is a

relatively fast, practical, repeatable and simple procedure for any source or pollutant under

consideration.46

43

Definition of BAT – Friends of the earth,

http://www.elni.org/fileadmin/elni/dokumente/elni_forum/2010/Pres_LesleyJames.pdf 44

RACT, BACT, LAER Clearinghouse, https://www3.epa.gov/ttncatc1/rblc/htm/welcome.html#data 45

European Environmental Agency, https://www.eea.europa.eu/themes/air/links/guidance-and-tools/eu-best-

available-technology-reference 46

BAT – Analysis Guidance and Case studies for North America, http://www3.cec.org/islandora/en/item/2195-

best-available-technology-air-pollution-control-en.pdf

http://www.elni.org/fileadmin/elni/dokumente/elni_forum/2010/Pres_LesleyJames.pdf

https://www3.epa.gov/ttncatc1/rblc/htm/welcome.html#data

https://www.eea.europa.eu/themes/air/links/guidance-and-tools/eu-best-available-technology-reference

https://www.eea.europa.eu/themes/air/links/guidance-and-tools/eu-best-available-technology-reference

http://www3.cec.org/islandora/en/item/2195-best-available-technology-air-pollution-control-en.pdf

http://www3.cec.org/islandora/en/item/2195-best-available-technology-air-pollution-control-en.pdf



Fig. 4.1: A top-down process used for choosing the most appropriate BAT

2.2.1. Step 1: Identify possible control Technologies

The first step in a top-down analysis is to identify all available control options. Available options can

be those technologies or techniques with a practical potential for application to the emission unit and

the pollutant under evaluation for emission reduction. Pollution control technologies and techniques

include the application of production processes or available methods, systems, and techniques, for

control of the affected pollutant. This includes technologies being used anywhere in the world.

2.2.2. Step 2: Eliminate infeasible options

Once all the pollution control technologies have been identified, their technical feasibility is evaluated

with respect to the source-specific (or emissions unit–specific) factors. Demonstration that an option

is not technically feasible is clearly documented based on physical, chemical, and engineering

principles. Control options that are not technically feasible are then eliminated from further

consideration.

2.2.3. Step 3: Sort and Rank Feasible Options

In this step, all remaining control alternatives not eliminated in step 2 are ranked and listed in order of

over-all control effectiveness for the pollutant under review, with the most effective alternative at the

top. A list should be prepared for each pollutant and for each emission unit (or grouping of similar

units) subject to a BAT analysis. Including the following data may help in this regard:

Emission reductions (% pollutant removed);

Expected emission rate (tons/year, pounds/hour);

Energy impacts;

Environmental impacts (includes any significant or unusual other media impacts, such as

water or solid waste, and effect on toxic or hazardous air contaminants);

Identify possible control technologies

Eliminate infeasible options

Sort and rank feasible options

Evaluate most effective option

Select BAT



Economic impacts (cost effectiveness). an applicant proposing the top control alternative

need not provide cost and other detailed information in regard to other control options. In

such cases the applicant should document to the satisfaction of the review agency that the

control option chosen is, indeed, the top.

2.2.4. Step 4: Evaluate most effective option

After identification of all available and technically feasible technology options, their associated

energy, environmental, and economic factors are evaluated in order to arrive at the final level of

control. At this point the analysis presents the associated impacts of the control option in the listing.

For each option, the applicant is responsible for presenting an objective evaluation of each impact.

Both beneficial and adverse impacts should be considered and quantified, wherever possible. In

general, the BAT analysis should focus on the direct impact of the control alternative. If the

applicant accepts the top alternative in the listing as BAT and there are no outstanding issues

regarding collateral environmental impacts, the analysis has ended, and the results are proposed as

BAT.

In the event that the control candidate is shown to be inappropriate, due to energy, environmental or

economic impacts, the rationale for this finding should be documented. Then, the next most stringent

alternative in the listing becomes the new control candidate and is subject to evaluation in the same

way. This process continues until the technology under consideration cannot be eliminated by any

source-specific environmental, energy, or economic impacts which demonstrate that option to be

inappropriate as BAT. The economic impact tends to be the most direct factor, as environmental and

energy issues can often be overcome by more expensive systems. The determination of what is

economically feasible is a subjective, case-by-case assessment by the evaluating expert. The objective

is to establish an acceptable level of cost impact.

2.2.5. Step 5: Select BAT

At this point, there should be one option that has been chosen as the best available and most feasible

emission reduction option. By this stage, there should be significant justification and documentation

available to support this decision. This decision, along with all the pertinent documentation that led to

it, is then submitted to an environmental official for review. Ultimately, the reviewer makes the

decision as to which control option is the best and most reasonable. This process is then repeated for

each pollutant and each process of interest.

2.3. DATA COLLECTION FOR DETERMINING BAT

On ground information regarding feasibility of BAT and collecting relevant data is an important step

when determining BAT. The information on key environmental issues can be obtained through

industry-specific questionnaires. These questionnaires are usually developed with the contribution of

Technical experts, having ample experience, working in the industry being concerned. The collected

data can include, but not limited to:

Emissions to air and water

Generation of solid by-products, residues and wastes

Efficient use of resources (e.g. Energy, water)

Techniques that are potential bat candidates



In the same way, contextual information relating to details on the techniques used (characteristics,

historical data) in normal and other than normal operating conditions, link between the fuel

characteristics and generated pollutants and consumptions (e.g. raw water, energy, chemicals) shall be

collected for effective usage of data during different steps.

2.4. BAT REF DOCUMENTS & BAT CONCLUSIONS

Under the European Commission’s Integrated Pollution Prevention and Control (IPPC) directive,

BAT ref documents and BAT conclusion documents have been prepared. As defined in the directive:

“BREF or ‘BAT reference document’ means a document, resulting from the exchange

of information organized pursuant to Article 13 of Directive 2010/75/EU, drawn up

for defined activities and describing, in particular, applied techniques, present

emissions and consumption levels, techniques considered for the determination of best

available techniques as well as BAT conclusions and any emerging techniques, giving

special consideration to the criteria listed in Annex III to Directive 2010/75/EU”

BAT Conclusion in the same way, is a part of BAT ref documents and can be defined as:

“A document containing the parts of a BAT reference document laying down the

conclusions on best available techniques, their description, information to assess their

applicability, the emission levels associated with the best available techniques,

associated monitoring, associated consumption levels and, where appropriate, relevant

site remediation measures.”

To introduce the inclusion of BAT in the permitting process of Punjab, the Institute of Environmental

Technology & Transfer(IETT) shall initially rely on the BAT reference and BAT conclusion

(wherever available) documents already published by the European directorate. The primary reason

for this choice is the lack of desired expertise currently including infrastructure, to conduct such a

comprehensive research for certain techniques/technologies to be classified as ‘best available’. This

activity also requires active involvement of all relevant stakeholders and as discussed, currently EPD

doesn’t have an effective framework and partnership in place with stakeholders such as industries,

NGOs, universities etc in order to integrate their expert opinion at policy level such as for BAT. The

BAT reference and BAT conclusions shall be contextualized and their link with PEQS is described in

the heading.

Over time, once EPD has established enough capacity and proven success of the BAT being used in

EU, IETT shall develop its own set of criteria and BAT. The immediate target has to be meeting the

PEQS so if there are no strict requirements e.g. export specifications, as long as the PEQS are being

met through the implementation of BAT to whatever capacity after contextualization, it shall suffice.

However, since the actual target and benchmark is going to be the EU BAT reference documents,

compliance with PEQS shall act as a trigger for even stringer permit conditions over time and

eventually reaching the highest possible level of compliance and environmental improvement.



2.5. IMPLEMENTATION OF BAT

The implementation of BAT by IETT on ground shall primarily rely on the conditions of issued

permits. With reference to BAT, every industrial installation shall require a permit including Emission

limit values (ELVs) or equivalent parameters or technical measures. Along with this, the permit shall

also include:

Suitable emission monitoring requirements, including the obligation to report emission

monitoring results

Requirements for regular maintenance as well as for other than normal operating conditions

Conditions for assessing compliance with the emission limit values

The chart below shows a sample of ingredients that can be included in permits, with regard to BAT:

Fig. 4.2: Contents of permits with reference to BAT

A generic framework of BAT implementation is shown in Figure. Under the proposed legislation that

maybe a further amendment to the PEPA 1997, the concept of provincial permitting procedures shall

be introduced that will lead to the incorporation of BAT in the environmental permits. Similarly, a

BAT Committee shall be established under IETT including representatives from EPD and industry-

wise experts hired on temporary or permanent basis. These industry specific experts shall also ensure

proper capacity building of EPD staff with regard to the potential techniques/technologies that can be

implemented in the respective industry and how the suggested techniques can lead to desired

reductions. Following the principle of continual improvement, these decisions shall be based on

making the standards and emission reductions stringent over time. As a result of their input coupled

with other stakeholders’ consensus, BAT conclusions shall be developed as an output of BAT

reference documents, containing set of industry specific BAT measures and the associated emission

limit values.



Fig. 4.3: Flow diagram of the development of BAT documents in Punjab

Fig. 4.4: Steps for implementation and enforcement of BAT

A holistic process of BAT implementation is shown in Figure 4.4. As a part of the revised legislation,

the conditions for BAT shall be specified in the permit. Any updates related to BAT such as

incorporation of new techniques shall be linked to the entire permit cycle. As explained in detail in the

monitoring report, on-site inspections shall follow the monitoring/supervision of permit conditions

eventually leading to effective enforcement of the issued permits.

2.5.1. Relation of BAT Conclusions with Punjab Environmental Quality Standards and

Environmental Performance

BAT Conclusions, specifying the associated emission limit values of the desired technology, are

essentially meant to act as a benchmark for level of environmental protection through the application

of the BAT. Environmental improvement is a journey not a stage, so there won’t be a situation where

a certain level of achieved environmental compliance demands to stop the journey. Over time, new



techniques/technologies are meant to evolve owing to increased innovation and competitiveness

globally. Once a certain level of compliance has been achieved, the next target of IETT shall be to

further improve the environmental situation by making the Punjab Environmental Quality Standards

even stringent.

There are 3 possible scenarios of BAT conclusion’s relation with PEQS. As in the current scenario

where there’s no notion about them in the current PEQS, hence new requirements are to be developed

i.e. introduction of BAT conclusions in the permitting system. As explained earlier, the proposed

permitting system takes into account these conclusions.

Once the BAT conclusions have been incorporated in relation with PEQS, the next possible scenario

shall be when these become equal or less demanding than the PEQS. This situation doesn’t require

any change in the standards as the associated emission levels shall be already calculated to be at

harmless degree. In cases where BAT conclusion levels exceed the PEQS, the PEQS need to be

proportional to the BAT conclusions. This relation is not difficult to achieve as the BAT conclusions

shall be updated regularly considering all technical, environmental, energy and economic constraints

so it won’t be impossible to achieve that level of compliance.

In the same-way, the long-term relationship between environmental performance and BAT

conclusions is depicted in Figure. Establishments that have already been assessed by way of EIA shall

implement BAT by rule of the regularly issued permits, incorporating the new concept of BAT after

PEPA-2018. However, any establishment filing for EIA after the PEPA-2018 shall already have

provisions to implement BAT. This shall be reflected in their Environmental Management Plans too.

The management plans are time-bound and may not be valid after a certain number of years, the

sustainability of BAT measures shall be ensured through regularly issued permits. As each of the

upward sloped and downward sloped lines depict in the graph, the achieved level of environmental

performance is bound to improve over time owing to increased stringency of emission limit values in

the permits. On the other hand, the emission levels in the environment shall decrease over time,

creating a win-win situation for the public-private sector and the public.

Fig. 4.5: Relation of BAT conclusion/limit values with PEQS



Fig. 4.6: Relation between effective implementation of BAT under permitting with

environmental performance

In order to enhance the situation of the environment special attention should be given to the

establishment and enforcement of Environmental Quality Standards (EQS). While doing so, the

following points should be considered:

1. Existing Environmental Quality Standards and Emission & Discharge standards, in

Punjab, shall be implemented and enforced upon Industries and major polluters.

2. Environmental Quality standards should be in place to cater to all the components of

environment, including water, wastewater, drinking water, ambient air, stack emissions,

noise, vehicle exhaust, treatment, soil quality, biodiversity etc., and set a basis for thresholds.

3. Introduction of pollution loads for polluters in the Permits issued and NOCs of EIA/IEE

should be made mandatory. A pollution load inventory is also a pre-condition for establishing

Market Based Instruments, especially emission trading, as the loads from all industries will

have to be compiled to set a cap for trade.

4. Continuous improvement should be brought about in the process of design, implementation

and enforcement of EQS, especially where and when they are exceeded. Measures to take into

account would involve:

i. Policies (with future target levels set)

ii. Tightening enforcement

iii. Setting new emission and Discharge standards

iv. Strict permit decisions on pollution loads (through renewed BAT conclusion

emission limit ranges)

v. Review and resetting of EQS



Fig. 4.7: Development of Punjab’s standards with regard to BAT

2.5.2. BAT in Pakistan and export requirements.

Currently, there’s no incorporation of the concept of BAT in any phase of the project, let alone during

permit issuance. Considering the global competitiveness and increased environmental consciousness

in the future state of Pakistan, there might be a demand from associated export regulations. Since

these exports have been a major contributor to the national economy from a long time e.g. to the EU,

it can be a binding on Pakistan to incorporate environmentally viable measures such as BAT in the

production of the exported materials to EU.

Recently, Pakistan’s business community has welcomed the renewal of GSP Plus status for two years

by the European Union in 2018. GSP+ is the EU's trade preference programme for vulnerable

developing countries which allows them to pay fewer or no duties on exports to the EU in return for

improving the implementation of core human and labor rights principles and standards. Through this

program, Pakistan’s exporters could exploit the underlying potential and meet the export target of $35

billion set by the Federal government in the Three year Strategic Trade policy framework 2016-18.47

Likewise, REACH is a European Union regulation (1907/2006/EC) restricting the levels of specific

chemical substances in all imported goods. Registration, Evaluation, Authorization and restriction of

47

Business Community welcomes GSP+ status, https://www.thenews.com.pk/print/285040-business-

community-welcomes-renewal-of-gsp-plus-status

https://www.thenews.com.pk/print/285040-business-community-welcomes-renewal-of-gsp-plus-status

https://www.thenews.com.pk/print/285040-business-community-welcomes-renewal-of-gsp-plus-status



Chemicals (REACH) is one of the most comprehensive and far-reaching pieces of environmental

legislation to come out of the European Union. If Pakistan is exporting certain chemical substances to

the EU above one tonne per year, there may have registration obligations

under EUREACH (Registration, Evaluation, Authorization and Restriction of Chemicals).

The figure below suggests methodology for choosing the BAT as reference in case the export

requirements specify any requirements. The eventual benchmark is going to be the practices,

techniques and/or technologies adopted in EU as a part of their BAT but since this can be difficult in

some cases to go to that level directly, the local BAT shall be implemented in Punjab that at least

ensure that the PEQS levels are not being exceeded.

Fig. 4.8: Choice of BAT for Export requirements

2.6. BEST AVAILABLE TECHNIQUES FOR PUNJAB’S MAJOR INDUSTRIES

Upon discussion with EPD, five of the most polluting sectors in Punjab were shortlisted for the

purpose of proposing a set of Best Available techniques. These techniques keep the EU BAT

references and EU BAT Conclusions (wherever available) as benchmark and can be implemented in

Punjab’s industrial sector by following the methodology suggested in previous section. Input from

Technical experts i.e. BAT Committee shall play a critical role in this regard. The industries

considered for the purposes of this document include:

1. Leather tanneries

2. Textile industry

3. Coal power plant

4. Brick kilns

5. Cement manufacturing



2.6.1. Leather

In an age of plastics, metals and synthetics, leather has managed to sustain its demand as a product of

superior quality. Due to this demand, tanning remains an essential economic activity. Leather

processing can be done at the small-scale or large-scale level, all to varying degrees of sophistication.

General cleaner techniques applications already being implemented globally include green hide and

skin processing, water management, recycling and chromium recovery, hair saving and application of

environmentally friendly chemicals. Special attention is also given to occupational health and safety

(OHS) in tanneries and environmental friendly disposal/application of waste in case of end-of-pipe

approach in CETPs.

A. Best available techniques in Leather tanneries

These BAT have been adopted and reproduced from the EU BAT reference document for Leather

tanneries.48

In raw materials, use of the following practices/chemicals is regarded as BAT:

Green fleshed, preferably in the abattoir

Short-term preserved by chilling, i.e. green – salt-free

If applied, then only environmentally acceptable biocides used

Dried (primarily skins) under well controlled conditions

B. General

Following practices are considered BAT:

Strict water management system (including batch rinsing instead of by continuous flow)

Float recycling both to reduce water consumption and/or improve the uptake of chemicals

Segregation of all chrome-bearing streams

Avoidance and monitoring of banned and/or potentially harmful substances such as

pentachlorophenol (PCP), hexavalent chromium (Cr6+), free formaldehyde and forbidden

aromatic amines

Substitution of all chemicals with strong negative environmental impact, including low

biodegradability (e.g. some complexing agents, halogenated organic compounds, organic

solvents etc) with friendlier alternatives

Use of least potentially environmentally harmful biocides at all stages (curing, soaking,

pickling, tanning, post-tanning)

Avoidance of potentially environmentally harmful surfactants such as nonylphenol

ethoxylates, NPE6, at all stages (soaking, liming, tanning, post-tanning)

Preference for chemicals with low neutral salts content

Highest possible exhaustion level of chemicals used

Monitoring and control of “hidden” presence and/or emissions such as organic solvents

contained in finishing chemicals, volatile organic compound (VOC) releases from leather

during storage

48

EU BAT reference document for Leather tanneries http://eippcb.jrc.ec.europa.eu/reference/BREF/TAN_Published_def.pdf

http://eippcb.jrc.ec.europa.eu/reference/BREF/TAN_Published_def.pdf



Specific targets – ceilings set for pollution loads (biological oxygen demand – BOD, chemical

oxygen demand – COD, suspended solids – SS, total Kjeldahl nitrogen – TKN, TDS etc.)

discharged from the main processing steps (liming, deliming, tanning, retanning etc.)

Specific targets- ceilings set for pollution load (BOD, COD, SS, TKN, TDS etc) contained in

the combined effluent

Specific targets – ceilings set for all hazardous and/or unpleasant air emissions(VOCs)

C. Specific Processing stages

During specific stages in leather processing, following practices are regarded as BAT:

Hair-save unhairing with hair separation and, ultimately, utilization

Splitting of limed pelts (ex-lime splitting)

Desalting of wet salted hides and skins

Highest technically possible accuracy of splitting be it in lime or after (pre)tanning

Low or ammonium salts-free (CO2) deliming

Short pickling floats preferably with recycling

Full scale chrome management of chrome emanating from the main tannage (high chrome

exhaustion, direct recycling of tanning floats, chrome recovery/reuse after precipitation) but

also from all other chrome emissions (retanning, sammying, any “bleeding”)

Vegetable tanning exhaustion rate not less than 95% (counter-current pit and drum tanning

with recycling)

Use of syntans and resins with low-phenol, -formaldehyde and low acrylic acid monomer

content

Optimized mechanical dewatering and forced drying

Environmentally friendly finishing: predominantly water based; avoidance of isocyanates and

aziridines; preference for roller/curtain coating; in case of spraying use of high volume, low

pressure (HVLP) and airless methods

Strict used of abatement techniques (wet scrubbing, absorption, bio-filters) to reduce VOC content as

well as malodour of air emissions.



