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Environmental Impact Assessment

Course Curriculum for Higher Education Institutionsin Pakistan

Produced with the financial support of the Embassy of the Kingdom of the Netherlands (EKN).

Thomas B Fischer PhD FIEMA & Obaidullah Nadeem PhD FIPP





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Published by:IUCN Pakistan (National Impact Assessment Programme)

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Environmental Impact Assessment (EIA) Course Curriculum for Higher Education Institutions in Pakistanwas prepared under the National Impact Assessment Programme (NIAP), a joint initiative of theGovernment of Pakistan and IUCN Pakistan, with the financial support of the Embassy of the Kingdom ofthe Netherlands (EKN).

Citation is encouraged. Reproduction and/or translation of this publication for educational or other non-commercial purposes is authorised without prior written permission from IUCN Pakistan, provided thesource is fully acknowledged. Reproduction of this publication for resale or other commercial purposes isprohibited without prior written permission from IUCN Pakistan.

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Citation:Fischer, Thomas B. and Obaidullah Nadeem. 2014. Environmental Impact Assessment (EIA) CourseCurriculum for Higher Education Institutions in Pakistan. Islamabad: IUCN Pakistan. 218 pp.

ISBN 978-969-643-001-8

Editor:Shadmeena Khanum

Technical Support:Netherlands Commission for Environmental Assessment (NCEA)

Facilitation:Ahmad SaeedArfa Zaheer Azmat

Design:Azhar Saeed

Cover Photograph:IUCN Pakistan

Printed by:Hamdard Press (Pvt) Limited

Available from:IUCN PakistanNational Impact Assessment ProgrammeHouse No. 2, Street 83Embassy Road, G-6/4, IslamabadTel: +92 (51) 2271027-34Fax: +92 (51) 2271017www.niap.pk

1EIA Course Curriculum for

Higher Education Institutions in Pakistan

1 Introduction 61.1 Background to EIA course curriculum 61.2 Structure of EIA course curriculum 7

2 What is EIA? What is it trying to achieve and what are its principles? What benefits can result from EIA if considered indecision-making and where in the world is it applied? 92.1 Definition of EIA 92.2 Principles of EIA 112.3 EIA origin and development 132.4 Different types of impacts considered in EIA 142.5 Purposes, objectives, scope and effectiveness of EIA 152.6 Different legal, administrative and policy EIA frameworks

internationally 162.7 Context specific elements that enable effective EIA application 172.8 Practical exercise 19

3 Decision-making theory and practice 203.1 EIA’s role to act as an advocacy instrument in

decision-making and recent integration attempts 203.2 Actors interacting in and through EIA 213.3 Organisational behaviour 223.4 Decision-making models 263.5 Influences on effective decision-making 313.6 EIA as part of the decision-making process 313.7 Practical element 32

4 Main environmental problems the international community andPakistan are faced with and instruments for environmentalintegration 334.1 The environment: physical, biological and social aspects 334.2 Drivers for environmental change 36

Table of Contents

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4.3 Existing and emerging environmental threats 384.4 Principles for environmental integration 414.5 Environmental integration through different tools and instruments 434.6 The ecosystem services approach and its potential usefulness

in EIA 444.7 Practical element 46

5 Legal EIA background and EIA guidance in Pakistan 475.1 Environmental Policies 475.2 Environmental legislation 495.3 Pak-EPA’s Guidelines for IEE/EIA 535.4 Environmental guidelines and checklists by Provincial EPAs 555.5 Administrative set up for implementation of EIA related legal

provisions and guidelines 555.6 Environmental Tribunals 575.7 Problems in Implementation of EIA related Provisions of

Environmental Protection Act/ Regulations 585.8 Practical element 58

6 EIA requirements of the World Bank and the Asian Development Bank 596.1 Introduction 596.2 World Bank 606.3 Asian Development Bank: EA requirements and guidelines 616.4 EIA requirements of other development banks and organisations 646.5 Practical element 65

7 Screening / project categorization and scoping 667.1 What is screening and how is it done? 667.2 Checklists for screening and project categorisation for

IEE/EIA under Pakistani regulation 687.3 The rapid environmental assessment (REA) checklists of the ADB 717.4 Scoping - Purpose, objectives, guiding principles 737.5 How scoping is undertaken and the role of the public 777.6 Criteria of good practice, methods and techniques 797.7 Types of impacts to be identified 807.8 Establishing what baseline data need to be considered 817.9 Practical element 82

EIA Course Curriculum for Higher Education Institutions in Pakistan

8 Methods and techniques for assessment of impacts 838.1 Methods and techniques used for assessing impacts in EIA 838.2 The most frequently used EIA methods and techniques 848.3 Moderately used methods and techniques 858.4 Low usage of methods and techniques 888.5 Practical element 88

9 Public participation and consultation in EIA 899.1 Explain the key role of public participation and consultation

in the EIA process 899.2 ‘The public’ and ‘public interest’ 929.3 The public, stakeholders and their representatives 939.4 History and rationale of public involvement in EIA 949.5 (International) legislation pertaining to EIA and public

decision-making 959.6 Participation and consultation techniques and their

suitability for different situations 979.7 Public participation in Pakistan 999.8 Practical element 102

10 EIA baseline data collection, consideration of alternatives and mitigation 10310.1 What baseline data need to be collected and reported

on EIA 10310.2 Role of alternatives in EIA 10410.3 The importance of avoidance, mitigation, as well as

compensation measures 10710.4 Practical element 114

11 EIA reporting and EIA report quality review 11511.1 The EIA Report 11511.2 Focus of an EIA report 11611.3 Pakistan Guidelines for preparing environmental reports of

specific sectors 11711.4 The importance of EIA quality review 12911.5 EIA report quality review packages 12211.6 The EIA report in Pakistan 12311.7 Practical element 124



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12 EIA follow-up, monitoring and auditing; the role of environmental and social management plans 12612.1 What is EIA follow-up and why is it relevant? 12612.2 What is the rationale for EIA follow-up? 12612.3 Who should be involved in EIA follow-up? 12812.4 Regulations for EIA follow-up 12812.5 How to do EIA follow-up? 12912.6 The potential role of a follow-up programme / environmental

and social management plan and possible connections with environmental management systems 130

12.7 What are barriers and enabling factors for EIA follow-up and challenges 131

12.8 EIA follow-up, monitoring and auditing requirements in Pakistan 134

12.9 Practical element 144

13 EIA effectiveness – what do we need to consider in order to enhance positive and avoid negative effects 14513.1 Exploring effectiveness – terminology and conceptual

framework 14513.2 Effectiveness framework 14613.3 EIA effectiveness criteria 14813.4 Empirical evidence for EIA effectiveness 14913.5 How to support effective EIA 15313.6 Practical element 154