2.6.2. Textile

The textile sector, with more than 700 industrial units currently running, is one of the most important

industrial sector of Pakistan. Textile and its made-ups account for over 60% of the country’s total

exports, besides catering to the local market demands49

. In addition to other remedial measures to stay

competitive, improvement in resource use efficiency, cleaner technology and better environmental

performance can contribute significantly in supporting the Pakistani textile processing industry.

A. Best Available Techniques in Textile Industry

These BAT have been adopted and reproduced from the EU BAT reference document for Textile

Industry.50

For all activities involved in textile processing, BAT is to do the following as relevant.

B. Management

Install an Environmental Management System

Implement environmental awareness and include it in all training programmes

Produce an annual waste minimisation report showing efforts made to reduce specific

consumption together with material balance and fate of all materials

Apply good practice for maintenance and cleaning

Store each chemical according to the manufacturer’s MSDS

Put in place measures to deal with spillage in the following order

Avoid

Contain

Clean-up

Note: it should be impossible for spillages to enter surface waters or sewer

Implement a monitoring system for process inputs and outputs (site and process level).

C. Generic Prevention Measures

For all textile processing, BAT is to do the following:

i. Dosing

Install automated dosing and dispensing

ii. Selection and use of materials

Where possible avoid the use of chemicals. Where not possible adopt a risk-based approach.

For surfactants, substitute alkylphenol ethoxylates and other hazardous materials

49

JCR-VIS Sector Update: Textile Industry, http://textilelearner.blogspot.com/2015/12/textile-industry-of-

pakistan-overview.html 50

EU BAT reference document for Textile Industry

http://eippcb.jrc.ec.europa.eu/reference/BREF/txt_bref_0703.pdf

http://textilelearner.blogspot.com/2015/12/textile-industry-of-pakistan-overview.html

http://textilelearner.blogspot.com/2015/12/textile-industry-of-pakistan-overview.html

http://eippcb.jrc.ec.europa.eu/reference/BREF/txt_bref_0703.pdf



For complexing agents, avoid their use in pre-treatment and dyeing by

Softening of fresh water

Using a dry process to remove iron particles from the fabric before bleaching

Remove iron from inside fabrics by acid demineralisation or non-hazardous

reductive agents

Apply hydrogen peroxide under optimal controlled conditions

Select biodegradable or bioeliminable complexing agents

For antifoaming agents

Minimise or avoid their use by using bathless airjets or re-using treated bath

Select anti-foaming agents which are free of mineral oils and have high

bioelimination rates.

iii. Selection of incoming raw materials

It is recognised that knowledge of the quality and quantity of substances (e.g. preparation agents,

pesticides, knitting oils) applied on the fibre during the upstream processes is essential to enable the

manufacturer to prevent and control the environmental impact resulting from these substances. BAT

is to seek collaboration with upstream partners in the textile chain in order to create a chain of

environmental responsibility for textiles. It is desirable to exchange information on the type and load

of chemicals that are added and remain on the fibre at each stage of the product’s life cycle. A number

of BAT were identified for different raw materials:

Man-made fibres: BAT is to select material treated with low-emission and biodegradable/

bioeliminable preparation agents

Cotton: the main issues are the presence of hazardous substances such as PCP and the quality

and quantity of sizing agents used (selection of material sized with low add-on techniques and

high-efficiency bioeliminable sizing agents). Preference should be given to organically grown

cotton when market conditions allow.

Wool: emphasis is given to using available information and to encouraging collaboration

initiatives between competent bodies in order to avoid processing wool contaminated with OC

pesticides and minimise at the source any legally used sheep ectoparasiticides. The selection of

wool yarn spun with biodegradable spinning agents instead of formulations based on mineral

oils and/or containing APEO is also part of BAT. All measures assume that the fibre raw

materials for textile processing are produced with some sort of quality assurance scheme, so that

the finisher can get the appropriate information about the types and amounts of contaminants.

iv. Water and energy management

BAT is to:

Monitor water and energy consumption

Install flow control devices and automatic stop valves on continuous machinery

Install automatic controllers for fill volume and temperature in batch machines

Establish well documented work procedures to avoid wastage due to inappropriate work

practices

Optimize production scheduling

Investigate the possibility of combining different treatments into a single step

Install low- and ultra-low- liquor ratio machinery in batch processes

Improve washing efficiency



Re-use cooling water as process water

Investigate possibilities for water re-use and recycling by systematic characterisation of

process streams

Fit hoods and covers to ensure full closure of machinery that could give rise to vapour losses

Insulate pipes, valves, tanks and machines

Optimise boiler houses – e.g. re-use of condensate, etc.

Heat recovery from water and exhaust gases

Install frequency controlled electric motors

D. Generic Management of Waste Streams

BAT is to:

Collect separately unavoidable solid waste

Use bulk or returnable containers

E. BAT – Preventive Measures for Specific Unit Processes and Operations

BAT is presented on a unit process basis, as follows:

i. Wool Scouring

This covers both aqueous and organic wool scouring.

Wool scouring with water

BAT is to:

Select fibre according to BAT measures in Table 5.1 of the BREF document

Substitute alkylphenol ethoxylates detergents with alcohol ethoxylates or other biodegradable

substitutes

Use dirt removal/grease recovery loops of high capacity. BAT associated values for water

consumption are 2 to 4 l/kg of greasy wool for medium to large mills (processing 15,000

tonnes/year of greasy wool) and 6 l/kg for small mills. Recovery of 25%-30% of the grease

estimated to be present in the wool scoured

Reduce energy consumption to 4-4.5 MJ/kg greasy wool processed (3.5 MJ/kg thermal

energy and 1 MJ/kg electrical energy).

Scouring with organic solvent

Scouring with organic solvent is considered BAT if all measures to minimise fugitive losses and

prevent groundwater contamination are taken.

ii. Textile Finishing and Carpet Industry

a) Pretreatment

Removing knitting lubricants from fabric



BAT is one of the following:

Select knitted fabric that has been processed using water soluble and biodegradable

lubricants. Remove them by water washing

Carry out the thermofixation step before washing and treat stenter frame air emissions by dry

electrofiltration with energy recovery and separate oil collection

Remove the non water-soluble oils using organic solvent washing. Describes subsequent

requirements. Persistent pollutants are destroyed in- loop (e.g. by advanced oxidation

processes).

Desizing

BAT is one of the following:

Select raw material processed with low add-on techniques and more effective bioeliminable

sizing agents, combined with efficient washing systems and low F/M waste water treatment

Adopt an oxidative route when it is not possible to control the source of raw material

Combine desizing/scouring and bleaching in one single step

Recover and re-use sizing agents by ultrafiltration

Bleaching

BAT is to:

Use hydrogen peroxide bleaching with techniques to minimise use of hydrogen peroxide

stabilisers (see BREF Section 4.5.6) or using bioeliminable/biodegradable complexing agents

Use sodium chlorite for flax and bast fibres (cannot be bleached with hydrogen peroxide

alone). A two-step hydrogen peroxide – chlorine dioxide bleaching is the preferred option

(ensure elemental chlorine-free chlorine dioxide is used

Limit the use of sodium hypochlorite to cases where high whiteness has to be achieved and to

fragile fabrics.

Mercerising

BAT is to either:

Recover and re-use alkali from mercerising rinse water, or

Re-use the alkali containing effluent in other preparation treatments.

iii. Dyeing

Dosing and dispensing of dye formulations

BAT is to do all the following:

Reduce the number of dyes (e.g. using trichromatic system)

Use automated systems (only consider manual systems for dyes that are used frequently)

In long continuous lines, with high dead volume. Give preference to decentralised automated

stations, with no premixing and automatic cleaning.



General BAT for batch dyeing processes

BAT is to:

Use machinery fitted with automatic controllers of fill volume, temperature, and other cycle

parameters, indirect heating and cooling, hoods and doors (to minimise vapour loss)

Choose machines that are most fitted to the size of the lot to be processed

Select new machinery in accordance with the recommendations in document (e.g. low- or

ultra-low liquor ratio, reduced cycle duration, etc.)

Substitute overflow rinsing with drain and fill or, for fabrics – smart rinsing

Re-use rinse water for the next dyeing and re-use the dyebath where technically feasible.

BAT for continuous dyeing processes

BAT is to reduce losses of concentrated liquor by:

Using low add-on liquor application systems and minimising dip trough volumes when pad

dyeing

Adopting on-line separate stream dispensing systems with mixing immediately prior to

application

Using improved systems for dosing padding liquor

Using counter current washing and reducing carry-over

PES and PES blends dyeing with disperse dyes

BAT is to:

Avoid the use of hazardous carriers

Substitute sodium dithionite in PES after treatment

Use optimised dye formulations containing bioeliminable dispersing agent.

Dyeing with sulphur dyes

BAT is to:

Replace conventional powder and liquid sulphur dyes with stabilised non-pre- reduced

sulphide free dyestuffs or with pre-reduced liquid dye formulations with a sulphur content of

less than 1%

Replace sodium sulphide with sulphur-free reducing agents or sodium dithionite, in that order

of preference

Adopt measures to ensure that only the strict amount of reducing agent needed to reduce

dyestuffs is consumed

Use hydrogen peroxide as preferred oxidant.

Batch dyeing with reactive dyes

BAT is to:



Use high fixation, low-salt reactive dyes

Avoid use of detergents and complexing agents in rinsing and neutralisation steps after

dyeing.

Pad-batch dyeing with reactive dyes

BAT is to:

Use dyeing techniques that perform at a level equivalent BREF

Avoid the use of urea and to use silicate-free fixation methods.

Wool Dyeing

BAT is to:

Substitute chrome dyes with reactive dyes or, where that is not possible, use ultra- low

chroming methods

Ensure minimum discharge of heavy metals to waste water when dyeing wool with metal

complex dyes

Give preference to pH control methods when dyeing with pH-controllable dyes (acid and

basic dyes)

iv. Printing

Process in general

BAT is to:

Reduce printing paste losses in screen dyeing

Reduce water consumption in cleaning operations

Use digital ink-jet printing machines for short runs for flat fabrics. It is not considered BAT to

flush with solvent to prevent blocking while the printer is in use

Use digital jet printing machines for printing carpet and bulky fabrics

Reactive printing

BAT is to avoid the use of urea by either:

The one-step process with controlled moisture addition or

The two-step process

Pigment printing

BAT is to use optimised printing pastes to fulfil the following requirements

Thickeners with low emission of VOC. Emission value: <0.4 g Org.-C/kg textile (assuming

20 m3

air/kg textile)

APEO free and high degree of bioeliminability



Reduced ammonia content. Emission value: 0.6 g NH3/kg textile (assuming 20 m3

air/kg

textile).

v. Finishing

Process in general

BAT is to:

Minimise residual liquor by using minimal application techniques (e.g. foam application)

Minimise energy consumption in stenter frames (see BREF Section 4.8.1 for techniques)

Use low air emission optimised recipes (see BREF Section 4.3.2 for “emission factor

concept”).

Easy care treatment

BAT is to use formaldehyde-free cross-linking agents in the carpet sector, and formaldehyde-free or

formaldehyde-poor (<0.1% formaldehyde content in formulation) for the textile industry.

vi. Mothproofing treatments

Process in general

BAT is to:

Adopt appropriate material handling procedures

Ensure 98% transfer efficiency

When insect repellent is applied from a dye bath, additional measures must be adopted

Specific measures must be adopted depending on the method of mothproofing. BAT is described for

the following operations:

Mothproofing of yarn produced via the dry spinning route

Mothproofing of loose fibre dyed / yarn scoured production

Mothproofing of yarn dyed production

vii. Washing

Washing

BAT is to:

Substitute overflow washing/rinsing with drain-fill methods or smart rinsing

Reduce water and energy consumption in continuous processes by:

Installing high-efficiency washing machinery

Use fully closed-loop equipment when halogenated organic solvent cannot be avoided

F. BAT – Measures for Effluent Treatment



i. General

BAT is:

Treatment of waste in an activated sludge system at low F/M ratio

Pre-treatment of highly loaded (COD> 5000 mg/l) selected and segregated single waste water

streams containing non-biodegradable materials by chemical oxidation.

For specific streams, e.g. wastes containing pigment pastes, azo-dyes. Additional physical-chemical

treatments may be necessary, if concentrated waste- streams containing non-biodegradabe compounds

cannot be treated separately. These include:

Tertiary treatment (e.g. adsorption followed by incineration)

Combined biological, physical, and chemical treatment (e.g. addition of activated carbon to

activated sludge system)

Ozonation of recalcitrant compounds prior to activated sludge treatment.

For Effluent Treatment in the Wool Scouring Sector (Water-Based Process)

BAT is to:

Combine the use of dirt removal/grease recovery loops with evaporative effluent treatment with

integrated incineration of the resulting sludge and full recycling of water and energy for:

New installations

Existing installations with no on-site treatment

Installations seeking to replace life-expired effluent treatment plant.

Sludge Disposal

BAT is to:

Use the sludge for brick-making

Incinerate the sludge with heat recovery (suitable environmental protection measures taken).



2.6.3. COAL POWER PLANTS

Globally, Power plants being built today emit 90% less pollutants (SO2, NOx, particulates and

mercury) than the plants they replace from the 1970s, according the National Energy Technology

Laboratory (NETL). Regulated emissions from coal-based electricity generation have decreased

overall by nearly 40 percent since the 1970s, while coal use has tripled, according to government

statistics. Examples of technologies that are deployed today and continue to be improved upon

include:

Coal cleaning by 'washing' has been standard practice in developed countries for some

time. It reduces emissions of ash and sulfur dioxide when the coal is burned.

Electrostatic precipitators and fabric filters can remove 99% of the fly ash from the flue

gases – these technologies are in widespread use. It removes particulates from emissions

by electrically charging particles and then capturing them on collection plates.

Flue gas desulfurisation reduces the output of sulfur dioxide to the atmosphere by up to

97%, the task depending on the level of sulfur in the coal and the extent of the reduction.

It is widely used where needed in developed countries.

Low-NOx burners allow coal-fired plants to reduce nitrogen oxide emissions by up to

40%. Coupled with re-burning techniques NOx can be reduced 70% and selective

catalytic reduction can clean up 90% of NOx emissions.

Increased efficiency of plant – up to 46% thermal efficiency now (and 50% expected in

future) means that newer plants create less emissions per kWh than older ones.

Ultra-clean coal (UCC) from new processing technologies which reduce ash below

0.25% and sulfur to very low levels mean that pulverised coal might be used as fuel for

very large marine engines, in place of heavy fuel oil. There are at least two UCC

technologies under development. Wastes from UCC are likely to be a problem.

Gasification, including underground coal gasification (UCG) in situ, uses steam and

oxygen to turn the coal into carbon monoxide and hydrogen.

Sequestration refers to disposal of liquid carbon dioxide, once captured, into deep

geological strata.

Fluidized-bed combustion - Limestone and dolomite are added during the combustion

process to mitigate sulfur dioxide formation. There are 170 of these units deployed in

the U.S. and 400 throughout the world.

Integrated Gasification Combined Cycle (IGCC) - Heat and pressure are used to convert

coal into a gas or liquid that can be further refined and used cleanly. The heat energy

from the gas turbine also powers a steam turbine. IGCC has the potential to improve

coal’s fuel efficiency rate to 50 percent. Two IGCC electricity generation plants are in

operation in the U.S.

Flue Gas Desulfurization - Also called “scrubbers,” and removes large quantities of

sulfur, other impurities and particulate matter from emissions to prevent their release

into the atmosphere.

Low Nitrogen Oxide (NOx) Burners - Reduce the creation of NOx, a cause of ground-

level ozone, by restricting oxygen and manipulating the combustion process. Low NOx

burners are now on 75 percent of existing coal power plants.

Selective Catalytic Reduction (SCR) - Achieves NOx reductions of 80-90 percent or

more and is deployed on approximately 30% of U.S. coal plants.



A. Best Available Technology in Coal Power Plants

These BAT have been adopted and reproduced from the EU BAT reference document relevant to

Coal Power plants.51

Minimising the heat loss due to unburned gases and elements in solid wastes and residues from

combustion:

Optimising steam cycle efficiency through achieving the highest possible steam pressure

and temperature and the repeated superheating of the steam.

Minimising cooling water temperature

Reducing energy losses via flue gases through preheating feed water and combustion air

Minimising the heat loss through slag and ashes

Minimising the internal energy consumption by taking appropriate measures (e.g. high

efficiency pumps and fans)

Preheating the boiler feed-water with steam

Use of more efficient turbines with improved blade geometry.

BAT for the control of particulate emissions is the use of electro-static precipitators (ESP) or fabric

filters (FF).

For coal fired combustion plant Flue Gas Desulphurisation (FGD) and the use of low

sulphur fuel are considered to be BAT for the control of SO2 emissions. The use of low

sulphur fuel can be a supplementary technique (particularly for plants over 100 MWth),

but generally is not itself sufficient to reduce SO2 emissions.

BAT for the control of particulate emissions is the use of electro-static precipitators

(ESP) or fabric filters (FF)

BAT for wastewater emissions is to provide storage areas and unloading areas with

appropriate containment and bunding.

B. Minimisation of Emissions to Air – Coal Fired Plant

BAT for the control of particulate emissions is the use of electro-static precipitators (ESP) or fabric

filters (FF).

For coal fired combustion plant Flue Gas Desulphurisation (FGD) and the use of low

sulphur fuel are considered to be BAT for the control of SO2 emissions. The use of low

sulphur fuel can be a supplementary technique (particularly for plants over 100 MWth),

but generally is not itself sufficient to reduce SO2 emissions.

The techniques that are considered to be BAT for pulverised coal fired combustion

plants are: wet scrubbers, spray dry scrubbers and, for smaller applications below

approximately 250 MWth, dry sorbent injection (i.e. dry FGD with an adjacent fabric

filter).

Wet scrubbers also have a high reduction rate for HF and HCl (98 - 99 %). Another

advantage of the wet scrubber is its contribution to the reduction of particulate matter

and heavy metal (such as Hg) emissions. Existing plants that have already installed a

51EU BAT reference document for Large combustion plants

http://eippcb.jrc.ec.europa.eu/reference/BREF/LCP/JRC107769_LCP_bref2017.pdf

http://eippcb.jrc.ec.europa.eu/reference/BREF/LCP/JRC107769_LCP_bref2017.pdf



wet FGD system can reduce SO2 emissions by optimising the flow pattern in the

absorber vessel.

Wet scrubbers are expensive for smaller plants and are not, therefore, considered as

BAT for plants with a capacity of less than 100 MWth. However, unlike other FGD

systems, wet scrubbers produce gypsum, which may be a saleable product, used by the

cement or construction industries.

For Pulverised Combustion, the use of primary measures such as low NOx burners and

Overfire Air (OFA) in conjunction with secondary measures, i.e. Selective Catalytic

reduction (SCR) or Selective Non-Catalytic Reduction (SNCR) is BAT for the control

of NOx.

For fluidised bed combustion, staged combustion and effective combustion control is

considered BAT for NOx abatement.

Effective combustion control is BAT for CO emission control, while limiting NOx and

SOx reduction.



2.6.4. BRICK KILNS

Pakistan is the third largest brick producing country in South Asia, producing more than 45 billion

bricks per year and there are around 18,000 brick kilns across the country. There are 7,966 functional

brick kilns only in Punjab province, according to Labour and Human Resource Department of Punjab.

The country's brick kilns largely rely on traditional or artisan technologies which use low-cost fuels

including coal, local biomass, plastic, waste oil, worn out tires and other materials. The construction

industry, including brick making, has been categorised by the ILO as dangerous and hazardous as the

informality of the sector, lack of regulation and a weak legal and policy environment make workers

particularly vulnerable to abusive, dangerous and harsh working conditions which affect their mental

and physical health and increase their marginalization.

A. Best Available Technology in Brick Kilns

Although there is no BAT reference document Brick Kiln manufacturing in EU as they are mostly

manufactured in the South Asian region, but some of the available techniques that can be employed to

reduce, if not cease the impacts include52

:

Adoption of cleaner kiln technologies (principally zig-zag and Vertical Shaft Brick Kiln)

Promotion of internal fuel in brick making by mechanizing the brick making process

Promotion of mechanized coal stoking systems

Diversifying products (e.g. production of hollow and perforated bricks)

Promotion of modern renewable energy technologies in brick making

Ensuring Occupational Health & safety practices at the manufacturing site

2.6.5. CEMENT

Cement Production in Pakistan increased to 3644 Thousands of Tonnes in January from 3459

Thousands of Tonnes in December of 2017.53

Considering the enormous amount of environmental

impacts the Cement manufacturing has, it is about time the industry is regulated. Incorporation of Best

Available Techniques can play a useful role in this regard.

BEST AVAILABLE TECHNIQUES IN CEMENT MANUFACTURING

These BAT have been adopted and reproduced from the EU BAT reference document for Cement

Production. 54

BAT includes the following practices in cement manufacturing:

Implementing Environmental Management systems in the cement manufacturing

i. Noise

52

Introducing energy efficient Clean technologies in the Brick sector of Bangladesh – Worldbank,

http://siteresources.worldbank.org/BANGLADESHEXTN/Images/295758-1298666789983/7759876-

1323201118313/BDBrickFINAL.pdf 53

Pakistan Cement Production, https://tradingeconomics.com/pakistan/cement-production 54

EU BAT reference document for Cement, Lime & Magnesium Oxide Manufacturing

http://eippcb.jrc.ec.europa.eu/reference/BREF/CLM_Published_def.pdf

http://siteresources.worldbank.org/BANGLADESHEXTN/Images/295758-1298666789983/7759876-1323201118313/BDBrickFINAL.pdf

http://siteresources.worldbank.org/BANGLADESHEXTN/Images/295758-1298666789983/7759876-1323201118313/BDBrickFINAL.pdf

https://tradingeconomics.com/pakistan/cement-production

http://eippcb.jrc.ec.europa.eu/reference/BREF/CLM_Published_def.pdf



In order to reduce/minimize noise missions during the manufacturing processes for cement, BAT is to

use a combination of the following techniques:

Select an appropriate location for noisy operations

Enclose noisy operations/units

Use vibration insulation of operations/units

Use internal and external lining made of impact-absorbent material

Use soundproofed buildings to shelter any noisy operations involving material transformation

equipment

Use noise protection walls and/or natural noise barriers

Use outlet silencers to exhaust stacks

Lag ducts and final blowers which are situated in soundproofed buildings

Close doors and windows of covered areas

Use sound insulation of machine buildings

Use sound insulation of wall breaks, e.g. by installation of a sluice at the entrance point of a

belt conveyor

Install sound absorbers at air outlets, e.g. the clean gas outlet of dedusting units

Reduce flow rates in ducts

Use sound insulation of ducts

Apply the decoupled arrangement of noise sources and potentially resonant components, e.g.

of compressors and ducts

Use silencers for filter fans

Use soundproofed modules for technical devices (e.g. compressors)

Use rubber shields for mills (avoiding the contact of metal against metal)

Construct buildings or growing trees and bushes between the protected area and the noisy

activity

In order to reduce emissions from the kiln and use energy efficiently, BAT is to achieve a smooth and

stable kiln process, operating close to the process parameter set points by using the following

techniques:

Process control optimisation, including computer-based automatic control

Using modern, gravimetric solid fuel feed systems

In order to prevent and/or reduce emissions, BAT is to carry out a careful selection and

control of all substances entering the kiln.

In order to reduce energy consumption, BAT is to use a dry process kiln with multistage

preheating and precalcination.

In order to reduce/minimise thermal energy consumption, BAT is to use a combination of the

following techniques:

Practices/techniques Application

Applying improved and optimised kiln systems

and a smooth and stable kiln process, operating

close to the process parameter set points by

applying: process control optimisation, including

computer- based automatic control systems

Generally applicable. For existing kilns, the

applicability of preheating and

precalcination is subject to the kiln system

configuration



modern, gravimetric solid fuel feed systems

preheating and precalcination to the extent

possible, considering the existing kiln system

configuration

Recovering excess heat from kilns, especially

from their cooling zone. In particular, the kiln

excess heat from the cooling zone (hot air) or

from the preheater can be used for drying raw

materials

Generally applicable in the cement

industry.

Recovery of excess heat from the

cooling zone is applicable when grate

coolers are used.

Limited recovery efficiency can be

achieved on rotary coolers

Applying the appropriate number of cyclone

stages related to the characteristics and

properties of raw material and fuels used

Cyclone preheater stages are applicable

to new plants and major upgrades

Using fuels with characteristics which have a

positive influence on the thermal energy

consumption

The technique is generally applicable to the

cement kilns subject to fuel availability and

for existing kilns subject to the technical

possibilities of injecting the fuel into the

kiln

When replacing conventional fuels by waste

fuels, using optimised and suitable cement

kiln systems for burning wastes

Minimising bypass flows

Generally applicable to all cement kiln

types

In order to reduce primary energy consumption, BAT is to consider reduction of the clinker content of

cement and cement products and cogeneration/combined heat and power plants.

In order to reduce/minimize electrical energy consumption, BAT is to use one or a combination of the

following techniques:

Using power management systems

Using grinding equipment and other electricity-based equipment with high energy efficiency

Using improved monitoring systems

Reducing air leaks into the system

Process control optimization

In order to guarantee the characteristics of the wastes to be used as fuels and/or raw materials in a

cement kiln and reduce emissions, BAT is to apply the following techniques:

Apply quality assurance systems to guarantee the characteristics of wastes and to analyse any

waste that is to be used as raw material and/or fuel in a cement kiln for:

Constant quality

Physical criteria, e.g. Emissions formation, coarseness, reactivity, burnability, calorific

value

Chemical criteria, e.g. Chlorine, sulphur, alkali and phosphate content and relevant

metals content



Control the amount of relevant parameters for any waste that is to be used as raw material

and/or fuel in a cement kiln, such as chlorine, relevant metals (e.g. cadmium, mercury,

thallium), sulphur, total halogen content

Apply quality assurance systems for each waste load

In order to ensure appropriate treatment of the wastes used as fuel and/or raw materials in the kiln,

BAT is to use the following techniques:

Use appropriate points to feed the waste into the kiln in terms of temperature and residence

time depending on kiln design and kiln operation

To feed waste materials containing organic components that can be volatilised before the

calcining zone into the adequately high temperature zones of the kiln system

To operate in such a way that the gas resulting from the co-incineration of waste is raised in a

controlled and homogeneous fashion, even under the most unfavourable conditions, to a

temperature of 850 °C for 2 seconds

To raise the temperature to 1 100 °C, if hazardous waste with a content of more than 1 % of

halogenated organic substances, expressed as chlorine, are co-incinerated

To feed wastes continuously and constantly

Delay or stop co-incinerating waste for operations such as start-ups and/or shutdowns when

appropriate temperatures and residence times cannot be reached, as noted in a) to d) above

In order to reduce channelled dust emissions, BAT is to apply a maintenance management system

which especially addresses the performance of filters applied to dusty operations, other than those

from kiln firing, cooling and main milling processes. Taking this management system into account,

BAT is to use dry flue-gas cleaning with a filter. In order to reduce dust emissions from flue-gases of

kiln firing processes, BAT is to use dry flue-gas cleaning with a filter e.g. electrostatic filters, fabric

filters, hybrid filters etc. In order to reduce the emissions of NOx from the flue-gases of kiln firing

and/or preheating/precalcining processes, BAT is to use one or a combination of the following

techniques:

Flame cooling: Applicable to all types of kilns used for cement manu facturing. The degree

of applicability can be limited by product quality requirements and potential impacts on

process stability

Low NOx burners: Applicable to all rotary kilns, in the main kiln as well as in the precalciner

Mid-kiln firing: Generally applicable to long rotary kilns

Addition of mineralisers to improve the burnability of the raw meal (mineralized clinker):

Generally applicable to rotary kilns subject to final product quality requirements

Process optimization: Generally applicable to all kilns

Staged combustion (conventional or waste fuels), also in combination with a precalciner and

the use of optimised fuel mix: In general, can only be applied in kilns equipped with a

precalciner. Substantial plant modifications are necessary in cyclone preheater systems

without a precalciner.

In kilns without precalciner, lump fuels firing might have a positive effect on NOx reduction

depending on the ability to produce a controlled reduction atmosphere and to control the

related CO emissions



Selective non-catalytic reduction (SNCR): In principle, applicable to rotary cement kilns. The

injection zones vary with the type of kiln process. In long wet and long dry process kilns it

may be difficult to obtain the right temperature and retention time needed.

Selective catalytic reduction(SCR): Applicability is subject to appropriate catalyst and

process development in the cement industry

In order to keep the emissions of TOC from the flue-gases of the kiln firing processes low, BAT is to

avoid feeding raw materials with a high content of volatile organic compounds (VOC) into the kiln

system via the raw material feeding route.

In order prevent/reduce the emissions of HCl from flue-gases of the kiln firing processes, BAT is to

use one or a combination of the following primary techniques:

Using raw materials and fuels with a low chlorine content

Limiting the amount of chlorine content for any waste that is to be used as raw material

and/or fuel in a cement kiln

In order to prevent/reduce the emissions of HF from the flue-gases of the kiln firing processes, BAT is

to use one or a combination of the following primary techniques:

Using raw materials and fuels with a low fluorine content

Limiting the amount of fluorine content for any waste that is to be used as raw material and/or

fuel in a cement kiln

In order to minimize the emissions of metals from the flue-gases of kiln firing processes, BAT is to

use one or a combination of the following techniques:

Selecting fuels with a low content of metals

Using a quality assurance system to guarantee the characteristics of the waste fuels used

Limiting the content of relevant metals in materials, especially mercury

Using one or a combination of dust removal techniques mentioned in BAT references

In order to reduce SO2 emissions from the kiln, BAT is to optimise the raw milling processes. In order

to reduce/minimise the emissions of SOx from the flue-gases of kiln firing and/or

preheating/proclaiming processes, BAT is to use adsorbent addition or wet scrubbers.



Chapter 5

Market Based Instruments

Section 1

Introduction and Overview

Chapter 5 Market Based

Instruments


Chapter 5

Market Based Instruments

Section 1

1.1. OVERVIEW

Polluting firms irrespective of their size, do not take into account the negative externalities that results

from their operation. For instance, a manufacturer in calculating the costs of his production would

include the cost of raw materials, labour, advertising and other such “‘significant and tangible”

expenses but would very conveniently ignore one of the actual cost i-e cost to the environment that

has a trickledown effect and justified on the ground that it is an economic function of the atmosphere

to assimilate such wastes. Continuing to ignore these fundamental costs is a dilemma that our country

is facing right now and that time is near when our people would yearn for a cleaner, fresher air to

breathe in. The very recent phenomenon of Smog that engulfed the major cities of Punjab was an

alarming indicator of a much larger air pollution crisis which is persistent and toxic even when

invisible to the naked eye.

Hence, whether regulators should impose strict standards or provide incentives for Industries has

always been the centre of debate which has ensued between economists, legislators, administrators,

and businessmen. It is the purpose of this report to help uncover this veil, and to lay out the basic

instrument alternatives available to the regulators, for instance EPA.

Hence in order to control pollution, various measures can be adopted. Though Punjab Environmental

Quality Standards for Air exists but their due implementation still remains a challenge. Recently, the

widespread use of MBIs across the globe provides critical lessons in emulating similar policies that

can be implemented in Punjab as well. This is especially true in case of Developing countries like

China, Indonesia, Malaysia, and India since we can relate to these countries to a large extent.

Well-designed policy instruments harness market forces by encouraging firms and individuals to

undertake pollution control efforts to collectively meet policy goals. However, the key lies in their

implementation and monitoring by the regulatory agency. Therefore, no measure whether Command

and Control or Market based instruments can be effective unless EPA strengthens its monitoring and

enforcement capacity. Hence in order to control pollution, various measures can be adopted. Recently,

the widespread use of MBIs across the globe provides critical lessons in emulating similar policies

that can be implemented in Punjab as well. This is especially true in case of Developing countries like

China, Indonesia, Malaysia, and India since we can relate to these countries to a large extent.

1.2. BACKGROUND

The framework for Pakistan’s AQM system dates back to 1993, when the NEQS were developed

under the 1983 Environmental Protection Ordinance. Consultations with major stakeholders were

initiated in April 1996. In December 1999, the Pakistan Environmental Protection Council (PEPC)

approved a revised version of the NEQS, and they became effective in August 2000. The review was

justified by the PEPC because some of the original parameters were more stringent than parameters

for other countries in South Asia.

The cornerstone of environmental legislation is the Pakistan Environmental Protection Act (PEPA),

enacted on December 6, 1997. PEPA provides a comprehensive framework for regulating


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environmental protection, including Air pollution. PEPA established the general conditions,

prohibitions, penalties, and enforcement to prevent and control pollution, and to promote sustainable

development. PEPA delineated the responsibilities of the PEPC, Pak-EPA, and provincial EPAs.

1.2.1. PROVINCIAL EPAs’ MANDATE

After the delegation of functions from the federal government, the mandate of the provincial EPAs

has become more comprehensive. Provincial EPAs have authority to handle the environmental

management of their respective provinces. Their mandate includes implementing rules and regulations

prepared under PEPA 1997 and additional legislation, per the needs of each province; designing,

implementing, and enforcing environmental standards and regulations; and developing provincial

systems for the implementation of pollution charges, among other responsibilities.

1.2.2. INTRODUCTION

In the South Asia Region, Pakistan is ranked as the worst in Air pollution measured as particulate

matter (PM) (measures PM10)55

.Concentrations of noxious particulate matter (PM) in Pakistan are

significantly higher than those found across South Asia. Air pollutants that cause negative health and

environmental impacts include PM, ozone (O3), carbon monoxide (CO), nitrogen oxides (NOx),

sulphur oxides (SOx), and volatile organic compounds (VOCs)

As a consequence, climate change and escalating environmental degradation have become key

constraints to economic growth and sustainable development. Pakistan produces more carbon dioxide

(CO2) emissions per gross domestic product than any of its neighbour countries in the South Asia

region, including the major contributor, India (World Bank 2010)

Pakistan’s largest province i-e Punjab is amongst the most rapidly urbanizing regions in South Asia

with its economy based mainly on agriculture and industrial sector. The province is experiencing a

fast paced social and economic growth however environmental degradation reflects the neglected area

of sustainable development. It is therefore well recognized that the real attainment of sustainable

development is through integration of environmental considerations. The environmental challenges

posing the province comes from all media; whether air, water or land. These challenges highlight the

gap in environmental governance and institutional capacity of the entities responsible for

environmental management and regulation.

Therefore, to achieve sustainable development in urban centres and cities of Punjab has been one of

the biggest challenge. It is unwise to have economic and social development at the cost of

environmental degradation. It is therefore well recognized that the real attainment of sustainable

development is through integration of environmental considerations while achieving the goals of

economic growth and development.56

Environment is broadly categorized into three components; air,

water and land. The brief overview on quality of Air is as under;

1.2.3. AIR

Air pollution in Punjab is getting severe day by day and is significantly damaging human health and

the economy. This is particularly true for large urban centres as it not only damages the populations’

health and quality of life but persistently contributes to environmental degradation57

. From 2007 to

55 Cleaning Pakistan’s Air: Policy Options to Address the Cost of Outdoor Air Pollution, 2014

56 Ibid at 7

57 Sánchez-Triana, et al. 2014. Cleaning Pakistan’s Air: Policy Options to Address the Cost of Outdoor Air

Pollution. Washington, DC, World Bank.


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2011, the reported levels of Particulate Matter (PM), Sulphur Dioxide (SO2), and Lead (Pb) were

many times higher than the World Health Organization (WHO) Air quality guidelines58

.

The continuous increase in emissions in Punjab has devastating effects not just on the current

population but on the generations to come. Sadly, the number of premature deaths and illnesses

caused by air pollution exceeds most other high profile causes of public health problems that receive

significantly more attention in Punjab, including road accidents59

. Over the past several years, thick

smog engulfs major cities of Punjab in November and December. However, the situation has

exasperated over the past 5 years owing to poor quality of air and increasing pollution. Rapid

industrialisation, growing vehicular emissions, tree slashing, coal plant emissions and increased crop

burning across the border has aggravated the situation.

The table below shows Air Quality Standards for some of the parameters of Air. For analysis, a

comparison is drawn with the QS of some of the benchmark countries.

Table 2.1: Ambient Air Quality Standards

58

Gurjar, B. R. et al. 2008. Evaluation of Emissions and Air Quality in Megacities. Atmospheric Environment.

42:1593–606. 59

http://www.who.int/violence_injury_prevention /road_safety_status/ country_profiles/pakistan.pdf.

Sr

No.

Pollutants Time–

Weighted

Average

PEQs

µg/m3

USEPA

µg/m3

India

µg/m3

Malaysia

µg/m3

Nepal

µg/m3

Sri

Lanka

µg/m3

Austr

alia

µg/m3

1.

Sulphur

Dioxide

(SO2)

Annual 80 - 80 - 50 - 50

24 hours 120 200 120 80 70 80 210

2.

Oxides of

Nitrogen as

(NO2)

Annual 40 100 80 - 40 - 56

24 hours 80 - 120 70 80 100 23

3.

Respirable

Particulate

Matter

(PM10)

Annual 120 - 120 40 - 50 -

24 hours 150 150 150 100 120 100 50

4.

Carbon

Monoxide(

CO)

8 hour 5,000 10,000 5,000 10,000 10,000 10,000 10,000

1 hour 10,000 30,000 10,000 30,000 - 30,000 -

Higher than PEQS

Equal to PEQS

Lower than PEQS


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According to Pakistan Clean Air Program (Pcap) and World Bank report of “Cleaning Pakistan’s Air”

below is a table that lists the major sources of Air pollution60

Sr.No Major Sources of Pollution in Punjab61

1. Vehicular Emissions

2. Emissions from Stationary sources( Industries, Power

Plants, brick kilns)

3. Burning of Solid Waste

The number of vehicles in Pakistan have been on the rise jumping from approximately 2 million to

10.6 million over the last 20 years, an average annual growth rate in excess of 8.5%. The number of

motorcycles and scooters grew more than 450% and motor cars, close to 650%62

from 1991 to 2012.

Many of the motorcycles and rickshaws have 2-stroke engines and almost 70% of rickshaws in

Lahore are unregistered63

. The number of vehicles in the province has jumped from approximately 6.6

million to 16.2 million from 2008 to 2016, in just 8 years, an average annual growth rate of about

12% for this period64

. The increase in the number of vehicles results in release in dangerous gases

such as carbon monoxide, oxides of nitrogen (NOx) and hydrocarbons that have grave ramifications.

1.2.4. INDUSTRIAL FACILITIES

Industrial facilities, in particular those using fossil fuels, emit substantial amounts of air pollutants.

Emissions from large-scale facilities in Punjab, such as cement, fertilizer, sugar, steel, and power

plants—several of which use furnace oil that is high in sulfur content are a key contributor to poor air

quality65

. A wide range of small scale to medium-scale industries, including brick kilns, steel re-

rolling, steel recycling, and plastic molding, also contribute significantly to urban air pollution

through their use of “waste” fuels in Punjab, including old tires, paper, wood, and textile waste.