14 Introduction to SEA 15514.1 Introduction to SEA - what is it and how does it differ from EIA 15514.2 The SEA process 15714.3 Definition and potential benefits of SEA 15814.4 Focus of SEA and differences from project EIA 15914.5 Principles of SEA and different SEA approaches 16014.6 Case studies 16314.7 Practical element 178

15 SEA application at the policy level and in Pakistani planningprocesses 18415.1 Introduce policy level SEA 17915.2 Evidence for the effectiveness of SEA at the policy level 179


15.3 Present the specific challenges with applying SEA at policy levels of decision-making; the need to consider different policy situations 181

15.4 Case study: Renewable energy policy in Scotland. 18315.5 Planning system and processes in Pakistan 19015.6 Practical element 195

16 Developing EIA and SEA further: Integrating different aspects and sustainability assessments 19616.1 Rationale for integrating different aspects in assessment 19616.2 Potential problems of integration in assessment 19716.3 Possible Solutions for Integration of Economic, Social and

Environmental Aspects 19916.4 Real life integrated assessment systems 20016.5 Practical element 200

References 203



6EIA Course Curriculum for Higher Education Institutions in Pakistan

This introduction consists of two parts. First, the background to the developmentof the curriculum is described. Secondly, the course structure is explained.

1.1 Background to EIA course curriculumThis EIA course curriculum for higher education institutions in Pakistan hasbeen developed on the basis of a total of seven National Impact AssessmentProgramme (NIAP) workshops that were conducted between 2011 and 2013.A total of over 150 individuals were involved in these workshops, representingover 30 higher and tertiary level institutions, the Higher EducationCommission, Federal and Provincial EPAs, as well as various other privateand public sector organisations, institutions and companies. Workshopparticipants were actively involved in the development of the curriculum,providing ideas, suggestions and feedback on materials and proposals. Thefollowing workshops were held:1. 20th October, 2011 - (‘EIA curricula review’, Islamabad);2. 17th November, 2011 - (‘EIA curricula review’, Lahore);3. 26th November, 2011 - (‘EIA curricula review’, Karachi);4. 16th February, 2012 - (‘Strengthening of EIA curricula in tertiary level

institutions’, Islamabad);5. 13th September, 2012 - (‘Improvement of EIA curricula of tertiary level

academic institutions’, Islamabad);6. 5th November, 2012 - (‘Enhancing the relevance of EIA curricula in

Pakistani tertiary education institutions – towards closer linkages with thepublic sector, industry and practice’, Islamabad); and

7. 27th June, 2013 - (‘Towards a standardised EIA curriculum for Pakistanitertiary education institutions’, Islamabad).

Workshops 1 to 4 aimed at establishing a basic overview of current EIAteaching activities in higher education institutions in Pakistan. This includedidentifying those institutions that currently teach EIA and establishing theirteaching methods and techniques. The first four workshops were chaired byProf. Irfan Khan of the International Islamic University, Islamabad.

Workshops 5 and 6 involved empirical data collection exercises within atargeted NIAP assignment on the ‘Development of EIA curricula for highereducation academic and public administrations’. This assignment had thefollowing five objectives:1. To identify strengths and weaknesses of existing EIA curricula being

taught at tertiary level institutions in Pakistan;

1 Introduction

2. To support the development of EIA curriculafor these institutions, taking internationalresearch and best practices into account;

3. To identify the feasibility of including SEA inthe curriculum;

4. To prepare an action plan for implementationof different curricula; and

5. To advise on a comprehensive one-week EIAtraining curriculum for public administrationinstitutions.

Here, data were collected through:1. A pre-fifth workshop questionnaire survey

with 20 representatives of tertiary leveleducation institutions in Pakistan. Seventeencompleted questionnaires, representingsixteen institutions were obtained, i.e. theresponse rate was 85% (a total of 35institutions were identified to teach EIA, inone form or another);

2. An initial anonymous fifth workshop survey,using an audience response system (GeneeWorld). Depending on the question, up to 21workshop participants took part;

3. An evaluation exercise based on an ‘EALecturers’ Handbook’, which had beenproduced during an earlier EuropeanCommission Erasmus Mundus Project onenvironmental assessment higher educationin Europe and Asia (see www.twoeam-eu.net); eighteen workshop participantscompleted an associated evaluationquestionnaire;

4. Group work on three essential EA tertiarylevel education questions;

5. A short final fifth workshop survey, againusing the audience response system.Depending on the questions asked, up tonineteen workshop participants took part;

6. Feedback on the results of the data collectionexercises during the sixth workshop held on5th November, 2012, in Islamabad on‘Enhancing the relevance of EIA curricula inPakistani higher education institutions –towards closer linkages with the public sector,industry and practice’. Workshop participantsincluded 46 experts, representing tertiary level

institutions, national and provincial EPAs,private sector representatives, the nationalMinistry of Climate Change and other NIAPpartners; and

7. Some detailed reflections by nine EIA expertson a detailed second EIA curriculum outline,of which a draft had been introduced andcommented upon during the sixth workshopand which had subsequently been furtherdeveloped.

The results of these various exercises aredescribed in a NIAP Report ‘Development of anEIA Curriculum for Tertiary Level Institutions inPakistan - Baseline, Development Needs,Curriculum Outline and Suggestions for FurtherAction’ which can be accessed viahttp://niap.pk/docs/Knowledge%20Repository/Reports/ReportEIAeducationPakistanFischer.pdfOverall, representatives of 24 tertiary levelacademic institutions contributed in one way oranother to the various exercises.

The EIA course curriculum put forward here wasdeveloped in two main stages. A first draftversion was produced in May 2013. This wasthen commented on by numerous people, amongwhich were those attending the seventhcurriculum workshop in Islamabad on 27th June,2013. Taking the feedback thus received intoaccount, this final version of the report wassubsequently produced.

The EIA course curriculum is complemented byanother NIAP document, the ‘EIA Handbook forPakistan’. This handbook was preparedspecifically in order to share practicalexperiences of EIA applications in Pakistan with awide audience, providing numerous EIA casestudies that professors and lecturers should alsouse in their EIA courses.

1.2 Structure of EIA course curriculumThere are various options for the development ofan EIA curriculum for Pakistani tertiary levelacademic institutions. These range from curricula



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for e.g. full diploma degree programmes in EIA toa 2+0 lecture-based EIA course.

This document presents a generic curriculum,which can be adapted to different purposes. Thecurriculum consists of sixteen themes, eachconsisting of lecture and practice elements. Whileit can be readily used in a 16-week semester 2+1course, it can also be taught over e.g. two ormore courses.

Based on the results of the various surveysconducted with Pakistani representatives oftertiary level academic institutions introducedabove, it has been established that the overallcurriculum outline can be broadly in line with whatis considered to be good practice internationally.However, the specific content needs to be both,international as well as Pakistan specific. Thesixteen themes include the following: Theme 1: What is EIA, what is it trying to

achieve, what are its principles, whatbenefits can result from EIA ifconsidered in decision-making andwhere in the world is it applied?