Industrial emissions are further exacerbated by the widespread use of small diesel electric generators

in commercial and residential areas in response to the electricity outages. Industrial emissions are

associated with poor maintenance of boilers and generators66

A variety of nonpoint sources contribute to air pollution in Pakistan, including burning of solid wastes

and sugarcane fields. More than 54,000 tons of solid waste are generated daily in the country, most of

which is either dumped in low-lying areas or burned. The situation is no different in Punjab. The

burning of solid waste at low temperatures produces various dangerous pollutants for instance, carbon

monoxide (CO), PM, and volatile organic compounds (VOCs), including toxic and carcinogenic

pollutants67

. High concentrations of particulate matter of less than 10 microns (PM10) are found in

rural areas in Punjab during sugarcane harvesting. Predominantly dry weather in arid conditions and

strong winds also generate substantial dust in most parts of southern Punjab, elevating PM10 levels in

60

http://environment.gov.pk/images/environmentalissues/PAKISTANCLEANAIRPROGRAMME.pdf,

Air pollution in Punjab(2015) 61

Punjab Clean Air Action Plan,Environmnet Protection Department 62

Cleaning Pakistan’s Air Policy Options to Address the Cost of Outdoor Air Pollution,The World Bank 63

UNEP research conducted in 2015,Air Quality Policies 64

Punjab Clean Air Action Plan,Environmnet Protection Department 65

Ghauri, Lodhi, and Mansha 2007; Khan 2011 66

(Colbeck, Nasir, and Ali 2010a; Ghauri 2010; Ilyas 2007; Khan 2011) 67

Faiz 2011


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the air. Due to extreme summer temperatures (40–50°C), fine dust is transported into the atmosphere

with the rising hot air and forms “dust clouds” and haze over many cities of southern Punjab. Dust

storms are also generated from deserts (Thal, Cholistan, and Thar), particularly during the summer,

and adversely affect air quality in the cities of Punjab68

According to Wold Banks report on Cleaning Pakistan’s Air, PM2.5 SO2, NO2 are the major

pollutants in Lahore. Lahore being a capital city of Punjab with a population of 9,508,00069

so can be

used a good proxy in determining the major pollutants in Punjab. Since Particulate Matter is one of

the major source of pollution in Punjab, it is worthwhile to consider this pollutant in detail below.

1.2.5. PARTICULATE MATTER

Pakistan’s pollution levels are significantly higher than neighboring countries and it can be safely

assumed that Punjab’s escalating population has contributed the most to this phenomenon and

therefore needs to be controlled. For example, PM10 concentration levels in China and India are

almost half of Pakistan .Source apportionment analyses completed in Pakistan (particularly for

Lahore) from 2006 to 2012 have found high concentrations of primary and secondary pollutants,

particularly, fine PM. Elevated levels of PM2.5 at Lahore ranged from 2 to 14 times higher than the

prescribed United States Environmental Protection Agency (USEPA) limits70

.A Positive Matrix

Factorization (PMF) model was performed on short duration analysis results of November 2005 to

March 2006, using. The results from the PMF model indicated that the predominant contributors to

PM2.5 in Lahore are soil/road dust, industrial emissions, vehicular emissions, and secondary

aerosols71

. The Earlier studies also reported similar events causing marked reductions in visibility,

disrupted transportation, and increased injury and death72

. As examples of international best practices,

large metropolises, such as Mexico City, Santiago, and Bangkok have efficiently reduced their

68

(Hussain, Mir, and Afzal 2005). 69

http://worldpopulationreview.com/world-cities/lahore-population/ 70

(Lodhi and others 2009) 71

(Lodhi and others 2009; Quraishi, Schauer, and Zhang 2009) 72

(Hameed and others 2000)

0

50

100

150

200

250

300

350

400

450

500

PM2.5 SO2 NO2 O3 CO

Emis

sio

ns

Pollutants

Emissions PEQS


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ambient concentrations of PM2.5 to a level that is even lower than those of small cities of Punjab such

as Gujranwala.

1.3. NATURE OF EXTERNALITY

There are different types of Pollutants depending on a lot of factors. For instance, Cumulative vs Non-

Cumulative, Local vs Regional and Global Pollutants, Continuous vs Episodic and Point vs Non Point

Sources.

Pollution sources differ in terms of the effort with which actual points of discharge may be

recognized. The points at which sulphur dioxide emissions leave a large power plant are easily

identifiable as they come out the end of the smokestacks associated with each plant. Municipal waste

treatment plants commonly have a single outfall from which all of the wastewater is discharged.

These are called point-source pollutants. There are many pollutants for which there are no well-

defined points of discharge. Agricultural chemicals, for example, usually run off the land in a

distributed or diffused pattern, and even though they may pollute specific streams or underground

aquifers, there is no single pipe or stack from which these chemicals are emitted and hence could be

sourced. This is a nonpoint-source type of pollutant. Like any other place, in Punjab as well it is easier

to establish policies and procedures for point source pollutants because they are easy to monitor and

measure unlike nonpoint-source pollutants.

1.3.1. MAJOR CAUSES AND HEALTH EFFECTS

There are numerous causes of ever increasing Air pollution in Punjab. Of the many reasons highly

inefficient energy use, accelerated growth in vehicle population and vehicle kilometres travelled,

increasing industrial activity without sufficient air emission treatment or control, open burning of

solid waste including plastic, and use of ozone depleting substances (ODSs) are some of the major

causes of deterioration of ambient Air quality in Pakistan

Moreover, Industries tend to agglomerate in a few geographic locations where there is accessibility of

specialized labour, inter-industry spill overs, higher road density, and local transfer of knowledge, and

access to international supplier and buyer networks. These factors essentially explain the clustering of

large-scale manufacturing and high employment levels around the metropolitan areas of Punjab.

While agglomeration economies can generate significant benefits, however they can result in

congestion and air pollution. Given the already severe damages caused by air pollution and the

possibility that environmental conditions might worsen because of growing industrialization and

urbanization, EPD should consider adopting priority interventions in the short term and building the

institutional and technical capacity to adopt additional measures over the medium and long term.

The health effects of poor air Quality are alarming and calls for immediate action on part of EPD and

its related agencies.The severity of the issue and bad air quality levels especially of PM 2.5 reaching

315 micrograms one day are especially alarming.

The health impacts of air, water pollution and productivity losses from deforestation and soil erosion

have been assessed at 1.71 billion dollars, or 3.3 percent of GNP, in the early 90s. The losses

attributed to air pollution, in terms of health care costs, amount to 500 million dollars a year. Amongst

the lists of losses as a result of poor Air Quality, a study using open-top chambers ventilated with

ambient or charcoal filtered air in the vicinity of Lahore, Punjab demonstrated reductions of 42% and

37% in the grain yield of two cultivars of rice (Oryza sativa L.)

By 2005 poor Air Quality resulted in more than 22,600 deaths per year were directly or indirectly

attributable to ambient Air pollution in Pakistan, of which more than 800 are children under five years


Instruments


of age . Outdoor air pollution alone caused more than 80,000 hospital admissions per year, nearly

8,000 cases of chronic bronchitis, and almost 5 million cases of lower respiratory cases among

children under five. It is disappointing and alarming when these numbers are put in perspective, it is

realized that the harm done by air pollution exceeds most other high-profile causes of mortality and

morbidity that receive significantly more consideration in Pakistan, including road accidents, which

resulted in over 5,500 reported fatalities and nearly 13,000 non-fatal injuries in 2007 (WHO 2009)

1.4. CURRENT MEASURES

Environmental protection has long been a concern of the Government of Pakistan. However, the

understanding of environmental issues, their relation with the development and their translation into

action is yet to be approached in a systematic and effective manner. In terms of policies, a landmark

feature was adoption of the National Conservation Strategy (NCS) in 1992 as the guiding

environmental policy for Pakistan. The turn of the century saw considerable progress in

environmental policy making and planning, as well as development of a number of sectoral and sub-

sectoral policies/plans as follows:

Biodiversity Action Plan of Pakistan, 2000

National Action Programme to Combat Desertification in Pakistan, 2002

Poverty Reduction Strategy Paper, 2003

Energy Security Action Plan, 2005

National Energy Conservation Policy, 2006

National Sanitation Policy, 2006

Pakistan Wetland Programme, 2007

National Forest Policy, 2010

National Rangeland Policy (draft)

National Climate Change Policy, 2012

Framework for Implementation of Climate Change Policy, 2013

National Wetland Policy (draft)

After the 18th Amendment, with the devolution of powers to provincial departments, Government of

the Punjab has also drafted numerous environmental related policies which are yet to be approved.

These include;

Punjab Environmental Policy (draft)

Punjab Climate Change Policy (draft)

Punjab Drinking Water Policy (draft)

Punjab Sanitation Policy (draft)

1.4.1. LAWS

With the inclusion of “environmental pollution and ecology” into the Concurrent Legislative List of

the Constitution, the President of Pakistan, promulgated the Pakistan Environmental Protection

Ordinance, 1983 (PEPO) for the control of pollution and preservation of living environment.

Whereas, Parliament passed the Pakistan Environmental Protection Act, 1997 for the protection,

conservation, rehabilitation and improvement of the environment; for the prevention and control of

pollution; and promotion of sustainable development.


Instruments


After the 18th amendment to the Constitution of Pakistan, environmental protection became the

provincial subject. The Government of Punjab enacted Punjab Environmental Protection

(Amendment) Act, 2012 passed by the Punjab Assembly on 18th April 2012.

Currently, there are 2 substantive laws in Punjab;

Punjab Environmental Protection Act, 1997 (Amended 2012)

Punjab Prohibition on Manufacture, Sale, Use and Import of Polythene Bags (Black or any

other Polythene bags below fifteen-micron thickness) Ordinance, 2002

1.4.2. RULES

Since the passage of the Punjab Environmental Protection (Amendment) Act, 2012, the following

rules and regulations set out in chronological order, have been made or issued under powers conferred

to the Provincial Government or Environmental Protection Agency, Punjab;

Punjab Environmental Protection (Tribunal) Rules, 2012

Punjab Environmental Protection (BTS) Regulations, 2012

Punjab Environmental Protection (Motor Vehicle) Rules, 2013

Punjab Environmental Protection Administrative Penalty Rules, 2013

Punjab Hospital Waste Management Rules, 2014

Punjab Bio-safety Rules, 2014

Punjab Environmental Protection Council (Procedure) Rules, 2016

Punjab Environmental Quality Standards (2016) for Drinking Water, Ambient Air, Industrial

Gaseous Emissions, Motor Vehicle Exhaust and Noise, Municipal and Liquid Industrial

Effluents, Noise and Treatment of Liquid and Disposal of Bio-Medical Waste by Incineration,

Autoclaving, Microwaving, and Deep Burial

1.4.3. REGULATIONS

Punjab Environmental Protection (Delegation of Powers for Environmental Approvals) Rules,

2017

Punjab Environmental Protection (Registration of Environmental Consultants), Regulations

2017

Section 31 of the PEPA confers onto the Federal Government the power to make rules, through

publication in the Official Gazette, for carrying out the purposes of the Act, “including rules for

implementing the provisions of the international environmental agreements, specified in the Schedule

to this Act.” Section 32 of the Act confers onto the Federal Government the additional power to

amend the Schedule so as to add any entry thereto or modify or omit any entries therein. This is a

mechanism of implementation of MEAs envisaged under the Act. It is pointed out that the Schedule

to the Act has never be2.5 en amended in exercise of powers conferred under the Act. Punjab

Biosafety Rules, 2014, issued by the Government of Punjab in exercise of powers to make rules

conferred by Section 31 of the Act. These rules are identical to the Pakistan Biosafety Rules, 2005

but with the substitution of “Punjab” for “Pakistan” etc. However, these two Rules overlap with one

another and are an example of the legal and institutional overlaps that can occur without proper

coordination between the Federation and the Provinces on the implementation of MEAs.

1.4.4. STRATEGIES

The National Conservation Strategy (NCS, 1992)


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Preventing and abating pollution, increasing energy efficiency, and management of urban wastes are

among the 14 core program areas of the NCS. With regard to air pollution control, specifically, the

NCS emphasizes energy conservation in industry and transport, site industries appropriately to

minimize pollution impacts, and introduce clean fuels, upgrade refineries, set up vehicles tune-up

stations and compressed natural gas (CNG) stations. Brick kiln conversion, energy conservation,

networks of meteorological stations, atmospheric environmental services and monitoring are some of

the proposed initiatives.

The National Environmental Action Plan (Neap)

In the meeting of Pakistan Environmental Protection Council (PEPC, 2001) in February 2001, the

council approved a National Environmental Action Plan (NEAP) developed by the Ministry of

Environment, Local Government and Rural Development. The plan reflects a renewed commitment to

the environment and focuses on taking immediate measures in four priority areas of concern –air,

water, solid waste, and ECO system management – to achieve a visible improvement in the quality of

air, water and land. The program for the control of vehicular pollution, industrial emission and indoor

air pollution would be developed by the federal EPA, in which a special Program Unit for clean air

has already been established.

1.4.5. INTERNATIONAL CONVENTIONS AND TREATIES

Pakistan has signed the following international treaties pertaining to air emissions:

United Nations Framework Convention on Climate Change, 1992

Vienna Convention for the Protection of the Ozone Layer, 1985

Montreal Protocol on Substances that Deplete the Ozone Layer, Montreal, 1987 and

amendments

Stockholm Convention on Persistent Organic Pollutants (POPs), 2001

1.5. SUCCESS & FAILURES

Although a plethora of rules, regulations, strategies, signed international conventions exist for Punjab

however the issues of escalating environmental concerns have been on the rise. Although recent

projects like Fuel Efficiency in Road Transport Sector project (FERTS), Introduction of Alternative

Fuels, CNG, Establishment of Cleaner Production Centres (CPCs) and Revised and more realistic

Provincial Environmental Quality Standards (PEQS) are there but all these efforts are constrained

and limited broadly due to poor or absence of monitoring , lack of implementation and political will.

Though Punjab is now improving upon its resources and institutions with EPD being quite active in

certain areas however a lot needs to be done to be at par with similar relatively cleaner countries.

The lack of formal monitoring system in Punjab as mentioned above, exacerbates the problem.

Lahore’s PM levels have been up to 6.8 times higher than required. Recent efforts include physically

collecting particles to find out the exact source and weight, appointing new Air pointers and asking

LWMC to wash around 10km of road every day and sealing of polluting factories. Environment

Protection Department has recently successfully negotiated about US$ 200 million soft loan for

Greening of the Punjab many other similar contributions. However, institutional strengthening is

critical to improve environment.

Current trends, including industrialization and urbanization, suggest that air quality in Punjab will

worsen over time unless targeted interventions are adopted in the short, medium, and long term, and


Instruments


Price Based (Setting prices on

ecosystem services)

Quantity Based (setting targets

to maintain ecosystem services)

Market Friction (Removing

obstacles to the formation or

growth of ecosystem market

Government regulation

Moral persuasion

Education

the institutional and technical capacity of organizations responsible for air quality management

(AQM) is strengthened (World Bank report)

The action plan calls for collective role of 15 department/agencies including Federal Agencies,

Agriculture, Health, Traffic police, Local Govt etc. Technology up gradation, building on regulatory

capacity, crop residuals and dealing with vehicles (compliance with Euro II standards and installation

of pollution control devices).

1.6. TYPE OF EMISSION CONTROL MECHANISM

To correct for these externalities problems explained above, there are two types of broad policy

instruments to alter behaviour to abate pollution for desirable outcome that are deployed at varying

degrees across the globe:

Command and Control Measures: These consist of mandatory standards and norms on

environment quality that are imposed by the regulatory agencies.

Market-Based Instruments: These act in free markets to establish price of pollutants and

distinguish themselves through their tradability and incentive structure.

Historically the objective of controlling pollution has been targeted by the implementation of

Command and Control (CAC) approach. Not only their effective implementation still remains

a big challenge in Pakistan but the second set of instruments are more efficient.73

Typology of instruments 74

1.7. COMMAND AND CONTROL POLICIES

Command-and-control approach (CAC) mandates the industries and/or people, by enacting a law, to

bring about a behavior and use an enforcement machinery to get people to obey the law. A standard is

generally the tool used in the CAC approach, which is a mandated level of performance enforced

73

Sawhney, A. (1997, March & april). A review of Market Based Instruments for Pollution

Control:Implicatuons for India. Retrieved from http://www.citationmachine.net/apa/cite-a-website/manual 74

Sarker et al.(2008)

Market-Based (MBIs) Non Market-Based (MBIs)

Instruments


Instruments


through legislation. The CAC approach basically involves the

setting of these standards to protect or improve environmental

quality and public health.

Industrial emission standards form an integral part in air

pollution control. Standards are designed to tackle the

environmental impacts of harmful emissions from industries by

setting legal requirements for acceptable concentrations of

pollutants within the exhaust gases emitted from stacks, and

also within the ambient air. Any modification in these standards

can result in changes to the ambient concentrations of pollutants

in the areas surrounding the facilities and play a key role in the

protection of human and ecological health.

The process for development of such standards is more or less

similar to any policy reform. The stakeholders must include

industry practitioners and relevant business

associations/chambers of commerce as well as all broad-based

stakeholders including people, non-governmental organizations,

not-for-profit bodies, international consultants and any other

stakeholders that may or may not have direct stakes involved in

the emission standard setting process.

1.7.1. AMBIENT STANDARDS

Ambient standards are never-exceed levels for pollutants,

measured in the ambient environment. They reflect the

qualitative dimensions of the surrounding environment and

could be anything from the ‘ambient’ quality of air in a certain

region or the ambient quality of water in a certain body. The

Punjab Environmental Quality Standards (PEQS) identify these

limitations in the form of concentrations in the ambient air over

time-weighted average, along with their method of measurement. For example, the concentrations of

Ozone (O3) measured over time-weighted average of 1 hour by Non-dispersive UV absorption method

cannot exceed 130 g/m3. It might not be possible to enforce ambient standards directly, as to who is

to be blamed in case of non-compliance of concentration level but various emissions that lead to those

ambient quality levels can be enforced. To ensure that ozone levels don’t go beyond 130 g/m3 in the

ambient air, its relation to emissions of various sources in the atmosphere should be identified. This

will eventually contribute in introducing different ways to control all or most intense of the specific

sources.

1.7.2. EMISSION STANDARDS

Like ambient standards, Emission standards are also never-exceed levels, but these are applied

directly to the quantities of emissions coming from pollution sources. Emission standards are

sometimes also referred to as ‘performance standards’ as they

target the end results to be achieved by the polluters that are

regulated.

Continuous emission streams such as industrial stacks may be subject to standards on instantaneous

rates of flow; limiting the quantity of residuals flow per minute or on the average residuals flow over

Fig. 2.1: A conventional standard setting

process


Instruments


given time period. With regard to their relationship with ambient standards, setting emission standards

at a certain level does not necessarily lead to compliance with ambient standards. Meteorological and

hydrological phenomenon play an active role in linking these two quality standards as well.

The link between emissions and ambient quality also can be impacted by human decisions. An

example in this case is that of automobiles in Punjab. Even if the emission standards have been set for

new cards in terms of emissions per miles driven, the aggregate quantity of pollutants in the car i.e.

ambient air quality might not be directly controlled as currently there is no effective way of

controlling the number of cars on the roads or total number of miles each is driven.

1.7.3. TECHNOLOGY STANDARDS

Standards like these aim at specifying technologies, techniques or practices to be adopted, rather than

the end results/concentrations. These standards specify the technologies or practices, including design,

engineering, input and output standards that polluters must adopt or meet to protect the environment.

In contrast to emission standards, technology standards impose on polluters certain decisions and

technologies to be used.

Requirements like installation of industrial stack-gas scrubbers to reduce SO2 emissions or simply

putting catalytic converters in vehicles come under technology standards. A concept that has caught

attention with respect to industrial emissions is that of Best Available Techniques/Technologies

(BAT) where set of techniques, including technologies, are suggested to industries considering the

environmental impacts, energy impacts, expected emissions rate and emission reduction as a result of

adopting them. Under the proposed future state, Punjab Environmental Technical Institute (PETI)

shall be responsible for suggesting and incorporating BAT as a part of permit approval process.

1.7.4. COST-EFFECTIVENESS OF STANDARDS

Currently, the concept of Ambient and Emission standards is already incorporated in the Punjab

Environmental Quality Standards (PEQS) to an extent but there is no formal clause on Technology

standards, as such. A vital consideration to be held true while setting the standards in future is that of

the equimarginal principle. The principle states that in order to get the greatest reductions in total

emissions for a given total abatement cost, the different sources of emissions must be controlled in

such a way that they have the same marginal abatement costs. The marginal abatement cost is the cost

of reducing one more unit of pollution. This might not hold true in the case of command & control

approach as there shall be different abatement costs, leading to inefficient allocation of cleanup

burden among different industries.

Authorities, like EPD, usually tend to apply the same level of pollution reduction through standards as

it makes their regulatory monitoring much simpler, and also gives the impression of being fair to

everyone because all are apparently being treated alike. But following the equimarginal principle,

identical standards shall only be cost-effective only in the unlikely event that all polluters have the

same marginal abatement costs. For example, let’s suppose industry A and industry B are releasing

100 units and 40 units of pollutants respectively. At this situation, the total emission units in the

environment are 100+40=140 units and considering a case where the regulating authority targets to

bring the emission units in the environment to 100 units, each industry shall have to reduce their

emissions by 40/2=20 units. Following this conventional approach of standards, industry A will have

to reduce their emissions to be 80 units and industry B will have to reach 20 units. This approach is

not cost-effective because the firms shall have unequal abatement costs and therefore, inefficient

allocation of cleanup burden. This approach can be made cost-effective if the marginal abatement

costs of each firm is calculated as a result of application of the standards but practically speaking, this


Instruments


is a data-intensive process requiring a lot of work beforehand and difficult in most cases, like that of

Punjab.

However, in the case of emission taxes, a trial and error approach can be implemented for setting up a

marginal abatement cost. The essence of the tax approach is to provide an incentive for the polluters

themselves to find the best way to reduce emissions, rather than having a central authority determine

how it should be done. Polluters will minimize their total private costs by reducing emissions until the

tax rate equals their marginal abatement cost. The imposition of an emission tax will automatically

satisfy the equimarginal principle because all polluters will set the tax equal to their MAC curve.

MACs will be equalized across all sources.

Section 2

Types of Market Based Instruments

Chapter 5 Market Based Instruments


Section 2 Briefly,

Market-Based Instruments (MBI) are aspects of policy that encourage behaviour through market

signals, rather than through explicit directives regarding pollution control levels or methods.

On the basis of the review of the present regulatory framework, there is no design of or any effective

economic instrument operational in the EPA regime in Punjab. So, there is a dire need to introduce

some economic instruments which are designed to create appropriate patterns of incentives or

disincentives for economic agent to behave accordingly. It should also be noted that incentives or

disincentives indeed work best in a package approach, which combined with more stringent policy

instruments.

2.1. TYPES OF MARKET BASED INSTRUMENTS

Market-Based Instruments (MBI) are aspects of policy that encourage behaviour through market

signals, rather than through explicit directives regarding pollution control levels or methods.75

On the basis of the review of the present regulatory framework, there is no design of or any effective

economic instrument operational in the EPA regime in Punjab. So, there is a dire need to introduce

some economic instruments which are designed to create appropriate patterns of incentives or

disincentives for economic agent to behave accordingly. It should also be noted that incentives or

disincentives indeed work best in a package approach, which combined with more stringent policy

instruments.

The direct instruments are applied on the pollutants directly and indirect instruments are applied on

the goods that create pollution.

75

Stavins.(2001, November).Experience with Market Based Environmental Policy Instruments

Pollution Charge Tradable Permits Deposit Refund

System Product Charge

and Tax Subsidy

Administrative Charge

Policy Tool Classification Details Relevance for Punjab

Pollution

Charge

Direct

Instrument

These are emission and

effluence charges and fees

levied by authority based on

quality and quantity of

pollutants discharged in

environment. These charges

alter pricing and encourage

pollution abatement. Challenge

is to identify optimal tax rate.

• Emission charges

• Effluent charges

Pollution charges can only be

levied if the EPA has the

capacity and capability to

monitor data e.g. the

measurable impact of different

industries on the

environmental. Currently

there is no steady revenue

stream from pollution charges



• Solid waste charges

• Sewage charges

Tradable Permit Direct

Instrument

The authority establishes

allowable overall level of

pollution and allocate among

firms in the form of permits.

Firms that keep their emission

level below may sell the excess

emissions.

• Emissions

• Effluents

• Fisheries access

Extensive data is required for

initial allocations of permits

including a state of the

environment report, and

expertise on how best to

divide the total pollution

between companies/firms.

Enforcement and compliance

can be complex, however this

can generate a further stream

of revenue to spend on

environmental issues in the

form of fees from permits and

fees when two companies

trade between themselves.

Deposit Refund

System

Direct

Instrument

Consumers pay a fee when

purchasing potentially

polluting products and deposit

is refunded when product is

returned for recycling or

disposal.

• Lead-acid batteries

• Beverage containers

• Automobile bodies

This sort of initiative will

require a mass level

informational awareness

campaign to promote

participation at household

level in Punjab. A parallel

collection and payment

mechanism will also be

required.

Collection and Payment

mechanisms can be set by

EPA Punjab. Consumers will

pay the fee to the relevant

authority decided by EPA

which will later be refunded

upon return of the product.

Product Charge Indirect

Instrument

Fees are either added to price

of product or inputs that cause

pollution in either

manufacturing or consumption

phase. These are levied to alter

consumption towards cleaner

goods. These are similar to the

direct emission fees, however

taxes are indirect instruments.

Because taxes do not require

the regulator to determine an

abatement level, they are easier

to implement.

EPA Punjab will need to set

up rules and a compliance

mechanism that have

enforceability powers, as

differential taxation is used to

promote consumption of

environmentally funded

products



2.2. POLLUTION CHARGE

Pollution charge/Taxes have been promoted in recent years as part of a proposed rigorous

international effort to combat global climate change. It is widely believed that if adopted, such taxes

would represent a flexible, reversible and lower cost alternative to regulatory responses. However,

both the need for and the mechanics of such taxes remain unsettled issues.

When taxes are imposed, firms are required to pay a certain charge for every unit of their emissions

they discharge. The rationale behind this is essentially that firms should pay for the services of the

environment—transportation, dilution, chemical decomposition, and so on just as they must pay for

all other inputs used in their operations. By giving the polluters liberty in determining how best to

reduce emissions for instance any combination of treatment, internal process changes, changes in

inputs, recycling, shifts to less polluting outputs, and so on, this type of policy attempts to couple their

own energy and creativity and their desire to minimize costs.

Taxes are enforced under the “Polluter Pays Principle” that the one who is polluting should also

pay. The PPP asks for a general framework for internalising environmental externalities and assigns

responsibility for addressing pollution to the polluter. This principle requires that the polluter should

compensate for pollution impacts .In this way if the costs are “internalised” this will reflect the true

actual price and output of goods and services. This way companies are encouraged to find alternative

manufacturing processes that create less pollution.

For implementation of the tax in Punjab, EPD can set a level of tax and if it doesn’t achieve their

target, the tax level can be readjusted. Infact, there is already a provision in the law about the tax:

• Leaded gasoline tax

• Carbon tax

• Fertilizer tax

• Pesticide tax

• Virgin material tax

• Water user charges

• Chlorofluorocarbon taxes

Subsidy Indirect

Instrument

Subsidies (incentives) are

given to induce reductions in

pollution. Among the subsidies

that may be used to help

manage environmental

pollution are grants, low-

interest loans, favourable tax

treatment, and preferential

procurement policies for

products believed to pose

relatively low environmental

risks.

• Municipal sewage plants

• Land use by farmers

• Industrial pollution

• Equipment purchases

EPA can grant subsidies for

electricity produced by

windmills, as well as refuse

disposal, forestry, production

of a cleaner substitute(clean

diesel vs. the standard type)

Although this is a good idea,

it required fiscal support and

generation to fund such an

activity.



PEPA(2012) S6(2)(d) : recommend to the [Government] the adoption of financial and fiscal

programmes, schemes or measures for achieving environmental objectives and goals and the purposes

of this Act, including:

i. incentives, prizes awards, subsidies, tax exemptions, rebates and depreciation

allowances; and

ii. taxes, duties, cesses and other levies;

The mechanics behind the tax regime is that if the same tax rate is applied to different sources with

different marginal abatement cost functions, and each source reduces its emissions until its marginal

abatement costs equal the tax, then marginal abatement costs will automatically be equalized across

all the sources. This is explained by the graph below.

Emissions

(Tons/month)

Marginal

Abatement cost

Total

Abatement cost

Total Tax bill at

1500 Rs per ton Total cost (Rs)

10 0 0 15,000 15,000

9 150 150 13,500 13,650

8 300 450 12,000 12,450

7 500 950 10,500 11,450

6 750 1700 9,000 10,700

5 900 2,600 7,500 10,100

4 1300 3,900 6,000 9,900

3 1500 5,300 4,500 9,800

2 1850 7,150 3,000 10,150

1 2300 9,450 1500 10,950

0 3000 12,450 0 12,450

Hypothetically, the tax has been set at Rs1500/ton/month. The minimum total cost of Rs 9, 800 occurs

at an emission rate of 3 tons/month. Suppose one firm is initially emitting 10 tons/month. If it does

0

500

1000

1500

2000

2500

3000

3500

0 1 2 3 4 5 6 7 8 9 10

Mar

gin

al A

bat

em

en

t co

st

Emissions(Tons/month)



not reduce emissions, the firm’s tax, or payment for using the environment, is Rs 15,000. The firm has

an incentive to reduce emissions. If it were to cut emissions to 9 tons, it would cost 150 in abatement

costs, but it would save 1,350 in total tax bill, clearly a good move because total costs drop to Rs

13,650. Following this logic, it could improve its bottom line by continuing to reduce emissions as

long as the tax rate is above marginal abatement costs. The rule for the firm to follow is to reduce

emissions until marginal abatement costs are equal to the charge on emissions. The charge of Rs1500

leads the firm to reduce emissions to exactly 3 tons/month. After the firm has reduced its emissions to

3 tons/month, its total (monthly) tax bill will be 4,500. Its monthly abatement costs will be 5,300.

Graphically, total abatement costs correspond to the area under the marginal abatement cost function.

The total tax bill is equal to emissions times the tax rate. Under a charge system of this type, a firm’s

total cost equals its abatement costs plus the tax payments to the taxing authority.

It’s advantageous to implement a tax as if the firm stayed at 10 tons of emissions, its total outlay

would be Rs1, 500/month, consisting entirely of tax payment. This is much higher than the Rs 9,800 it

can achieve by cutting back to 3 tons/month. The assumption in an emissions charge program is that

competitive pressures will lead firms to do whatever they can to minimize their costs. Thus, when

there is competition in the industry subject to the emission tax, it will lead firms to reduce emissions

in response to the tax and would be least costly as explained above.

2.3. TRADING PERMIT

Emissions trading is a government-mandated, market-based approach to controlling pollution by

providing economic incentives for achieving reductions in the emissions of pollutants. These schemes

are flexible as it allows businesses to decide how best to meet policy targets. A central authority

allocates or sells a limited number of permits to discharge specific quantities of a specific pollutant

per time period. Polluters are required to hold permits in amount equal to their emissions. Polluters

that want to increase their emissions must buy permits from others willing to sell them.

In theory, polluters who can reduce emissions most cheaply will do so, achieving the emission

reduction at the lowest cost to society. There are active trading programs in several air pollutants. For

greenhouse gases, which cause climate change, permit units are often called carbon credits.

For the initial understanding of how a Trading Permit system works, below mentioned is a case study

on Sahiwal’s Coal power plant

2.3.1. CASE STUDY

Sahiwal’s coal power plant was taken as an example to illustrate the trading dynamics, aimed at

calculation of NOx value/units. According to PEQS, the tonnes of NOx allowed is 25544.75

(calculations shown below) and the power plant is emitting 8514.8 tonnes of NOx.76

.It is clear that

Sahiwal’s power plant is within the target set and has the option to sell the excess permits available.

The excess tonnes available are 17030 and since each allowance gives the holder the right to emit one

tonne of NOx but we have kept a margin of 10% so the number of permits available to offer are

15327. Auctioning will be used as an allocation method. The industry can sell the Permit at a certain

rate, $120 per tonne77

to the highest bidder. This price is for NOx as rates will vary depending on the

gas for which the permit is issued. For instance, in Australia the research firm Reputex was reported

in late November 2012 as expecting Australian carbon permits to average $A16 in the years leading

up to 2020 but by the end of April 2013 Reputex had reported an expected Australian permit price

76

EIA Report of Coal Fired Power Plant near Sahiwal (March 2014) 77

https://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0216B-07.pdf/$file/EE-0216B-07.pdf

https://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0216B-07.pdf/$file/EE-0216B-07.pdf



average of $A2.70 over the period 2015–202078

EPA Punjab will take 10% commission from the

proceeds of the sale of permits to the industry in need.

a. Yearly Release of Pollutants in Tonnes79

1. Calculate the stack's volumetric gas flow rate () using the formula:

2. Correct the stack gas flow rate for the moisture content and standard conditions using

the

formula:

3. Convert from ppm (volume) to mass emission rate (kg/h) as follows:

4. Calculate the yearly release:

The calculations have been summarised in the following table

78

Reputex, ‘Price of renewable energy credits to soar’, 4 December 2012, accessed 20 March 2013; N Perry, ‘Business says

end carbon tax, bring in ETS’, Herald Sun, 18 April 2013, accessed 30 April 2013 79

Canadian government’s methodology for reporting pollutant releases, https://www.canada.ca/en/environment-

climate-change/services/national-pollutant-release-inventory/publications/reporting-example-

calculations/chapter-6.html

PEQS of

NOx

(mg/Nm3)

Tonnes

of NOx

allowed

Emission

of NOx

(tonnes)

1200 25544.75 8514.8

Excess/Deficit 17030

$Rate/tonne 120

Number of

Permits issued

(10%)

15,327

Proceeds from

sale of

permits for

1,839,240

𝐷𝑟𝑦 𝑉𝑚3

𝑚𝑖𝑛= 𝑉

𝑚3

𝑚𝑖𝑛×

(273.15 𝐾)

𝑇 𝑎𝑐𝑡𝑢𝑎𝑙×

𝑃 𝑎𝑐𝑡𝑢𝑎𝑙

1 𝑎𝑡𝑚

× (1

− 𝑓𝑟𝑎𝑐𝑡𝑖𝑜𝑛 𝑤𝑎𝑡𝑒𝑟 𝑣𝑎𝑝𝑜𝑟)

𝑀𝑎𝑠𝑠 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑅𝑎𝑡𝑒𝑘𝑔

ℎ

= 𝑝𝑝𝑚 × 𝑑𝑒𝑛𝑠𝑖𝑡𝑦 𝑜𝑓 𝑎𝑖𝑟 𝑎𝑡 𝑠𝑡𝑑 𝑐𝑜𝑛𝑑𝑖𝑡𝑖𝑜𝑛𝑠 × 60𝑚𝑖𝑛

ℎ×

𝑀𝑊

𝑀𝑊 𝑎𝑖𝑟

𝑌𝑒𝑎𝑟𝑙𝑦 𝑅𝑒𝑙𝑒𝑎𝑠𝑒

= 𝑀𝑎𝑠𝑠 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑅𝑎𝑡𝑒 ×𝐻𝑜𝑢𝑟𝑠

𝑦𝑒𝑎𝑟

𝑉 𝑚

3

𝑚𝑖𝑛= 𝑔𝑎𝑠 𝑣𝑒𝑙𝑜𝑐𝑖𝑡𝑦

𝑚

𝑠× 𝜋 ×

(𝑖𝑛𝑡𝑒𝑟𝑛𝑎𝑙 𝑠𝑡𝑎𝑐𝑘 𝑑𝑖𝑎𝑚𝑒𝑡𝑒𝑟)2

4× 60

𝑠

𝑚𝑖𝑛

http://www.sustainabilitymatters.net.au/news/57572-Price-of-renewable-energy-credits-to-soar

http://www.heraldsun.com.au/news/breaking-news/aust-carbon-price-could-fall-to-3-report/story-e6frf7kf-1226623635331

http://www.heraldsun.com.au/news/breaking-news/aust-carbon-price-could-fall-to-3-report/story-e6frf7kf-1226623635331

https://www.canada.ca/en/environment-climate-change/services/national-pollutant-release-inventory/publications/reporting-example-calculations/chapter-6.html





The industry who’s buying the permits will then do a cost benefit analysis, analysing what is less

costly. For instance if any industry is falling short of 5000 tonnes according to the target defined then

they can either reduce their emissions by 5,000 tonnes, or purchase 5,000 Permits in the market. In

order to decide which option to pursue, they will compare the costs of reducing their emissions by

5,000 tonnes by adopting cleaner technology or buy permits. Industries will then opt for the least

costly option.

2.4. DEPOSIT-REFUND SYSTEM

Under this approach, consumers pay an extra charge when buying a potentially polluting product.

However, their deposit is refunded when they return it to an approved centre for recycling or proper

disposal. This instrument is applied to products that are either durable or reusable or not consumed or

dissipated during consumption, such as drink containers, automobile batteries and pesticide

containers.

Beverage container recycling programmes are one of the most prevalent forms of deposit refund

system which include the collection of a monetary deposit on reusable packaging of beverages at the

point of sale, combined with a refund being paid out when the empty containers are being delivered

back to selected collection points. Similar systems are also in place for car hulks as well as for waste

oil. This means that one can get a refund for delivering used lubricating oil to selected collection

points.

There are a lot of factors which needs to be considered before establishing a successful deposit-refund

system in Punjab. Firstly, it requires products that are easy to identify and handle and users and

consumers that are able and willing to take part in the scheme. On part of EPA, it might also require

new organisational arrangements for handling the collection and recycling of products and substances

as well as for managing the financial arrangements. As most of the management responsibility

remains with the private sector and incentives are in place for third parties to establish return services

when users do not participate is a big advantage of deposit-refund systems. This system aims to lessen

the amount of waste going to landfills, encourage recycling, and prevent the incorrect handling of

waste. They reward good behaviour and often cover the costs of environmentally-sound waste

disposal. However, a major drawback of this approach is that the costs of managing deposit-refund

programmes, i.e. administrative, collection, recycling, and disposal expenditures, fall to the private

sector.

In Australia, currently, all states except Victoria and Tasmania have some sort of state-based

container deposit scheme operating. The scheme has different payments against each type of bottle in

Belgium, Denmark, Croatia, Czech Republic, Finland, Hungary, Iceland, Norway, Sweden,

Switzerland, and United Kingdom. Canadian provinces and two of the territories have their own

deposit refund systems and no national scheme. In Estonia there is a universal deposit and recycling

system since 2005 for one-time and refillable containers. By 2012, 90% of all PET bottles, 63% of all

aluminium cans and 86% of all glass bottles sold in Estonia were returned into the deposit and

recycling system. United States container-deposit laws are popularly called "bottle bills" after the

industry

EPA’s

commission

(10%)

183,924



Oregon Bottle Bill, the first container deposit legislation passed. There are efforts to pass container

deposit legislation in the remaining 39 states that do not have them.