Theme 2: Decision-making theory and practiceand EIA;

Theme 3: Main environmental problems that theinternational community and Pakistanare faced with;

Theme 4: Legal background and guidance onEIA in Pakistan;

Theme 5: Requirements of internationaldevelopment banks;

Theme 6: Screening / project categorisation andscoping;

Theme 7: Assessment of impacts; Theme 8: Public participation and consultation

in EIA; Theme 9: Baseline data collection and

presentation, identification of impacts,consideration of alternatives andmitigation in EIA;

Theme 10:EIA reporting and EIA report qualityreviews;

Theme 11:EIA follow-up, monitoring andauditing; the role of environmental and

social management plans;Theme 12:EIA effectiveness – what do we need

to consider in order to enhancepositive and avoid negative effects?

Theme 13:SEA part 1: Introduction to SEA;Theme 14:SEA part 2: SEA application at the

policy level and in Pakistani planningprocesses;

Theme 15:Developing EIA and SEA further:Integrating different aspects andsustainability assessments; and

Theme 16:Studying specific EIAs (guest lecturesby consultants/public servants).

All themes include lecture and practice basedelements. Theme 16 revolves around guestlectures by practitioners (consultant / publicservants). Guest lectures should reflect personalexperiences by practitioners and, therefore,cannot be prescribed. In this way this documentprovides the basis for themes 1-15 (chapters2 - 16), guiding the lecturer through one theme ata time, i.e. providing them with the baseline fortheir lectures. In this context, reference is madeto many other works, that complement theinformation given here.

The curriculum includes some case studies,mainly with regards to SEA applications.Numerous Pakistani-specific EIA case studies areintroduced in the NIAP ‘EIA Handbook forPakistan’. For this reason, this curriculum doesnot follow a case study-based approach for EIA.

Generally speaking, it is suggested that themes1-10 (chapters 2 to 11) are suitable for both,undergraduate and postgraduate levels (i.e.bachelors and masters levels). Themes 11-15(chapters 12 to 16), on the other hand, arethought to be particularly suitable for post-graduate teaching (i.e. masters levels). Themesixteen should feature in any EIA course. Many ofthe references and sources provided are web-accessible and are therefore easily usable. Someother, non-web-based key resources are,however, also provided.




This chapter consists of seven sections. First, definitions of EIA are provided.This is followed by an introduction to its principles. Thirdly, the origin anddevelopment of EIA are described before different types of impacts to beconsidered in EIA are introduced. Purposes, objectives, scope andeffectiveness of EIA are elaborated on and some of the different internationallegal, administrative and policy EIA frameworks are introduced. Finally,context specific elements that enable effective EIA application are defined.The main sources that this chapter draws on include Fischer et al. (2008;chapter 6 by Gazzola and Fischer: 42-57), Fischer (2005), IAIA (1999), UNESCAP (2003), UN University (2006 a; b; c) and UNEP (2002a).

2.1 Definition of EIA Environmental Impact Assessment (EIA) is a decision-making supportinstrument that aims at identifying, predicting, evaluating and mitigating thebiophysical, social and other relevant environmental effects of developmentproposals prior to major decisions being taken and commitments being made(IAIA and IEA 1999). It aims to (Gazzola and Fischer, 2008, p44):l ensure that environmental considerations are explicitly addressed and

incorporated into the development decision-making process; l anticipate and avoid, minimise or offset the adverse significant

biophysical, social and other relevant effects of development proposals;l protect the productivity and capacity of natural systems and the

ecological processes which maintain their functions; andl promote development that is sustainable, optimising both resource use

and management opportunities.

EIA is a legal requirement in well over 100 countries. Furthermore, in mostcountries where it is not legally required, it is either practiced voluntarily orintroduced through other requirements, e.g. by development banks (WorldBank, Asian Development Bank, etc.), meaning that there are experiences withEIA in most of the nearly 200 countries worldwide.

EIA is usually thought of as a process which involves consultation withstatutory and non-statutory bodies and general public participation. An EIA

2 What is EIA? What is it trying toachieve and what are its principles?What benefits can result from EIA ifconsidered in decision-making andwhere in the world is it applied?

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report is usually seen to be at the heart of theassessment process. This is the main documentproduced during an EIA which describes thelikely significant impacts and possible mitigationin detail.

However, in order to be an effective decision-making instrument, EIA needs to be seen asbeing more than a simple assessment process,namely an integral part of a planning system of awider environmental protection policy (Lawrence,1994). By establishing comprehensive baselinedata and by applying suitable assessmentmethods to assess environmental impacts, EIAaims at adding scientific evidence todevelopment planning processes, i.e. it also has asubstantive component. It has been suggested

that it can be considered a science and an art, asin that it attempts to combine a scientificapproach to assessment while accepting thepolitical nature of decision-making (Bartlett andKurian, 1999; Kennedy, 1988).

EIA should be pro-active, i.e. it should not onlyreact to development proposals, but shouldinfluence them early on. This way, its impact isnot reduced to just trying to mitigate givenimpacts, but rather to help avoid or reduceimpacts in the first place.

EIA should be tailor-made, i.e. it should bedesigned to suit the specific situation and contextin which it is applied. This means that e.g.specific geographical, societal, cultural, sectoral


Box 2.1: Different EIA definitionsEIA is:l “a technique and a process by which information about environmental effects of a project is

collected, both by the developer and from other sources, and taken into account by the planningauthority in forming the judgement on whether the development should proceed” (Department ofEnvironment, UK, 1989);

l “the systematic, reproducible and interdisciplinary evaluation of the potential effects of aproposed action and its practical alternatives on the physical, biological, cultural and socio-economic attributes of a particular geographical area” (USEPA, 1993);

l An instrument that “integrates the environmental concerns in the developmental activities right atthe time of initiating for preparing the feasibility report. In doing so it can enable the integration ofenvironmental concerns and mitigation measures in project development. EIA can often preventfuture liabilities or expensive alterations in project design” (Indian Ministry of Environment andForests; http://envfor.nic.in/divisions/iass/eia/Chapter1.htm);

l “an environmental study comprising collection of data, prediction of qualitative and quantitativeimpacts, comparison of alternatives, evaluation of preventive, mitigatory and compensatorymeasures, formulation of environmental management and training plans and monitoringarrangements, and framing of recommendations and such other components as may beprescribed” (Pakistan Environmental Protection Act, 1997);

l “the process of identifying, predicting, evaluating and mitigating the biophysical, social, andother relevant effects of development proposals prior to major decisions being taken andcommitments made (IAIA, 1999);

l “the systematic, reproducible and interdisciplinary identification, prediction and evaluation,mitigation and management of impacts from a proposed development and its reasonablealternatives (UNEP EIA Training Resources Manual, 2002); and

l “a governance instrument [which] introduces rules [...], assigning particular roles andresponsibilities to actors, [...]aiming to steer actors’ behaviours towards greater environmentalawareness, leading to the incorporation of environmental values in proposed activities and plans”(Arts et al., 2012).

Source: various

and other issues need to be taken into accountwhen applying it. There are numerous definitionsof EIA available. Box 2.1 lists a sample (followingUNESCAP, 2003 and Arts et al. , 2012).

EIA aims at achieving a number of things asfollows (adapted from UNEP, 2002a):l to provide decision-makers with an analysis

of all aspects of the environment so thatdecisions can be made based on as nearlycomplete and balanced information aspossible;

l to assess and present those effects that arenot adequately addressed by cost-benefitanalysis or other technical assessments(including e.g. risk assessment);

l to provide information to the public on aproposal;

l to formalise the consideration of alternativesto a project proposal so that the leastenvironmentally harmful means of achievingthe given objective can be chosen; and

l to improve the design of new developmentsand safeguard the environment through theapplication of measures to avoid and mitigateimpacts.

2.2 Principles of EIAIn addition to overall aims and objectives,principles for the application of EIA have also beendefined. These have been summarised by theInternational Association of Impact Assessment(IAIA, 1999) in terms of basic principles andoperating principles. Basic principles mean thatEIA should be (IAIA, 1999, p3):

Purposive: the process should inform decision-making and result in appropriate levels ofenvironmental protection and community well-being;

Rigorous: the process should apply “bestpracticable” science, employing methods andtechniques appropriate to address the problemsbeing investigated;

Practical: the process should result ininformation and outputs which assist withproblem solving and are acceptable to and ableto be implemented by proponents;

Relevant: the process should provide sufficient,reliable and usable information for developmentplanning and decision-making;

Cost-effective: the process should achieve theobjectives of EIA within the limits of availableinformation, time, resources and methods.

Efficient: the process should impose theminimum cost burdens in terms of time andfinance on proponents and participantsconsistent with meeting accepted requirementsand objectives of EIA;

Focused: the process should concentrate onsignificant environmental effects and key issues;i.e., the matters that need to be taken intoaccount in making decisions;

Adaptive: the process should be adjusted to therealities, issues and circumstances of theproposals under review without compromising theintegrity of the process, and be iterative,incorporating lessons learned throughout theproposal’s life cycle;

Participative: the process should provideappropriate opportunities to inform and involve theinterested and affected publics, and their inputsand concerns should be addressed explicitly in thedocumentation and decision-making;

Interdisciplinary: the process should ensure thatappropriate techniques and experts in therelevant bio-physical and socio-economicdisciplines are employed, including use oftraditional knowledge as relevant;

Credible: the process should be carried out withprofessionalism, rigour, fairness, objectivity,impartiality and balance, and be subject toindependent checks and verification;



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Integrated: the process should address theinterrelationships of social, economic andbiophysical aspects;

Transparent: the process should have clear,easily understood requirements for EIA content;ensure public access to information; identify the

factors that are to be taken into account indecision- making; and acknowledge limitationsand difficulties.

Systematic: the process should result in fullconsideration of all relevant information on theaffected environment, of proposed alternatives


Box 2.2: EIA procedural stages and what they meanScreening: to determine whether or not a proposal should be subject to EIA and, if so, at what levelof detail.

Scoping: to identify the issues and impacts that are likely to be important and to establish terms ofreference for EIA.

Generation of baseline data: to document the status quo and to establish the basis for assessingthe environmental impacts of the proposal.

Examination of alternatives: to establish the preferred or most environmentally sound and benignoption for achieving proposal objectives.

Impact analysis and impact prediction: to identify and predict the likely environmental, social andother related effects of the proposal.

Mitigation and impact management: to establish the measures that are necessary to avoid,minimize or offset predicted adverse impacts and, where appropriate, to incorporate these into anenvironmental management plan or system.

Evaluation of significance: to determine the relative importance and acceptability of residualimpacts (i.e., impacts that cannot be mitigated).

Preparation of an environmental impact statement (EIS) or report: to document clearly andimpartially impacts of the proposal, the proposed measures for mitigation, the significance of effects,and the concerns of the interested public and the communities affected by the proposal.

Review of the EIS: to determine whether the report meets its terms of reference, provides asatisfactory assessment of the proposal(s) and contains the information required for decision-making.

Decision-making: to approve or reject the proposal and to establish the terms and conditions for itsimplementation.

Follow-up: to ensure that the terms and conditions of approval are met; to monitor the impacts ofdevelopment and the effectiveness of mitigation measures; to strengthen future EIA applications andmitigation measures; and, where required, to undertake environmental audit and process evaluationto optimise environmental management.Source: adapted from IAIA (1999)

and their impacts, and of the measures necessaryto monitor and investigate residual effects.

Furthermore, there are operating principles.According to these EIA should be applied (IAIA,1999, p4):l As early as possible in decision-making and

throughout the life cycle of the proposedactivity;

l To all development proposals that may causepotentially significant effects;

l To biophysical impacts and relevant socio-economic factors, including health, culture,gender, lifestyle, age, and cumulative effectsconsistent with the concept and principles ofsustainable development;

l To provide for the involvement and input ofcommunities and industries affected by aproposal, as well as the interested public; and

l In accordance with internationally agreedmeasures and activities.

The EIA process is understood to consist of anumber of distinct stages. These are introducedin Box 2.2.

2.3 EIA origin and development EIA first developed in the USA with the NationalEnvironmental Policy Act (NEPA, 1969) being thefirst legislation internationally that includedrequirements for assessing the environmentalimpacts of a wide range of Federal ‘actions’,covering projects, policies, plans andprogrammes. A key reason for its introductionwas growing concerns about the quality of theenvironment in 1960, following the works of e.g.Aldo Leopold, in particular his book “A SandCounty Almanac” from 1949 and Rachel Carson,through her book “Silent Spring” from 1962.Concerns were fed by increasingly visible effectsof new technologies and ever-larger developmentschemes e.g. major motorway projects, such asthe New York West Side Highway project in theUS, and major industrial developments, as well asgeneral land degradation and contamination. Inthis context, it was recognised that the economicappraisal techniques that had already been used

for several decades e.g. benefit cost analysis,and that were applied to development proposals,did not consider environmental and socialimpacts of major projects.

NEPA was signed by the then US presidentRichard Nixon on 31st December, 1969. Itsintention was to use EIA as an ‘action-forcing’mechanism. It was hoped that it would changethe way in which government decisions weremade. Subsequently, many other countriesstarted introducing EIA, including Canada andAustralia in 1973 and 1974, respectively. InEurope, European Union (EU) Directive 85/EC/337made EIA for projects a requirement in all EUmember states which, at the time, includedfifteen member states and now 28.