In Germany container deposit legislation, passed in 2002 and was implemented on January 1,

2003.The standard deposit for all single-use containers (Cans, single-use glass and plastic bottles) is

EUR 0.25.Since they are the private business of the individual beverage manufacturer so the deposits

for reusable bottles are not regulated by law and can therefore vary in rate. Additional revenues from

deposit-charged containers for retailers are estimated to be EUR 50 million per month. However, the

implementation costs are estimated by the German Environment Ministry’s to be EUR 1 billion and

running costs an additional EUR 135 million per annum (Reported in January 2003).

Pakistan is the second largest market of plastic materials in South Asia after India but local production

of polymer resins is limited to less than 150,000 tonnes. Lately the use of polymer resins in

manufacturing of PET bottles, cans and crates has increased as farmers are shifting from wooden and

straw baskets to plastic crates for vegetables and fruits picking and transportation to markets. PET

bottles are also being increasingly used in packaging of fruit juices, beverages and water.

The container deposit legislation may be early to enforce considering the fact that the consumer

industry is at an early stage in Pakistan and implanting the legislation at Punjab level would require a

huge outlay and initial budgetary commitments. In the supply chain of waste and materials, it would

be better to first deal with bulk waste and then move forward vertically up the chain.

2.5. PRODUCT CHARGE

These charges can be applied to products that have a tendency to pollute surface water or ground

waters before, during, or after consumption. They are critical for products that are consumed or used

in large quantities and in diffuse patterns (e.g. fertilisers, pesticides, lubricant oils). Tax differentiation

is a special type of product charge. Product price differentials can be applied in order to discourage

the use of polluting products and to encourage consumption of cleaner alternatives.

EPA should consider that when a product is highly toxic, and when its use should be drastically or

completely reduced, a partial or total ban is preferable to product charges. Product charges can act as a

substitute for emission charges whenever it is not feasible to apply direct charges to pollution. The

rates of product charges decided by EPA should reflect the environmental costs associated with each

step of the product life-cycle. The rates are fixed but can be re-calculated if the charge lacks incentive

power. The effectiveness of a charge on polluting products or product inputs will generally depend on

the elasticity of the demand for that product. For example, where input costs are a small fraction of

total costs, doubling or tripling the price through an input tax is unlikely to have a significant effect on

consumption, unless there are suitably priced substitutes. If less polluting substitutes are available,

small increases in input prices may induce substitution and innovation over the longer term . Like any

other MBI, revenues from product charges can be used by EPA for any other pollution mitigation

technique for instance, to treat pollution from the product directly, to provide for recycling of the used

product or for other budgetary purposes.

2.6. SUBSIDIES

Subsidies is another Market Based Instrument which is designed to induce polluters to reduce the

quantity of their discharges by investing in various types of pollution control measures. These include

Tax incentives (accelerated depreciation, partial expensing, investment tax credits, and tax

exemptions/deferrals)

Grants and low interest loans



There are some shortcomings of Subsidies. First, subsidies can result in inefficiencies by encouraging

over-investment in pollution control or over-expansion of the polluting activity. For instance, large

subsidy shares in the investment costs of pollution control, as implemented in the United States

Construction Grants Program, can induce plant operators to design capital intensive facilities with

excessive capacity. They also are not consistent with the polluter-pays-principle because the general

taxpayer subsidises the control costs of specific polluters. Moreover, subsidies pose a drain on

government resources80

so EPA will have to consider about the budget and the amount of subsidies to

be given to which Industries.

Moreover, as the small and medium size enterprises suffer a competitive disadvantage when they

adopt environmental control technologies so in order to compensate, the government gives Subsidies.

This becomes more critical during process changes as the small enterprises must face all-or-nothing

decisions and face considerably higher financial risks unlike large enterprise, with several processes

running in parallel and are able to make changes incrementally. Therefore, even where such subsidies

are not justified on the basis of efficiency, they may address equity concerns81

. It is worth noting that

the removal of a subsidy can also lead to a reduction in pollution. For instance, the removal of a water

subsidy can lead enterprises and residential users to conserve water and thereby reduce the amount of

pollutants they discharge into the effluent stream. Similarly, the removal of subsidies on pesticides

and chemical fertilisers can reduce water pollution, particularly groundwater contamination, and the

poisoning of aquatic life through run-off into water systems.

Conclusively, in terms of ease, Subsidies can be complex to design and implement but are flexible as

they can be very targeted or broad. However, as firms can get used to lowered cost of certain

activities/ technologies so such distortionary effects makes the authorities to question the

effectiveness of Subsidies. Hence EPA would also needs to consider the pros and cons of

implementing an MBI such as Subsidies but in general, Subsidies should be selective and should be

provided on a short-term basis as a free-ride situation of a totally free resource is not sustainable.

Below are tabulated the examples of Developing and Developed countries that have implemented

Subsidies.

Country Medium Description

Developed

Australia Air, water,

land

Deductions for Capital Expenditures incurred after 18 August 1992 for

preventing/combating/recycling pollution/ or treating/cleaning

up/removing/storing waste82

.

US Land As of 1991,23 states have fiscal incentives for recycling :tax

credits/deductions for investment in recycling equipment, sales tax

exemptions on recycling machinery and various loans/grants for related

activity83

Japan Air, water,

land

Special Initial depreciation as a percentage of the acquisition cost, in

addition to ordinary depreciation, for pollution preventing/recycling

equipment, and for energy efficiency Improving technology. Air, water and

noise abatement facilities get reductions of income, corporate, municipal

80

(O'Connor, 1994) 81

O'Connor, 1994 82

(OECD 1995 ,p 90) 83

(Oates 1994, p 119)



and fixed property taxes.

Asbestos emission reduction facilities are exempt from municipal and fixed

property taxes.84

Developing

China Air, water 80% of the revenue from effluent fines is placed in banks for borrowing by

enterprises making pollution control investments. This forms an important

source of earmarked pollution control funding. Also on an average 70 to

80% of the water effluent fees are rebated to the firms for environmental

protection improvements 85

India Air, water In 1983, accelerated depreciation for Pollution control machinery was

introduced. In 1990-91 the Ministry of Finance introduced rebates in custom

and excise duty for various pollution control equipment86

Mexico Air, water,

land

Accelerated depreciation at the rate of 50%/year for investment in

equipment used to control environmental pollution. Also immediate

deduction of 91%

on investment in new fixed assets(environmental pollution control)

permanently located out of the three most polluted cities (Mexico,

Monterrey, Guadalajara)87

84

(OECD 1991 ,p 91) 85

(Bernstein 1993 , p, 47,32) 86

(Mehta, Mundle & Sankar 1994 ,p. 13-17 87

OECD 1995 p.92

Section 3

Trading Permit System


Instruments


Section 3

3.1. OVERVIEW

The tension between environmental quality and economic growth in Punjab has been on the rise.

Punjab should not sacrifice the overall well-being of its citizens by adopting any global climate

regime that unfairly confines its growth. As there is little incentive for reducing pollution through the

existing regulating regime hence an incentive driven scheme-Emission Trading scheme can be fruitful

in Punjab.

3.1.1. DEFINITION

Market-based policy instruments have caught increasing attention of policymakers over the last

decades. Specifically, the tradable emission permits have been considerably more attractive for them

due to its various benefits over other available instruments. As briefly explained above, a central

authority (usually a governmental body) like EPA Punjab allocates a limited number of permits to

discharge the quantities of pollutant being considered over a specified time period. Polluters are

expected to have valid permits in proportionate amount to their emissions. Polluters willing to pollute

more or unable to limit their emissions, can do so by buying more permits from others who are willing

to sell their permits.

3.2.TYPES OF EMISSION TRADING PROGRAMS

Three Basic Types of Emissions Trading Programs

There are three basic types of Emission Trading Programs. Although the tradability feature is

common amongst all however they differ in some important aspects.

1. Reduction credit/Credit basesd

2. Averaging

3. cap-and-trade programs

In a credit based regime, facilities that reduce their emissions according to some pre defined level are

able to earn credits and these credits can be taken towards compliance by any other entity which is

either has a high cots or for them the regulatory requirements are difficult to meet. Under this

program, the credits must be pre-certified before they can be traded and this feature of creating credits

through an administrative process makes it different from the other Averaging type of Emission

Trading In which the certification is automatic .In Averaging programs in order to keep average

emission rate at a predetermined level it also involve the offsetting of emissions from higher-emitting

sources with lower emissions from other sources. Although like reduction credit programs, averaging

programs provides freedom to individual sources to meet emissions constraints by allowing

differences from source-specific standards to be traded between sources.

A Cap-and-trade program operates on different principles. Under a cap-and-trade program, a total cap

on emissions is set that defines the total number of emissions “allowances,” each of which provides its

holder with the right to emit a unit (typically a ton) of emissions. Limiting total emissions is a distinct

feature of the Cap and Trade systems as compared to the other two types. Each source covered by this

program must hold permits to cover its emissions, with sources free to trade permits from each

other.—similar to averaging programs—cap-and-trade programs do not require pre-certification of

allowances; the allowances are certified when they are distributed initially-In contrast to reduction

credit programs.


Instruments


For a successful program, all three types of emissions trading rely on certain factors that constitute as

prerequisites. First and most importantly, all three forms assume that an emissions control

requirement has been put in place that requires emissions to be reduced to levels below what they

otherwise would be. In a cap-and-trade program the requirement will take the form of an aggregate

cap on emissions combined with the provision that each source surrender allowances equal to its

emissions. For credit and averaging programs, the requirement will typically be a source-specific

standard (e.g., a maximum emissions rate).Moreover, in all three types of trading programs, the

requirements must be both enforceable and enforced. It would be impossible to enforce the

requirements because it would be impossible to determine whether sources were in compliance so it is

crucial that there must be accurate measurement of actual emissions or emissions rates.

For implementation an Emission Trading system in Punjab, a Cap and trade system will be followed

and Industries will be assigned an upper limit on emissions based on Punjab Environmental Quality

Standards.

3.3.POTENTIAL IMPACT OF AN EMISSIONS TRADING SCHEME

Emissions trading as a regulatory instrument can alter the trade-off between environmental quality

and growth for the betterment of the environment of Punjab. As discussed above, since Punjab is

facing challenges with pollution on both local and global scales hence It must develop new regulatory

instruments to meet these challenges. Introducing an emissions trading scheme will be a step forward

from both a regulatory and economic perspective. Emissions trading can reduce compliance costs

from the perspective of polluting firms and make the regulatory environment more predictable, raising

investment and growth. In the longer run, the reduced costs of compliance can have a multiplier effect

and can lead to initiatives that increase environmental quality.

Generally, there are four main reasons for the increasing interest in Emission Trading system:

• Desire to improve environmental performance;

• The flexibility with regards to implementation of policy;

• Explicit and separate treatment of distributive aspects;

• Economic efficiency

3.4.VISION/ OBJECTIVE OF EMISSION TRADING

Emissions trading scheme is a regulatory tool used to reduce pollution emissions at a low overall cost.

The potential gains from emissions trading appear most where, as in Punjab, the population is large

and economic growth is reliant on industry. Punjab , in moving forward to adopt an emissions trading

scheme for local pollutants can achieve its target of a healthier environment with industries having an

incentive to reduce.

The proposed emissions trading scheme for Punjab will aim to cap total pollution emissions, increase

regulatory transparency and accountability and reduce compliance costs for all participants. To

achieve this, a higher level of transparency and accountability is required. At present, the level of

pollution emissions is hard to determine and the lack of data especially of Emissions of industries

makes it even more difficult to implement instruments like Emission Trading System. Hence, by

collecting far more data and making this data available, at a lag, to the public, EPA can commit to

well-defined goals for total emissions from pilot sectors. Apart from direct cost savings, firms will

also gain from the greater predictability and transparency of regulation.

Section 4

Design and Implementation



Section 4

4.1. DESIGN AND IMPLEMENTATION

A trading scheme shall have several design ingredients in order to be actually able to facilitate the

efficient operation of a cost-effective and competitive marker, eventually enhancing the

environmental state. Some of the design elements in this regard could include a clearly defined scope,

specified cap with rationale, fair distribution of tradable permits, conducive banking facilities and

effective monitoring system.

The steps include:

1) Survey

Before beginning the process of trading permits, it is of paramount importance that there is sufficient

information collected as to who are the polluters, what is their existing level of emissions and the

major pollutants. Unless EPA has a strong mechanism of monitoring and reporting, the efficiency of

this system is limited. So at first, a survey should be conducted through which all the necessary

information could be collected.

2) Define the scope

The scope of an ETS includes the geographic area being considered, industries/sectors, emissions

sources, and gases for which permits are targeted along with the responsible authorities. The scope

should also define the boundaries of the policy. EPA Punjab shall define the scope along with

identification of sectors and gases to be covered. Setting thresholds should also be considered.

3) Set the cap

The cap sets limit on the number of permits issued over a stated time period, thereby constraining the

total amount of emissions produced by applicable entities. The lower the cap, the higher the price and

thus, stronger incentive to reduce emissions if everything else is considered equal. The number of

permits issued to Industries shall be according to the Punjab Environmental Quality Standards.



4) Distribute permits.

As caps determine the emission impact of an ETS, permit allocation determine its distributional

impacts. Special attention should be given to this step as entire system’s efficiency can be influenced

otherwise. Permits will be pre-allocated for free by EPA Punjab followed by auction between the less

polluting and polluting firms monitored by EPA. The highest bidder will be allocated the permits and

10% revenue will be granted to EPA Punjab.

5) Ensure compliance and oversight

Similar to any other policy, ETS needs a vigilant oversight for effective enforcement of associated

obligations. The basic functioning of the market, high economic stakes for participants and emission

reporting will be under threat if the system lacks compliance and oversight. EPA must make

industries confident that buying permits is the only reliable way to meet environmental obligations

EPA Punjab shall have to manage emissions reporting by regulated industries efficiently and

implement any penalties accordingly. In case of non-compliance in the first year, an increase of 25%

of permit price will be charged followed by an annual increase by 50% in the proceeding year and so

on.

6) Implement, evaluate, and improve

A successful ETS requires support from public and political infrastructure, in addition to collaboration

across government and market players based on shared principles such as, trust, and capability. In

fact, the manner and, in particular, the transparency with which ETS policy makers engage with

others in government and external stakeholders will determine the long-term viability of the system.

Hence in order for it to be a success in Pakistan, EPA will have to tactfully keep on board all

stakeholders and keep their point of view in consideration.

4.2. CHALLENGES

Implementing a Trading Permit system is a complex and time taking task which requires a dedicated

and combined effort of all the stakeholders involved. The challenges can broadly be categorized into

1. Design issues

2. Implementation issues

4.2.1. DESIGN ISSUES

These issues represent serious concerns when it comes to designing a Trading Permit system .The first

and foremost is to decide at what level the cap on Emissions should exist. Does it have to be

according to PEQS or a percentage reduction of PEQS? Deciding on which gases to include can be

difficult as well since prioritizing any one gas over the other may pose a challenge. Especially in

Punjab where there are big and small industries so which industries to include under this cap and trade

program requires serious effort on part of concerned EPA officials. Allocation of initial allowances is

another important challenge. Should they be grandfathered or auctioned out? Another one is

Geographic or temporal flexibility or restrictions which includes the possibility of restricting

trades among different parts of the geographic range of the program 88

.EPA will also have to decide

whether it would allow the firms to bank and borrow their permits or not.

4.2.2. IMPLEMENTATION ISSUES

A number of concerns come into play when its about implementation of which Certification of

permits is one. However this only applies to reduction credit programs, which require that emission

88

Tietenberg 1995



reductions be certified before they can be traded. Monitoring and reporting of emissions is the most

important challenge. It is of paramount importance that methods must be designed to monitor and

report emissions from each participating source89

. Moreover currently with the lack of efficient

monitoring system in Punjab calls for immediate actions on part of EPA as otherwise the efficiency of

this system is constrained. Determining compliance and enforcing the trading program is another

major challenge. These decisions relate to the means of determining whether sources are in

compliance and enforcing the program if sources are out of compliance. Maintaining and

encouraging participation. This relates to decisions made by EPA to keep sources in the program

and encourage participation of sources whose participation is optional (e.g., those given the

opportunity to opt-in).

The main issue that still needs to be dealt with is cost uncertainty. Abatement costs are and will

remain largely uncertain. Especially in Punjab where a lack of information and insufficient awareness

prevails, lobbying by powerful interest groups, limited public support and participation, lack of

technical expertise and most importantly lack of data on emissions are serious concerns that need to

be addressed before setting a Permit system. Even where there is strong political will, EPA may not

be able to act effectively because of institutional deficiencies. Under these unfavorable circumstances,

therefore, opportunities for the effective application of economic instruments such as Tradable Permit

scheme in Punjab can be very limited. However, the intensity of environmental problems, the

potential cost savings from trading, and improvements in infrastructure all provide optimistic signs for

the use of emissions trading. Many barriers still needs to be addressed before emission trading

schemes can be implemented on a large scale in Punjab.

4.3. CONTINUOUS MONITORING TO SUPPORT ETS

As discussed, a successful emission trading system is contingent upon a sound monitoring system.

This calls for continuous emissions monitoring systems (CEMS) at each participating industry in

order to support emissions trading. The reasons for this requirement are reviewed here.

1. Monitoring Total Emissions. The unit of exchange in an emissions market is some measure

of total industry emissions into air. Emissions concentrations and the rate of flow must be

measured continuously and totaled over the whole trading period, often a quarter, half-year

or full year to monitor this total quantity.

2. Integrity of Emissions Trading System. All participants in emissions markets must have

confidence that the unit of exchange, for example a ton of emissions, represents a

commodity of equal value no matter its source. Online monitoring and constant scrutiny of

each participating unit creates this confidence by showing units the rigor of the system.

3. Equity of Compliance System. The value of permits that each unit must buy or sell depends

on emissions at all other units. If any emissions from any unit are reported low, for instance,

it lowers the demand for and thus the value of permits and reduces incentive for all units to

achieve additional abatement. Any lower standard of monitoring is therefore especially

unfair to the units achieving the most abatement.

Spot-monitoring of emissions combined with some model to relate these spot observations to total

emissions is a substitute to continuous emissions monitoring. For instance, in the Chilean total

suspended particulates trading scheme, the actual trading units were not based on monitored

emissions but on the capacity to produce emissions. This was achieved by measuring the boiler size

and fuel type of each unit during annual inspections by the regulator. Under the Clean Development

89

Tietenberg 2002



Mechanism (CDM), units project carbon emissions based on fuel consumption and emissions factors,

which are then verified on-site during annual validation by a Designated Operating Entity (DOE),

basically a third-party auditor.

Hence, for an Emission Trading system in Punjab, the reports submitted by the concerned Industries

would be verified by a third party. Incase if there is any discrepancy between the results, it would call

for a reverification of the results. Penalties may be imposed for the firms to be careful and vigilant

next time.

4.4. INTERNATIONAL EXPERIENCE WITH EMISSIONS TRADING

A few examples of Emission Trading Program include but not limited to

United States’ Environmental Protection Agency (EPA) initiated Lead Trading Programme in 1980

for the purpose of helping companies who had to comply with strict environmental standards by

lowering the lead content of gasoline by 10%. It was a Credit based Emission trading system where

firms which could lower the lead content than required were able to earn credits. Trading was

complemented by a "banking" component whereby the EPA created a program that would allow firms

to "bank" these credits. Thus, the banking mechanisms allowed the refineries additional time to

comply with the stricter lead standards. The monitoring and reporting was through periodic facility

inspection. RECLAIM Regional Clean Air Incentives Market is another Emission Trading Program

that covers Sulphur dioxide and nitrogen oxide. Allowances are Grandfathering and No banking or

borrowing is allowed. It also charges a penalty up to US$ 500 per violation.