Furthermore, many other countries startedintroducing EIA, including Pakistan in 1983 -Pakistan Environmental Protection Ordinance(PEPO). The Pakistan Environmental ProtectionAct 1997 (PEPA’97) replaced PEPO. EIA was thenstrengthened further through the 2000 EIAReview Rules. Provinces have released their ownlegislation. Generally speaking, EIA in Pakistan isdeveloped at national, provincial and local levelsof decision-making.

The development of EIA can be said to haveculminated in Principle 17 of the Rio Declarationon Environment and Development (UnitedNations Conference on Environment andDevelopment, 1992). This states that(http://www.un.org/documents/ga/conf151/aconf15126-1annex1.htm):

“Environmental impact assessment, as anational instrument, shall be undertakenfor proposed activities that are likely tohave a significant adverse impact on theenvironment and are subject to a decisionof a competent national authority.”

Over the past 40 years, EIA has also evolvedsignificantly, both in terms of theory and practice.In the early stages of EIA, only biophysical



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impacts were considered (e.g. air and waterquality, flora and fauna, noise, climate and water).Increasingly, other aspects were then alsoconsidered, for example, social, health, andeconomic aspects. While understanding ofprocedures and methods, as well as effectivenesscriteria has greatly improved since the early daysof EIA, there is still scope to further improve theinstrument. In particular, in current practice EIA isstill often used in a more reactive, rather thanpro-active way, and its impact is usuallymoderate, only (see e.g. Arts, et al. 2012). Thereare indications, though, that effectiveness hasbeen improving significantly over the past morethan 40 years in many countries and systems(Fischer, 2009; Phylip-Jones and Fischer, 2013).

The development of EIA can be summarised in anumber of time periods, as follows:1. Introduction and early development (1970-

1975): Foundations of EIA laid in the USNational Environmental Policy Act (NEPA);subsequently adopted by other countries,first by Australia and Canada; basic EIAprocedure and methods developed; this stillapplies today;

2. Increasing applications and advancement oftheory (mid-1970s to early 1980s): emergenceof more sophisticated methods (e.g. basedon quantitative modelling) and guidelines;impacts considered were extended to includesocial aspects; public enquiries and reviewstriggered innovations in EIA; the instrumentwas beginning to be used in developingcountries e.g. China, Thailand and thePhilippines;

3. Process strengthening and improvedintegration into planning processes; furtherincrease of application (early 1980s to early1990s): EIA practice and experiences startingto be reviewed; EIA frameworks weresubsequently updated and increased effortsfor improving integration with other processeswere made e.g, project appraisal, land-useplanning; ecosystem and cumulative effectswere considered and increased attention wasgiven to monitoring and follow-up; numerous

other countries started to adopt EIA,including e.g, Pakistan and the EuropeanCommunity; development banks also startedformulating requirements;

4. Increased integrated strategic andsustainability orientation (early ’90s to date):EIA enshrined in international agreements;rapid growth in international training,capacity- building and networking;development of strategic environmentalassessment (SEA) of policies, plans andprogrammes which has increasingly beenseen to be distinct from project EIA; EIAapplied in all OECD countries and largenumber of developing and transitionalcountries; and

5. Revival of interest in effectiveness of projectlevel EIA (since 2010), based in particular on40 years of NEPA and 25 years of EuropeanEIA Directive (special issue of the Journal ofEnvironmental Assessment Policy andManagement; 2012-14). Increasing researchon the effectiveness of EIA systems and theirdifferent components, including publicparticipation, quality of EIA reports andothers; renewed efforts to strengthen EIAsystems, their legal and institutionalframework, quality of EIA reports, reviewmechanism, consultants accreditation andEIA education (Fischer, et al., 2007).

2.4 Different types of impactsconsidered in EIAAn environmental impact can be understood as achange to the environment, which can be both,adverse (negative) or beneficial (positive), andwhich is wholly or partially resulting from humanactivities (e.g. construction, combustion,transport), products (e.g. cars, computers,furniture) or services (e.g. education, catering,retailing).Impacts can be short, medium or long-term, reversible or irreversible, and permanent ortemporary (Morris and Therivel, 2001). There areseveral types of impacts, including direct,indirect, cumulative, synergistic and residual.These are further explained in Box 2.3.


2.5 Purposes, objectives, scope andeffectiveness of EIAEIA is needed for a wide range of reasons and itsapplication is often thought of in terms ofdelivering certain benefits. Generally speaking, ifapplied in a transparent, rigorous and unbiasedway, EIA is thought to be able to (followingGazzola and Fischer, 2007, p46; see also Fischer,1999a and Dusik et al. , 2003):

l support decision-making and the formulationof development actions to achieveenvironmentally sound and sustainabledevelopment;

l strengthen project planning processes,helping to reconcile environmental, social andeconomic objectives and supporting moreenvironmentally sustainable outcomes;

l save time and money by avoiding costlymistakes and environmental impacts thatrequire expensive mitigation or remedialmeasures; and

l improve good governance and build publictrust, by providing key stakeholders the

opportunity to participate in the projectplanning process before a decision is made.

Besides the specific historical reasons describedabove, another reason why EIA was developed isa perceived failure of traditional projectassessment or appraisal techniques to takeenvironmental impacts into account. Generallyspeaking, without the application of EIA, projectsmay result in:l significant negative environmental change; l negative social effects; l higher development costs; and even inl a failure to deliver the project.

In line with a growing understanding ofenvironmental processes and problems, since EIAwas first applied over 40 years ago, impacts havebecome ever more complex and further reachingin their potential consequences. In practice, inmost countries throughout the world, EIA is stillapplied primarily to prevent or minimise theadverse effects of major development proposals,such as power stations, dams and reservoirs,



Box 2.3: Types of impact to be considered in EIAl Direct impacts: impacts of an action, intervention or of a specific project that occur in the same

space and time. Also known as primary impacts, they are the direct consequences that a projecthas on the environment;

l Indirect impacts: impacts of a chain of activities associated or induced by a project that oftenoccur later in time, affecting a broader area, but that are nevertheless reasonably foreseeable;

l Cumulative impacts: result from the incremental effects of an action when added to other past,present and reasonably foreseeable future actions. Cumulative impacts could result from anumber of minor impacts that individually have minor significance, and may therefore not requirean EIA. If assessed cumulatively, however, the impacts could have a higher significance and thenrequire an EIA;

l Synergistic impacts: impacts that result from the interaction among impacts of a project, or fromthe interactions among impacts of several projects within a same area that may be greater thantheir simple sum; and

l Residual impacts: the impacts that remains after implementation of the project and all associatedmitigation and other environmental management measures.

Source: Gazzola and Fischer (2007); see also Nunn (1979) and European Commission (1999).

16

industrial complexes, motorways, airports andothers. More limited forms of EIA can be used toensure that smaller scale projects conform toappropriate environmental standards or site anddesign criteria. Such projects include e.g. roadrealignments and upgrading, minor changeswithin existing developments or more small scaledredging.