European Union Emission Trading Scheme is the largest greenhouse gases trading program. The

sources include, Energy intensive industries, iron and steel, certain mineral Industries, Energy

production and Pulp and paper. The covered pollutants include Carbon dioxide. It follows Cap and

trade: Overall cap on total emissions from all 25 member countries equal to the EU commitment

under the Kyoto Protocol. Permits are grandfathered and Banking and Borrowing of Permits is

allowed. Penalties are imposed €40 per ton of CO2 in the first phase €100 per ton of CO2 in the

second phase.

There have been a number of actions in India to create carbon markets. An important one is the

Perform, Achieve & Trade (PAT) scheme which is being implemented for the designated industries

under the National Mission on Enhanced Energy Efficiency. The activities under the PAT scheme

provide opportunities for new markets as PAT devises cost effective energy efficient strategies for

end-use demand-side management leading to ecological sustainability. Another scheme is the

Renewable Energy Certificate (REC) mechanism, which is also being implemented to promote further

investment and development of renewable energy sources in India. This is complimentary to the state-

wise targets for Renewable Purchase Obligation (RPOs) mandated by the Government with an aim to

increase the share of renewable energy in India’s energy mix.

India’s two-year pilot Emissions Trading Scheme (ETS) mechanism began in 2011 in three states –

Gujarat, Tamil Nadu, and Maharashtra. The states received government mandates to implement

programs focusing on particulates, such as, SO2, NOx, and SPM. The pilot ETS was launched by

MOEFCC together with CPCB and relevant SPCB. Under this mechanism, SPCBs determine which

pollutants to regulate for industrial facilities based on targeted overall pollutant concentration. State

regulators distributes emission permits to capped facilities, which have the option of complying with

their caps and selling extra permits or buying permits from the market. The objective of the scheme is

to improve the air quality, incentivize facilities to reduce air pollution and help states meet their



National Ambient Air Quality Standards (NAAQS). The system covered nearly 1,000 industrial

facilities under the scheme where SPCB determined the eligibility criteria.

In 2001, the European NEC Directive has set national emission ceilings for every MS with regard to

the substances NOx, SO2, NH3 and VOC. Due to Netherlands inherited high population density and

their susceptibility to acidification; it received a very stringent ceiling on NOx and SO2 emissions.

The emission level of 393 kton of NOx in 2003 was to be minimized to 260 kton in 2010 according to

the EU Directive. As this called for a stark decline in NOx so the Netherlands decided to use an

emission trading scheme with the following allocations.

Mobile Sources (158 kton)

Industry (55 kton)

Consumers and services (19 kton)

Others and reserve (28 kton)

In this program, Banking and borrowing is restricted to 5% of one year’s allowance and Permits are

granted for free and follows the principle of Self-monitoring. Moreover, in the industrial sector, this

trading scheme covers 260 installations with a capacity exceeding 20 MWth. Dutch NOx scheme

differs from the international CO2 emission trading in the sense that it uses relative rather than

absolute emission ceiling. Thereby the scheme allows for industry growth and non-Dutch companies

can operate within the country’s geographical area without having to buy allowances but by simply

complying with the relative emission standard. Performance Standard rates (PSR) is used to generate

allowances. This sums up to a distinct ET scheme, called a “dynamic cap” system which has a higher

uncertainty about the environmental outcome and implies higher administrative costs compared to the

standard “cap and trade” system but at the same time is industry-friendly and more widely accepted.

Hunter River in north of Sydney, Australia, drains large coastal catchments. Its water is used for

several activities. Australia set a salinity trading scheme according to which 1,000 salinity ‘credits’

were available. Each credit allows 0.1% of total salinity discharge per block of water. The credits

have different life spans, allowing 200 to be reissued every two years and allowing new entrants to

participate in the market. The credits have a lifespan of 10 years and are issued by auction, thus

available for purchase by licence holders. Credits are tradable between participants thereby creating a

market for exchange of these emissions and pay price for higher demand.

Below is summary of MBIs applications in developing countries

S# MBIs Reasons Applying Countries Examples

1. Pollution

Charges

Industrial air and

water pollution from

large units

China, Colombia,

Ecuador, Malaysia,

Mexico, Philippines

China – Higher industrial

electricity prices for more

energy-intensive enterprises

2. Tradable

Permits

Air pollution from

large units, water use

by large units and car

use/congestion in

megacities

Chile, Mexico,

Singapore

India – Energy intensity-

based cap-and-trade for

industry and tradable

renewable energy

Certificates

Korea – Emission

trading legislation (Cap-



S# MBIs Reasons Applying Countries Examples

and-Trade)

China – pilot emission

trading systems

3. Deposit

Refund

Systems

Waste management

of households

focusing on batteries,

plastic and glass

Colombia, Ecuador,

Jamaica, South Korea,

Mexico, Sri Lanka,

Taiwan, Venezuela

EU – Offering money

for return of glass and

PET bottles

4. Product

Charge

and

Taxes

Air pollution mostly

from large units, fuel

use, and traffic

congestion is taxed. It

is also used to halt

deforestation.

Brazil, Chile, Kenya,

Mexico, Thailand

South Africa – Tax on

high CO2-emitting

motor vehicles and

electricity from non-RES

Korea – Removal of

price support for

anthracite coal

production

5. Subsidy Air pollution from

both large and small

units. It is used to

incentivize

reforestation and

adoption of cleaner

technologies

Brazil, Chile,

Colombia, Ecuador,

Kenya, Mexico,

Tanzania

Korea, Brazil – Tax

exemptions for biofuels

India, China, Pakistan –

Feed-in tariffs for

electricity from

Renewable Energy

Sources (RES)

Brazil – National

Development Bank

financing for electricity

production from RES

and ethanol

Korea – Credit

Guarantee Funds for

“green” technologies

Government can set emission limits for industries operating or develop a Pollution Index as per Indian

example. Failure to report emissions and surrender emission permits may be punishable by a further

government regulatory mechanism. Industries will choose the least-cost way to comply with the

pollution regulation, which will lead to reductions where the least expensive solutions exist, while

allowing emissions that are more expensive to reduce.

4.5. CONCLUSION

Emissions trading requires highly accurate monitoring verification of industrial emissions not just

reporting but a check and balance needs to maintained. The choice and success of an instrument is

much more than simply a question of which instrument is the most cost-effective. EPA Punjab has to

consider the current situation to understand the feasibility of Tradable Permit System as the lack of

transparency and monitoring possibilities, inadequate legal systems, and, foremost, the difficulties



involved in creating a functioning market observed is prevalent. In the near future, emissions trading

might be the centrepiece of local and international efforts to build a global and comprehensive

Trading Permit system.

It should be noted that Punjab can’t just rely on the new Market Based Instruments. Command and

Control approach has to be supplemented with Market based instruments as just the implementation of

former is not very encouraging. Market based instruments support the financial incentives with

environmental objectives and give an effective driving force to enterprises to advance and adopt cleaner

and better pollution control technologies. However, it remains an open question whether tradable

permits are appropriate for use in transition and developing economies like Pakistan. As mentioned

before there are critical design issues for the permit schemes which should be considered.

4.6. RECOMMENDATIONS

An intensive design period needs to be kicked off immediately and calls for modification into the

current structure of state environmental policy instruments The following steps are necessary to

prepare the key elements of the proposed system:

Broad political discussion with key stakeholders so that everybody is on board

Strengthening institutional and human resource capacity. Arrange seminars and awareness

campaigns and try to influence industries to introduce Best Available Technologies.

Incorporation of trading into the legal system (e.g. alterations/amendments to specific

legislation.)

Studies on specific design and implementation issues, other legal issues, analysis of economic

impacts, and links with the international emissions trading system.

Strong Monitoring and evaluation system to gain information especially of emission levels of

Industries.

Chapter 6

Enhanced System for Quality

Environmental Assessments Reports

and

Technical Reviews

Chapter 6 Enhanced System for Quality EA reports and Technical

Review


118

Chapter 6

Enhanced System for Quality

Environmental Assessment Reports and

Technical Reviews In order to improve the EIA review and approval process of Punjab EPA, and the resulting quality of

the Environmental Assessment Reports, the Punjab EPA IEE/EIA process were assessed together with

selected EIA cases in Punjab (reflected in the Gap Analysis report). To further enhance and

systematize the review process, recommendations were made at each step for improvements into the

current EIA review process of Punjab EPA with the aim to ensure ease of business and at the same

time meeting environmental protection requirements.

In addition to the main weaknesses noticed in the IEE/EIA review process (during the Gap analysis)

in Punjab, the main underlying factors causing bottlenecks in the process are

Lack of sufficient staff,

Lack of expertise,

Limited public hearing practise with no formal redress mechanism,

Lack of monitoring and

Lack of laboratory capacities for carrying out monitoring.

There are different steps involved in the Environmental Assessment process and practices such as

screening, scoping, baseline data collection, public participation, review and appeal and monitoring.

These steps are improved and enhanced with the support of ICT based web interface of EIA module

that will help in removing the bottle necks in the current system.

In the following, main suggestions are made for enhancing and increasing the efficiency of the

IEE/EIA review process of Punjab step-by-step.

1.1. STEPWISE SUGGESTIONS FOR ENHANCING PUNJAB EIA PROCESS

I. Registration of Consultants

In the current system, there are no registered environmental consulting firms & consultant, which

result in production of low quality of reports. This is one of the major concern that encounter from the

EPA officials at the time of GAP analysis. The poor quality reports results in delay of the process and

also increases pendency of review of IEE/ EIA cases.

Improvement suggestion

It is suggested to have an online registration system for environmental consulting firms as well as

individual consultants. In addition to this, it is also proposed that there should be different categories

of these consultants that defines their projects and scope of work. The proposed categories of these

consultants are;

Category A: Consultants in this category shall be eligible to undertake all types of studies (e.g.,

Environmental Impact Assessments (EIAs), Strategic Environmental Assessments (SEAs),


Review


environmental surveys, Preliminary Environmental Reviews (PERs), Action Plans, Construction

Environmental Management Plans (CEMPs), Operation Environmental Management Plan (OEMPs)

for projects falling within their core competency requirements.

Category B: Consultants in this category shall be eligible to undertake preliminary studies, e.g., Initial

Environmental Examinations (IEEs), Environmental Surveys, Preliminary Environmental Reviews

(PERs), Action Plans, (i.e., all studies except SEAs, EIAs) for projects falling within their core

competency requirements.

Category C: Consultants in this category shall be eligible to undertake studies for basic projects

falling within their core competency requirements.

II. Information dissemination

In a current system, there is no proper mechanism of sharing and dissemination information to general

public and even proponent. In most of the times, there is very limited information available that

results in mistrust among stakeholder.


In a proposed EIA web portal, there are three interfaces where relevant information can be shared

with the stakeholders. The information shared are;

Public ( EIA report, public hearing minutes & environmental approvals)

EPA officials (EIA report, project information, impacts and mitigations, monitoring)

Proponent and consultants (Status of EIA review process, public hearing minutes &

environmental approvals)

This new system will improve the business process by bringing in transparency in the process and

help regain the trust among key stakeholders.

Fig. 7.1: Key interfaces of enhanced Environmental Assessment Process and flow of information


Review


III. Screening

The very first step in the environmental assessment process is the Screening process that results in key

decision making of either the project requires Initial Environmental Examination (IEE) (project falls

in Schedule I) or Environmental Impact Assessment (EIA) (project falls in Schedule II) dealt by the

Regulations Section 12 of the IEE/EIA Regulations, 2000. This step requires a systematic procedural

approach, as an important decision making tool.

Review of IEE/EIA Regulations 2000 gives a standardized list of projects through Schedule I & II.

The major issue is the inadequacy of these schedules that includes missing project types, placement of

projects in wrong categories, inappropriate division of projects for IEE & EIA. In some cases the

project scheduled of IEE have significant impacts due to number of reasons (i.e. size, place etc.)

therefore need to be revised.


In order to strengthen systematic screening of the environmental approval applications for

Projects by Punjab EPA, Screening Worksheet based on checklist has been developed as part

of this consultancy. Given that the Punjab EIA process includes also Site Inspections, the

Screening process and suggested enhancements into the EIA Review have been linked also

with the Site Inspections so that the site inspections can be guided by the screening and

provide additional information into the EIA review. The Screening sheet including the

checklist questions developed is provided as Annexure 1.

A part from screening checklist, a comparative analysis of Schedule I & II (projects requiring

IEEs and EIAs) from section 12 of Review of IEE/EIA Regulations 2000 was done with the

schedules of different countries and EU directives. Based on above analysis, a new schedules

has been proposed (attached in Annexure 2).

IV. EIA Report Review

In the currently guidelines, the only checklists for the IEE/EIA review process are the limited

numbers of project types usually not specifically identified as part of the review process and main

report contents.

In the EIA case review, it was noted that the project type in question is not usually recorded in the

review and EPA receives applications concerning some project types that are currently missing from

the IEE/EIA project type categories. Moreover, some applications may be submitted as IEEs but they

are later turned into EIAs as part of the ongoing internal review process instead that the application is

rejected and requested to be resubmitted.

In general there seems to be lack of systematic approach for assessing the projects and their impacts

why a brief overview for such review enhancement is provided.


Carry out systematic assessments throughout the review from project types to impacts and mitigation.

This review suggests to amend the existing IEE/EIA process of Punjab with project types and

processes of screening and scoping as recognized by international consultants. This, however, requires

decisions from the relevant legislative authorities for making provisions into the laws. The

suggestions provided for how to enhance the current process are therefore made based on the current

EIA guidelines but also with regard to the broader following amending. If the laws will be amended

by recognizing more systematic project lists (Schedule I & II of IEE/EIA Regulations 2000).


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Following are the main steps of improvement in EIA review process;

i) Screening: Once the project is submitted for screening by the proponent, the EIA official

needs to verify the screening by checking the Schedule I & II of IEE/EIA Regulations 2000.

The EIA official will approve the project screening stage.

Fig. 7.2: Interface for decision on screening Stage

ii) Scoping: Scoping means the process of determining the content and extent of the matters,

which need to be covered in the environmental information submitted to a competent

authority for projects subject to EIA. In other words, the competent authorities define what

information is required from the project in an EIA in Scoping.

It is important that the scoping stage will be systematically done in the EIA review process.

At the time of screening and scoping stage, the proponent will have to submit the terms of

references (TORs) of the IEE/ EIA report. The EIA officials can review the TORs of the

report and suggest changes. This stage is very important to be part of a systematic process as

this stage is currently either missing or haphazard and done once the EIA report is prepared

and submitted to the EPA. In the EIA web portal, the scoping stage is placed before the

submission of the EIA report.


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Fig. 7.3: Interface for decision on scoping Stage

iii) Preliminary scrutiny: Currently this stage allows 10 days for reviews followed by

requesting additional information from the proponent as deemed needed. In case full /

satisfactory information is not received, another set of queries are sent to the proponent

preferably within 10 days.

In practice this stage is also used to first define some preliminary questions (first round of

questions) that are then completed by further questions (second and further rounds of

questions to the proponent). The main problem with this stage is that any application can stay

in the scrutiny loop an unknown time due to repeated queries. Also, internally the reviews can

be extensive including several spheres of directors which is very time consuming for the

process.


Comprehensive staff and/or expert review so that all possibly missing information is

requested at once

EIA web portal will only accept the application once all the required document has been

uploaded on the portal. This will include;

Review few cheque (scanned copy)

Filled schedule four form

IEE and EIA report

TORs of the report

Contract between Consultant and proponent

iv) Standard Forms: There are no standard forms for collection of information. That results in

reports that missed out important information required for the review and approval of the

project.



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Standard forms are very important to collect structured information. Standard forms have

been developed for the following processes and also make them part of our ICT based

solution.

Certificate of completion (EIA web portal)

Site Inspection Report (android based)

Lab report (android based)

Public Hearing Advertisement (template in EIA web portal)

Environmental Approval / No objection certificate (template in EIA web portal)

v) Review of complex projects: In the EPA EIA case analysis reported separately, it was noted

that although the reviews were time consuming due to several internal review steps in EPA as

well as additional query rounds to the proponent, the review could still miss out on some

relatively significant matters such as impacts sources, additional plans (such as buildings)

requiring specialized waste management, suggested energy solutions, railways and high level

technologies required for highly complex projects such as large power plants.


Enhance the technical review by assigning dedicated experts into the review in cases where

in-house expertise is not available or does not suffice. If specialized expertise is required,

does it concern specific technology, set of impacts or the complexity of the project?

If technology, does one specialized expert’s input suffice?

If set of impacts, have all the potential impacts identified or are some missing?

If this cannot be answered, suggest asking a peer review / external inputs.

Consider whether a site visit required?

If complexity of the project, what areas of the project need closer reviewing?

Transport solutions, urban planning of highly populated areas, suggested

energy solutions, waste management, water supply/water use?

V. Check Environmental Monitoring Plan and Budgets

In the Punjab EIA case review undertaken (Gap report), the proponents provide typically

Environmental Monitoring Plans (EMPs) for the projects which are not actively assessed in the EPA

when undertaking the review process or delivering decisions.

However, the EMPs can provide tools to be considered for the Environmental Approval / No

Objection Certificate provided to the proponent by EPA that include monitoring requirements. It is

therefore suggested that the EMPs provided are assessed by EPA against screening and scoping as

well as to define the real budgetary requirements for the EMP that can be included in the

Environmental Approval which improves monitoring efforts and compliance enforcement that seem

to be currently largely missing.


Assess the Environmental Monitoring Plans against screening, scoping and define realistic budgetary

requirements for EMPs to be included in the Environmental Approval / No Objection Certificate.

Main steps

i) Based on screening and scoping, assess what monitoring and mitigation measures are

required for the project impacts (air, water, soil, land use, land ownership, pollution

prevention/control).


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ii) Check whether the Environmental Monitoring Plan (EMP) of the project accounts for all the

significant impacts and mitigation measures and that the EMP has been divided into project

phases and/or different areas accordingly.

iii) Based on screening and scoping, assess and define annual monitoring requirements to be

reported for compliance and compare these with the suggested EMP.

iv) Assess the costs of the annual monitoring

v) Check whether EMP budgets are realistic annually for the project / monitoring duration

If inconsistencies or insufficient budgeting are detected, note what needs to be included and request

revised budgets to cover the monitoring.

VI. Public Participation

As a current standard, only one public participation event is arranged in an EIA usually after the

proponent receives a letter from EPA requesting the event to be organized. The proponent usually

advertises the event before 30 days in the local newspapers.

The public hearing minutes reflect mostly what the proponent has presented together with some main

technical questions that the public raises. Complaints or concerns concerning the project impacts are

not asked for or recorded properly.

The participation event does not present development alternatives since these are not usually well-

described in the EIA review process.

The 30 days and one event applied now as a practice provides a very limited scope to allow sufficient

participation especially for projects that are large scale and/or concern many stakeholders. As a result,

in EIAs that may concern a large populations (in the millions such as for urban plans), the event may

only have some tens of participants.


It is recommended that the EIA public participation requirements are amended so that enhanced

participation is ensured by

i) Adjusting the number of participation events and the time period for participation by EPA

based on project type so that large scale projects affecting a large area/population or are

complex have more events and longer time for participation. Large and complicated

projects with possible land disputes may require even some months for sufficient

participation.

ii) Asking for complaints and concerns regarding the project including compensations from the

participants in the public hearings by EPA

iii) Asking for the proponent to present and display development alternatives

iv) Recording, analysing and addressing the complaints and concerns received

v) Requesting public participation event advertisements to be published in the project area

newspapers also in local language

vi) Ensuring participation events are arranged also near to the project site to allow local

participation.

vii) Public Hearing minutes should be displayed at the EPA website or EIA web portal.

viii) Public Hearing minutes can also be send to the participants or even to those who raised their

concerns.


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ix) It is further suggested that, in EIA web portal all the IEE/ EIA reports will be displayed to

the general public for their information and comment. Any person can comment on the

report by getting registered on the EIA web portal.