An effective application is necessary in order forEIA to result in the benefits that are supposed toaccrue, as described above. In this context,effectiveness has been defined as “somethingthat works as intended and meets the purpose forwhich it was designed” (Sadler, 1996, p.37).Evaluating the effectiveness of EIA thus usuallyaims at establishing whether EIA is adding valueto project planning processes. Elements andprinciples for EA effectiveness have beendeveloped by a number of authors. They aresummarised in Box 2.4 (following Gazzola andFischer, 2007).

2.6 Different legal, administrative andpolicy EIA frameworks, internationallyEvery EIA system is unique and is the result ofparticular sets of legal, administrative and politicalcircumstances (Wood, 2003). Subsequently, a fewlegal, administrative and policy frameworks forEIA will be considered in countries where EIA isformally applied. The existence of formalrequirements should mean more than simplymentioning the possibility of applying EIA in aparticular system. Legislative or administrative

requirements should be in place, clearlyexplaining when EIA is required and what itshould involve.

Reviews of EIA systems worldwide have shownthat there are a number of ways and formalarrangements through which EA processes areapplied to decision-making (see e.g. Sadler, 1996;Barker and Wood, 1999; Wood, 2003). Individualarrangements are the results of differentinstitutional, legal and policy frameworks. Thesedefine context-specific rules and activities for EIAin different countries. As mentioned earlier, thereare now far more than 100 countries that haveintroduced EIA requirements formally (Lee andGeorge, 2000). Also, certain countries, e.g.federal countries, may have state or provincialEIA requirements. Examples include the USA,Canada, Australia, Germany, Spain and Pakistan.Subsequently, a few systems are brieflydescribed, following Wood (2003) and Gazzolaand Fischer (2007):l USA: the foundations of EIA lay in the US’s

1969 National Environmental Policy Act(NEPA) which is considered the MagnaCharta of EIA. More than 30 states haveintroduced other forms of EIA or haveenacted “little NEPAs”, with the Californiasystem being one of the most comprehensive(see Fischer, 2007). In practice, most NEPA-based assessments apply to projects;

l Canada: Together with Australia and NewZealand, Canada was a frontrunner to followthe USA’s example; all ten provinces and


Box 2.4: EIA effectiveness elementsEIA is effective when it:l includes proper and suitable methods for assessing impacts;l includes the formulation of alternatives, selection of a proposed alternative, and mitigation of

adverse impacts;l includes the placement of appropriate weight on environmental impacts relative to economic and

technical factors;l is fair and provides opportunities for public participation before a decision is made;l is central and contributes to decision-making;l is applied flexibly to the various stages of the EIA process; and l takes into account environmental and socio-economic factors.Source: Gazzola and Fischer (2007); based on Ortolano et al. (1987), CEARC (1988), Sadler (1996), Glasson (1999)

both territories now have their own EIAsystems. Informally established in 1973 andsubsequently developed further, the CanadianEnvironmental Assessment Act wasproclaimed in 1995, and subsequentlyamended several times (Wood, 2003). TheAct includes provisions for consideringcumulative environmental effects, mediation,follow-up, consideration of trans-boundaryeffects and the encouragement of publicparticipation (Wood, 2003);

l Australia: First introduced in 1974, Australia’sEIA system subsequently evolved further andin 1999 a new system was introduced, throughthe Environment Protection and BiodiversityConservation Act (EPBC). The aim was tocomplement the legislative and administrativeprocedures that the six Australian states andtwo territories had in place. The EPBC Actincludes provisions for SEA and the holding ofinquiries (Wood, 2003);

l New Zealand: EIA was first introduced in1974 on the basis of a cabinet minute andreformed in 1991 by the ResourceManagement Act, subsequently amendedseveral times. The Act introduced EIA as acentral element in decision-making andpromotes the sustainable management ofnatural and physical resources. EIA is definedas a comprehensive and flexible tool, as itapplies to all projects at the appropriate levelof detail, as well as to those policies andplans that are prepared under the Act;

l EU: The European Union (EU) has currently27 member states that have to comply withDirective 85/337/EEC on the assessment ofeffects of certain public and private projectson the environment, known as the EIADirective. This requires an EIA to be carriedout prior to the authorisation of developmentprojects likely to have significantenvironmental effects. It was initiallyintroduced to ensure that all Member Stateswere equally subjected to the samedevelopment restraints and conditions(Weston, 1997). But, once adopted, its mainobjective became the protection of the

environment and quality of life. The EIADirective was amended three times andbecame codified by Directive 2011/92/EU. Itapplies to two lists of projects. Annex 1projects require EIA for all cases. Annex 2covers development projects that are subjectto various criteria and thresholds set byindividual Member States. Consequently,although the procedural and methodologicalapproaches are to a certain extent commonto all Member States, the way in which theDirective is enforced and the type of projectsit applies to varies across the EU (Sheate,1996). For more information, seehttp://ec.europa.eu/environment/eia/eia-legalcontext.htm.

2.7 Context-specific elements thatenable effective EIA applicationThere are certain context-specific elements thatenable effective EIA application. FollowingFischer (2005), these include:l Providing formal requirements, clear

provisions and competences to conduct andeffectively consider EIA;

l Establishing clear, transparent and consistentvalue frames and expectations;

l Considering and influencing traditionaldecision-making approaches;

l Establishing a clear focus— addressing theright issues at the right time;

l Clearly defining roles of assessors andplanners;

l Achieving a willingness to cooperate inintegration;

l Acknowledging and dealing withuncertainties; and

l Providing appropriate funding, time andsupport.

Each of these is subsequently described infurther detail.

2.7.1 Providing formal requirements, clearprovisions and competences to conduct andeffectively consider EIAFormal requirements are the basis for EIA to beapplied in a consistent manner (Sadler, 1996).



18

Furthermore, explicit provisions to considerassessment results in decision-making showcommitment and are likely to be a key conditionfor effective EIA. Without formal requirements andprovisions, EIA is bound to be “toothless” andhighly sensitive to political struggles and powergames. Formal requirements give certainty to theactors involved in EIA and project planningprocesses (Partidario, 1997; Fischer, 2002).Provisions in the form of clear and establishedguidance help EIA to be routinely and confidentlyapplied (following Wilburn et al., 2004).Furthermore, provisions for regular internalreporting on EIA processes will help decision-makers and other actors to learn fromexperiences, thus advancing knowledge. Formalrequirements should ask for EIA to take results ofother prior assessments (e.g. of SEA) to be takeninto account (See: Tomlinson and Fry, 2002). ForCanada, Hazell and Benevides (1997) found thatassessments that were legally required by the1991 Farm Income Protection Act were “superior”to those prepared under the Federal CabinetDirective in that they were more effectivelyleading to a better consideration of theenvironment in decision-making. Anotherimportant aspect for effective EIA is an allocationof clear competences, which may not always beeasy to achieve if e.g, decision-making power issplit between different administrations.