Fig. 7.4: Interface for general public for download and comment on IEE/ EIA Reports

VII. Revisiting Conditions and Extension of EIA to Operational Phase

In successful applications, the Punjab EIA process results into Environmental Approval of the EIA

granted for the project construction phase with main conditions to be full-filled. The operational phase

following the construction phase is subjected to a separate EIA process.

The main issue currently is that the conditions for construction are not monitored or checked in

practice and that the conditions cannot be revisited once granted as these are fixed for the construction

period.

Also, having the same project go through another EIA process for operations seems rather time

consuming as the same project could be processed with one EIA review with the conditions subjected

to periodic renewal based on monitoring/field inspections.


It is recommended that the Environmental Approval that includes main conditions for the construction

phase is changed as a periodic renewal process and the project proceedings are checked by

compliance monitoring and EPA site inspections.

It is recommendable that the compliance monitoring requirements for the proponent are defined on

monthly and quarterly basis by EPA and that the Environmental Approval granted including

conditions is reviewed annually.

It is also recommended that the current EIA review process of Punjab is extended to cover both

construction and operational phases of the project so that there is no need for a separate EIA for the

operational phase.


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In order to combine construction and operational phases together, it is recommended that the

proponent prepares EIAs that cover both phases, indicate what different impacts are expected in the

construction and operational phases and suggests how these will be monitored and mitigated.

A part from this a new system of environmental permitting is proposed that will allow the EPA to

renew their permit after a specified interval during the operational phase of the project. Environmental

permitting will help improve the protection and conservation of the environment by establishing better

compliance.

VIII. Complaints & Compensations

Currently complaints are not recorded in the EIA process while disputes over land ownership are

typically raised based on land laws of the 1890’s that will be taken into courts indicating that the

complaint and redress compensation process is largely missing and inefficient.

As an alternative settlement, EPA can summon the proponent into negotiations aimed at

compensation settlements. In case these are not successful, the cases need to be settled in court.

Nonetheless, the EIAs usually provide an outline of a typical redress mechanism that can be used for

compensations although this is usually not followed.


Given the relatively weak participation and compensation mechanisms currently in place, it is

recommended that these aspects in the EIA are enhanced in particular.

As the most relevant laws concerning land disputes and their settlements originate over 100 years in

Pakistan, enhancing the legal basis for compensations is likely to require extensive legal assessments

and associated reforms. It is therefore recommended that lawyers are engaged in renewing the

relevant laws.

Before the legal basis for compensations is in place, it is recommended that World Bank grievance

and redress mechanisms, that acknowledge for example land use rights and local use of resources, can

also be followed and applied for EIAs till the time new laws will be in place.

ANNEXURES


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Annexure 1

PROJECT SCREENING CHECKLIST FOR ENVIRONMENTAL

IMPACT ASSESSMENT

Project Details

Project name

and district

Summary description of the project / development

Proponent

More specific

project site

location

EIA Details

Does the Project require EIA? <SELECT>

If YES, what project types(s) are in question?

Does the Project have applicable thresholds/criteria for EIA? <SELECT>

If YES, what criteria?

Is the development in, partly in or in the vicinity protected areas or

environmentally sensitive areas as defined in the EPA Sector Guidelines?

<SELECT>

If YES, which area(s)?

Does the Project require more information from proponent / site inspection? <SELECT>

If YES, more information / site inspection on which aspects are needed?

Screening

Does the screening done by proponent cover Characteristics of Project,

Location of Project, Type and Characteristics of the Potential Impact?

<SELECT>

If no or unsure, what is missing?

Is additional expertise required for the case review/ screening? <SELECT>

If yes, what? Would site inspection additional with expertise be beneficial?

Have development alternatives been considered and assessed sufficiently? <SELECT>

Earlier Applications/ Complaints/Environmental Protection Acts Etc.

Has the proponent applied for this or similar project earlier, are there known

complaints or legal issues (concerning environmental protection acts,

Click here to enter

text.


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128

disputes etc). Against the proponent/concerning the site?

Chapter 6 Enhanced System for Quality EA reports and Technical Review


SCREENING

Question

(Part 2a) / (Part 2b)

Answer to the question and explanation of reasons (Yes/No or

Not Known (?) or N/A)

(Part 3a) / (Part 3b) (only if Yes in part 2a)

Is a Significant Effect Likely?

(Yes/No or Not Known (?) or N/A)

Briefly explain answer to Part 2a and, if applicable and/or known,

include name of feature and proximity to site

(If answer in Part 2a / 2b is ‘No’, the answer to Part 3a / 3b is

‘N/A’)

Note: Question 12 differs from this where Part 12a is meant to

assess whether the review requires additional expertise due to

project complexity or large size used identifying projects that

may reauire more complicated, time consuming and specialized

review with public hearings. Part 12b is to identify the main

impacts and mitigation measures.

Is a significant effect likely, having regard particularly to

the magnitude and spatial extent (including population size

affected), nature, intensity and complexity, probability,

expected onset, duration, frequency and reversibility of the

impact and the possibility to effectively reduce the impact?

If the finding of no significant effect is reliant on specific

features or measures of the project envisaged to avoid, or

prevent what might otherwise have been, significant

adverse effects on the environment these should be

identified in bold.

Natural resources

1.1 Will

construction,

operation or

decommissioning of

the project involve

actions causing

physical changes in

the area?

1.2 Will

construction or

operation of the

project use natural

resources above or

below ground such as



land, soil, water,

materials/minerals or

energy that are non-

renewable or in short

supply?

1.3 Are there any

areas on/around the

location which

contain important,

high quality or scarce

resources which

could be affected by

the project such as

forestry, agriculture,

water/coastal,

fisheries, minerals?

Waste

1.4 Will the

project produce solid

wastes during

construction or

operation or

decommissioning?

Pollution and nuisances

1.5 Will the

project release

pollutants or any

hazardous, toxic or

noxious substances to

air?

1.6 Will the

project cause noise

and vibration or



release of light, heat,

energy or

electromagnetic

radiation?

1.7 Will the

project lead to risks

of contamination of

land or water from

releases of pollutants

onto the ground or

into surface waters,

groundwater, coastal

waters or the sea?

1.8 Are there any

areas on or around

the location which

are already subject to

pollution or

environmental

damage (such as sites

where existing legal

environmental

standards are

exceeded), which


the project?

Population and Human Health

1.9 Will there be

any risk of major

accidents (including

those caused by

climate change, in

accordance with

scientific knowledge)



during construction,

operation or

decommissioning?

1.10 Will the

project present a risk

to the population

(having regard to

population density)

and their human

health during

construction,

operation or

decommissioning?

(for example due to

water contamination

or air pollution)

Water resources

1.11 Are there any

water resources

including surface

waters, e.g. Rivers,

lakes/ponds, coastal

or underground

waters on or around

the location which


the project,

particularly in terms

of their volume and

flood risk?

Nature conservation/protected areas (species and habitats)

1.12 Are there any

protected areas which



are designated or

classified for their

terrestrial, avian and

marine ecological

value, or any non-

designated / non-

classified areas

which are important

or sensitive for

reasons of their

terrestrial, avian and

marine ecological

value, located on or

around the location

and which could be

affected by the

project? (these

include for example

wetlands,

watercourses or other

water-bodies, the

coastal zone,

mountains, forests or

woodlands,

undesignated nature

reserves or parks.)

Where designated

areas, indicate level

of designation

(international,

national, regional or

local).

1.13 Could any

protected, important



or sensitive species

of flora or fauna

which use areas on or

around the site, e.g.

For breeding,

nesting, foraging,

resting, over-

wintering, or

migration, be

affected by the

project?

Landscape and Visual Aspects

1.14 Are there any

areas or features on

or around the

location which are

protected for their

landscape and scenic

value, and/or any

non-designated / non-

classified areas or

features of high

landscape or scenic

value on or around

the location which


the project?90

where

designated indicate

level of designation

(international,




local).

1.15 Is the project

in a location where it

is likely to be highly

visible to many

people? (if so, from

where, what

direction, and what

distance?)

Cultural heritage/archaeology

1.16 Are there any

sites, areas or

features protected for

their cultural heritage

or archaeological

value, or any non-

designated /

classified areas

and/or features of

cultural heritage or

archaeological

importance on or

around the location

which could be

affected by the

project (including

potential impacts on

setting, and views to,

from and within)?

Where designated

indicate level of

designation

(international,




local).

Transport and Access

1.17 Are there any

routes on or around

the location which

are used for access to

natural resources,

communal/indigenou

s land or important

facilities (such as

health care centers),

which could be

affected by the

project?

1.18 Are there any

transport routes on or

around the location

which have heavy

traffic or cause

environmental

problems that can be

affected by the

project?

Land use

1.19 Are there

existing land uses or

community facilities

on or around the

location which could

be affected by the

project? For example

housing, densely



populated areas,

industry / commerce,

farm/agricultural

holdings, forestry,

tourism, mining,

quarrying, facilities

relating to health,

education, places of

worship, leisure

/sports / recreation.

1.20 Are there any

plans for future land

uses on or around the

location which could

be affected by the

project?

1.21 Are there any

important community

resources or land use

rights on or around

the location which


the project?

Disaster risk, climate and stability

1.22 Is the location

susceptible to

extreme /adverse

climatic conditions,

e.g. Temperature

inversions, fogs,

severe winds, which

could cause the

project to have

environmental



impacts?

1.23 Is the location

vulnerable to

disasters such as

floods, earthquakes,

landslides, erosion,

regular coastal

flooding/ storm

surges that could

cause the project to

have impacts?

Project complexity /

scale / area Describe what requirements/solutions and where

Describe possible impacts and main mitigation

measures required

1.24 Does the

project have

specialized

technological

requirements (eg.

Large energy

production with

specialized

technologies such as

managing

hazardous/nuclear

materials, toxic

substances, cooling

systems etc.), cover

large areas (square

kilometres) or areas

affecting a large

population size (over

10,000 people)?

1.25 Does the



development

site/project require

specialized analysis

or measures such as

soil contamination

management, soil

rehabilitation; does

the project have high

levels of local

resource use

(groundwater)?

Cumulative IMPACTS

1.26 Could this

project together with

existing and/or

approved

development result in

cumulation of

impacts together

during the

construction/operatio

n phase?

Transboundary effects

1.27 Is the project

likely to lead to

transboundary effects

or is the project

linked with existing

important

(provincial, national)

strategy or

development plan

(such as energy



solutions, urban

development plan)?91

91 The Regulations require consideration of the transboundary nature of the impact and the relevance of Strategic Environmental Assessments.


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141

5. CONCLUSIONS

<INSERT CONCLUSIONS>

6. SCREENING SUMMARY FOR EIA REVIEW AND MONITORING

Impacts needing attention Click here to enter text.

Need to provide more analysis for

development alternatives and their impacts Click here to enter text.

Need for CIA, SEA or Specialized Expert

Analysis due to project characteristics Click here to enter text.

Issues regarding land ownership, land use

rights, resettlement requirements

Click here to enter text.

Any impacts causing compensation Click here to enter text.

Climate impacts requiring attention Click here to enter text.

Disaster impacts requiring attention Click here to enter text.

Main monitoring requirements, for how

many years and what reporting periods


Other notes (pending legal cases, disputes,

specific project features etc.)


7. IMPACT ASSESSMENT 8. OUTCOME

Is likely to have significant impacts on the

environment EIA Required

Is likely to have minor or some impacts on

the environment IEE Required

Not likely to have effects on the environment

(exclusion project list, other project of no

impact)

More information is required from

proponent and/or site inspection

Request further info/

Undertake Site

Inspection

NAME Click here to enter text.

DATE Click here to enter a date.


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Annexure 2

Punjab Screening Criteria for IEE


Project Type Criteria

Agriculture, Livestock, Fisheries

1. Poultry, livestock, dairy, stud and fish farms

with total cost

> Rs. 20 M

2. Projects involving Packaging, formulation,

cold storage or warehousing of agricultural

products

All Projects

3. Projects for the restructuring of rural land

holdings;

All Projects

4. Projects for the use of uncultivated land

or semi-natural areas for intensive

agricultural purposes;

All Projects

5. Initial afforestation and deforestation for the

purposes of conversion to another type of

land use

All Projects

Energy

6. Hydroelectric power generation < 100 MW

7. Thermal power generation < 200 MW

8. Coal power generation < 100 MW

9. Transmission lines < 11 KV and large distribution projects

10. Oil and Gas Transmission Systems All Projects

11. Oil and gas extraction projects including

exploration, production, gathering systems,

separation and storage

All Projects

12. Surface and Underground storage of Natural

Gas, combustible gases, fossil fuels,

petroleum, petrochemical and chemical

products

All Projects

13. Wind Projects All Projects

14. Solar Projects All Projects

15. Waste-To-Energy All Projects

16. BTS, telecom & other wireless

communication towers

All Projects

Manufacturing & Processing

17. Ceramics and Glass Units <Rs. 100 M

18. Food Processing Industries <Rs.100 M

19. Installations for the slaughter of animals All Projects

20. Synthetic resins, plastics and man-made

fibres, paper and paperboard, paper pulping,

plastic products, rubber, textiles (except

<Rs.100 M


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apparel), printing and publishing, paints and

dyes, oils and fats and vegetable ghee

projects

21. Manufacturing Apparel > Rs. 25 M

22. Plants for the pre-treatment (operations such

as washing, bleaching, mercerization) or

dyeing of fibers or textiles

All Projects

23. Wood Products > Rs. 25 M

Mining and Mineral Processing

24. Commercial extraction (sand, limestone,

clay, sulphur any mineral not in schedule II)

<Rs.100 M

25. Crushing, grinding and separation All Projects

26. Smelting Plants <Rs.50 M

27. Installations for the production of asbestos

and the manufacture of asbestos products

All Projects not included in mandatory EIAs

Production and Processing of Metals

28. Installations for the production of iron or

steel (primary or secondary fusion)

including continuous casting

All Projects

29. Installations for the processing of ferrous

metals:

(i)hot-rolling mills;(ii)smitheries with

hammers;

(iii)application of protective fused metal

coats

All Projects

30. Ferrous metal foundries All Projects

31. Installations for surface treatment of

metals and plastic materials using an

electrolytic or chemical process

All Projects

32. Manufacture and assembly of motor vehicles

and manufacture of motor-vehicle engines

All Projects

33. Installations for the construction and repair

of aircraft

All Projects

34. Manufacture of railway equipment All Projects

35. Installations for the roasting and sintering of

metallic ores

All Projects

Transport

36. Federal and Provincial Highways <Rs.50 M

37. Ports and Harbours Ships <500 Gross Ton

38. New Roads 2 - 4 lanes

39. Realignment and/or widening of existing

road to provide four or more lanes

< 2 lanes with 5- 10 km continuous length

Water Resources Management

40. Dams and Reservoirs < 50 M cubic meters


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< 8 Square kilometre surface area

41. Irrigation & Drainage < 15,000 hectare serving area

42. Groundwater abstraction or artificial

groundwater recharge schemes

<10 million cubic meters abstracted or

recharged annually

43. Works for water resources transfer between

river basins to prevent water shortages

<100 million cubic metres annually

(excluding projects of transfers of piped

drinking water)


river basins

Multi-annual average flow of the basin of

abstraction exceeds < 2000 million cubic

metres/year

and amount of water transferred not exceeds

5 % of that flow (excluding projects of

transfers of piped drinking water)

Water Supply and Treatment

45. Supply Schemes and Treatment Plants

<Rs.25 M

Waste Disposal

46. Domestic or Industrial Waste Disposal

Facility

Annual capacity < 10,000 cubic meters

47. Waste water treatment plants <150 000 population equivalent

48. Sludge-deposition sites All Projects

Urban Development and Tourism

49. Housing Schemes All Projects

50. Public facilities with significant off-site

impacts (such as hospital wastes)

All Projects

51. Urban development projects All Projects

52. Holiday villages and hotel complexes outside

urban areas and associated developments

All Projects

53. Permanent campsites and caravan sites; All Projects

54. Theme parks All Projects

Other Projects

55. As required from Provincial Agency by Sub-Regulation 2 of Regulation 5


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Punjab Screening Criteria for EIA



Energy

1. Hydroelectric power generation > 100 MW

2. Thermal power generation > 200 MW

3. Coal power generation > 100 MW

4. Transmission lines ≥ 11 KV and large distribution

projects

5. Pipelines for transport of gas, oil, chemicals or

carbon dioxide (CO2) streams for geological

storage incl. associated booster stations

> 800 mm diameter

and

> 40 km length

6. Nuclear power plans All Projects

7. Petroleum refineries All Projects

Manufacturing & Processing

8. Cement Plants All Projects

9. Chemical Projects All Projects

10. Fertilizer Plants All Projects

11. Food Processing Industries ≥Rs.100 M

12. Industrial estates (including export processing

zones / ports)

All Projects

13. Manufacturing of apparel, spinning mills,

woolen mills, weaving mills including dyeing

and printing, garments and leather stitching

units, cotton ginning mills, plastic materials &

products, glue manufacturing, detergent, rubber

products, printing

>Rs.100 M

14. Pesticide (manufacturing or formulation) All Projects

15. Petrochemicals complex/production, processing

units

All Projects

16. Synthetic resins, plastics and man-made fibres,

paper and paperboard, paper pulping, plastic

products, textiles (except apparel), printing and

publishing, paints and dyes, oils and fats and

vegetable ghee projects

> Rs. 100 M

17. Tanning and leather finishing projects having

wet process

All Projects

Mining and Mineral Processing

18. Mining and processing of coal, gold, copper,

sulphur and precious stones

All Projects

19. Mining and processing of major non-ferrous

metals, iron and steel rolling

All Projects

20. Smelting Plants > Rs.50 M

21. Extraction of asbestos and for the Asbestos-cement > 20 t of finished


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processing and transformation of asbestos

and products containing asbestos

products annually

Friction material > 50 t of finished

products annually

Other uses > 200 t annually

Transport

22. Airports All Projects

23. Federal and Provincial Highways > Rs.50 M

24. New Roads > 4 lanes

25. Realignment and/or widening of existing

road to provide four or more lanes

< 2 lanes with at least 10 km

continuous length

26. Ports and Harbours Ships > 500 Gross Ton

27. Railways All Projects

Water Resources Management

28. Dams and Reservoirs > 50 M cubic meters

> 8 Square kilometre surface area

29. Irrigation & Drainage > 15,000 hectare serving area

30. Groundwater abstraction or artificial

groundwater recharge schemes

>10 million cubic meters abstracted

or recharged annually


river basins to prevent water shortages

>100 million cubic metres annually

(excluding projects of transfers of

piped drinking water)


river basins

Multi-annual average flow of the

basin of abstraction exceeds >

2000 million cubic metres/year

and amount of water transferred

exceeds 5 % of that flow (excluding

projects of transfers of piped

drinking water)

Water Supply And Treatment

33. Supply Schemes and Treatment Plants

>Rs.25 M

Waste Disposal

34. Waste disposal and/or storage of hazardous or

toxic waste (incl. landfill sites, incineration of

hospital toxic waste)

All Projects

35. Domestic or Industrial Waste Disposal Facility Annual capacity > 10,000 cubic

meters

36. Waste water treatment plants >150 000 population equivalent

Urban Development and Tourism

37. Land use studies and urban plans (large cities) All Projects

38. Large scale tourism development projects >Rs. 50 M

Environmentally Sensitive Areas

39. Environmentally Sensitive Area All Projects


Review


147



Other Projects

As required from Provincial Agency by Sub-

Regulation 2 of Regulation 5

All Projects

40. Any other project likely to cause an adverse

environmental effect

All Projects


Review


148

Environmental Assessment - epd.punjab.gov.pk Technical submission.pdf · Mr. Abdul Moiz Ms. Bisma...

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