2.7.2 Establishing clear, transparent andconsistent value frames and expectationsClear goals that are coming out of a commonbelief system provide guidance for EIA. In thiscontext, common expectations of what EIAshould achieve are important. Faludi (2000)suggested that “planning doctrines” or“paradigms” can act as normative or “value”frames (also called “policy frames” by Schön andRein, 1994). In this context, mega-objectives forplanners and assessors are needed. If there is noconsensus on underlying goals, planning hasbeen said to mean “endless argument, andreasoned choice becomes difficult” (Faludi, 2000,p.315). The existence of sustainable developmentstrategies and links to existing environmental

objectives that are accepted by all actors havebeen shown to be particularly useful (Wilburn etal., 2004).

2.7.3 Considering and influencing traditionaldecision-making approachesCompartmentalised organisational structures andbureaucratic prerogatives may be in the way ofeffective EIA application (see, for example,Diamantini and Geneletti, 2004). Therefore,careful consideration of decision-makingtraditions is of crucial importance for effective EIAapplication. Achievement of a full commitment byactors and stakeholders is, however, likely to takesome time. In order to avoid frustration aboutinitial EIA “failures”, it is therefore important thatactors involved in EIA processes are made awareof any potential problems and uncertainties.

2.7.4 Establishing a clear focus - addressingthe right issues at the right timeA clear focus is important for the effectiveapplication of EIA. The problem of boundarysetting in planning processes was recognised asearly as the 1950s. Simon (1957) established thatthere is often ambiguity about the boundaries ofthe problem for which a solution is to be found. Inorder to overcome confusion and disagreementwith the choice and form of alternatives, clear“framing” of the issues to be considered in an EIAis needed (Valve, 1999). Effective framing shouldhelp to create situations in which EIA actors donot only struggle to define the issues to beaddressed, but are actually dealing with thequestion what can be done to address them. Inthis context, the definition of clear and relevanttasks is of great importance.

2.7.5 Clearly defining roles of assessors andplannersIt should be possible to overcome cognitivelimitations, at least to some extent, ifenvironmental assessment (including EIA andSEA) systems are put into place that clearlyallocate tasks to different tiers of decision-making(See also: Chapters 14 and 15 on SEA). In thiscontext, the role of the assessor and planner maybe more clearly defined. Policy situations are


marked by a low degree of knowledge andconcreteness. Here, planners may findthemselves as policy mediators, supporting a“wide debate on overall objectives and values”. Inplan situations, planners may find themselvesacting as “entrepreneurs, advocating values andnorms, reflecting those formulated in higher tierpolicies”. In project and programme situations,there is often a high degree of knowledge andconcreteness. Planners may therefore act astechnicians, using previously defined stakeholdervalues in multi-criteria analysis and cost-benefitanalysis (Leknes, 2001; Fischer, 2003).

2.7.6 Achieving a willingness to cooperate inintegrationWhile integration is at the heart of any balanceddecision-making, so far there is no clear evidenceas to whether integration improves the position of“the environment” or whether it rather watersdown “weaker” aspects (See: Kidd and Fischer,2007). Integration requires trust and “acceptancefor the need to compromise, which may involveconcessions from all sides” (German Presidencyof the EC Council, 1999, p1). Insufficient politicalwill and a limited societal support base arebarriers to the effective application of EIA (Sadlerand Verheem, 1996). These barriers will take timeto overcome. Only if administrations, agencies,politicians and other decision-makers considerthemselves as real actors in the PPP process, is itlikely that they are going to be willing to get fullyinvolved. Power relationships need to beidentified, as integration is likely to bring actorswith differing powers together and those issuesthat are supported by powerful interests oftenreceive more attention. Furthermore, clearcommunication of assessment results isimportant, as participants’ awareness of howtheir decisions can influence the environment canincrease (See: Kaljonen, 1999; PIARC, 1999). Inthis context, experts need to present theirfindings in a way that makes sense to the policy-maker (Alton and Underwood, 2003; Cherp andAntypas, 2003). Organisational and politicalsupport and positive attitudes will increase thewillingness to cooperate in integration and are

important building blocks of effective SEAsystems (See: Sadler, 1996; Elling, 1998; Fischer,2002).

2.7.7 Acknowledging and dealing withuncertaintiesIt is important that actors involved in EIA aremade aware of and acknowledge thatuncertainties and unforeseeable impacts are likelyto occur in all EIA situations. Furthermore, allactors need to recognise that information aboutthe effects of alternatives and the possibilities ofmitigation are often going to be incomplete(Niekerk and Voogd, 1996).

2.7.8 Providing appropriate funding, timeand supportAppropriate funding, time and support are ofessential importance for being able to conductEIA in a meaningful manner. Sufficient time needsto be made available in the interest of reliableresults and effective consultation andparticipation. Appropriate support mechanismshelp PPP makers and assessors to deliver aneffective and efficient EIA process. Support canbe provided, for example, by suitable agencies,centres of expertise or coordination units(German Presidency of the EC Council, 1999,point 12). Other possibilities include advisorybodies that are jointly established by severalministries or departments, bringing togetherdifferent networks of experts and differentsectors. Finally, education and training areimportant.

2.8 Practical exerciseStudents are to research other decision-makingsupport tools and find out how they work,including e.g. cost-benefit analysis – CBA, multi-criteria analysis – MCA, life-cycle-assessment –LCA, technology assessment, risk assessment,generic modelling tools and others; studentsshould prepare a table as to how these differfrom EIA.




This chapter is sub-divided into six parts. First, EIA’s role as an advocacyinstrument in decision-making and recent integration attempts are discussed.Secondly, the roles of actors interacting in and through EIA are identified.Thirdly, organisational behaviour is explored. Decision-making models areintroduced and influences on effective decision-making are established.Finally, EIA as part of the decision-making process is elaborated on. The mainsources this chapter draws on include Fischer et al. (2008; chapter 10 byPosas and Fischer: 93-114), Morrison-Saunders and Fischer (2006) and UNUniversity (2006d).

3.1 EIA’s role to act as an advocacy instrument indecision-making and recent integration attempts The original purpose of EIA, following the US NEPA from 1969, was tosupport the consideration of the biophysical environment in decision-makingfor development proposals. In this context, Gibson (2001, p29) noted that EIA:

“has generally been viewed as a means of addingenvironmental considerations into predominantly financial,technical and political decision-making processes,encouraging some adjustments to the usual objectives inthe interests of avoiding serious environmental harm”.

EIA is not only a simple environmental protection tool, but an instrument forstrengthening environmental management processes. Furthermore, over thepast 40 years, EIA has been followed by the development of many otherforms of impact assessment, including, for example, health impactassessment, social impact assessment, risk assessment and others. Since thebeginning of the 1990s, EIA has also increasingly been used at strategic levelsof decision-making. Here, it has become known as strategic environmentalassessment (SEA).

Over the past 20 years, discussions have intensified on whether EIA shouldnot only focus on biophysical (and in this context, human health) aspects, butalso take account of social and economic considerations. In this context,there has been a growing interest in more integrated forms of assessment.This has led to the development of sustainability assessment (SA), whichseeks to integrate economic, social and environmental components.

Emerging evidence on whether integration in assessment leads to morebalanced decisions suggests that in many situations it may be preferable to

3 Decision making theory and practice

keep EIA as an advocacy environmentalassessment instrument. This was shown anddiscussed by e.g. Morrison-Saunders and Fischer(2006) for EIA and Tajima and Fischer (2013) forSEA. Similarly, Pope et al. (2004) argued thatintegration through sustainability assessment:

“can be seen to overly promote theprevailing economic agenda and therebyundermine 30 years’ worth of hard-wonenvironmental policy gains”.

The greatest concern from those who advocatethe consideration of environmental aspectsthrough EIA is that environmental impacts arebecoming increasingly traded-off for socio-economic gains. In fact, the increasing emphasison integrated assessment is seen by some (Kiddand Fischer, 2007):

“as part of an incremental erosion of theenvironmental focus within the field ofimpact assessment as environmentalconcerns are increasingly subordinated tobroader sustainability and governancedebates”.

Putting it somewhat more bluntly, Dovers (2002)asserted that:

“environmental and social issues matter,until it matters economically”.

Along similar lines, the Environmental ProtectionAuthority (EPA) of Western Australia suggestedthat:

“traditional thinking is generally based onthe model which sees the economy as themain game, with social and environmentalissues peripheral” (EPA, 2004).

Integrated forms of impact assessment may,therefore, simply serve to promote dominanteconomic perspectives over broadersustainability and environmental concerns(Scrase and Sheate, 2002). Integration of differentsubstantive (economic, social and environmental)aspects through EIA therefore has to be seenwith some scepticism. This will be discussedfurther in chapter 16.

3.2 Actors interacting in andthrough EIAEIA is a decision-making support instrumentwhich acts as a communication platform onwhich numerous actors come together andinteract. Regulators set the overall framework and



Figure 3.1: Actors interacting in EIA

Source: Posas and Fischer, 2008; adapted from Glasson et al. (1994)

22

monitor compliance with EIA legislation.Developers need to apply the instrument and aresupported by facilitators (i.e. consultants andadvisors). Furthermore, those potentially affectedare given an opportunity to comment or, if theyfeel impacts are unacceptable, to object. Figure3.1 shows the actors coming together in andthrough EIA (following Posas and Fischer, 2008;adapted from Glasson et al., 1994). These includethe developers and their facilitators (consultantsand other advisors). Furthermore, it includes theaffected parties (e.g. statutory bodies and thegeneral public). Finally, it includes those settingthe rules for planning and EIA, i.e. the regulators.

3.3 Organisational behaviourOrganisational behaviour is understood as thestudy of human behaviour in organisationalcontexts. The focus is both, on individual as wellas group behaviours (including processes andactions; see: Brooks, 2003). The study oforganisational behaviour developed in themanagement sciences. It however, has roots inmany traditional disciplines, including psychology,social psychology, sociology, anthropology,political science and economics.

There are different dimensions of organisationalbehaviour that can be allocated to micro, macro,and meso scales. Micro themes are psychologicalprinciples that govern the exercise of leadership,motivation, decision-making, negotiation, andcreativity. Macro themes consist of sociological,cultural and institutional factors shapingorganisational structures and systems, inter-organisational relationships, and networks. Finally,in between the micro and macro scales are“meso” factors, including teamwork, groupdynamics, and organisational culture (LondonBusiness School, 2007). There are threeoverarching themes in organisationalmanagement, including (Brooks, 2003):l the management of change, l communication, and l conflict.

These three areas influence an organisation’scompetitiveness and ability to meet its objectives.Overall, developing a good understanding oforganisational behaviour should enable those incharge of an organisation or, in the case of EIA, ofa decision process to,

“explain and predict human behaviour inorganisations and even control it ifappropriate” (Brooks, 2003, p2).

Generally speaking, a good understanding oforganisational behaviour can help decision-makers to optimise conditions for smootherprocesses and more effective outcomes.Subsequently, a selected number of theories andmodels that are relevant for EIA will beintroduced. These include theories of motivationand goal setting as well as SMART metrics.Furthermore, organisational learning and the roleof power are explored. Political processes andknowledge on how to support conflict resolutionare discussed and factors for the successfulconstruction of an environmental problem areintroduced.

3.3.1 Motivation, goal setting theory andSMART metricsTheories of motivation include Maslow’s hierarchyof needs. Developed in 1943, this model ofhuman motivation is based on a pyramid, whichhas physiological needs (food, water, shelter, andclothing) at the bottom of the hierarchy, followedby security needs, love and belonging needs,esteem needs, and finally at the top of thepyramid growth needs. The lower needs are themost powerful and instinctive. Maslow’s pyramidhelps explain why people, especially those inmarginal circumstances, are likely to supportoptions and alternatives that will help themmeeting their basic needs. With regards to EIA,what is of particular interest is that peopleaffected by projects may have an interest insafeguarding the environment, because theydepend on it for their basic needs (i.e. air, water,food, and shelter). Figure 3.2 shows Maslow’spyramid.


Goal-setting theory provides for anothermotivation-related model, which was developedfirst over 50 years ago by Locke. This conceptthinks of goals as being motivators. Five areasshould be considered when setting goals,namely: 1. goal clarity; 2. level of challenge; 3. commitment (buy-in); 4. feedback; and 5. task complexity.

Understanding these five areas can help makingEIA processes more effective. Feedback is seen tobe a particular important motivator. Commitment isconnected with the presence of values in manyprocesses, including cultural, religious and others.This implies that people are likely to perform betterwith regards to a goal if this is consistent with theirown values and personal standards. Finally,recognition and improved reputation is animportant motivational factor.

In management, the acronym SMART isfrequently used. This stands for goals andobjectives that are Specific, Measurable,Attainable (or Agreed), Relevant (or Realistic) andTime-bound. The ideas on goals and motivationpresented in this section should be born in mind

when designing EIA objectives, follow-up,monitoring and evaluation criteria. They can helpto motivate collaborators and relevantstakeholders.3.3.2 Organisational learningIn recent years, enabling individual, organizationaland wider social learning has increasingly beenportrayed as being one of EIA’s main roles. In thiscontext, many authors have drawn on Kolb’swork who saw learning as a continuous processof experience, reflection, and action. His model(See: Figure 3.3) is based on the belief thatpeople learn through their experiences. Kolb’smodel led on to studies on cognitive styles.These styles deal with the way information isorganised and processed. Subsequently, fourcognitive styles were identified that are linked tothe phases of Kolb’s cycle. These are (Brooks,2003, p35):l the activist (linked to concrete

experimentation); l the reflector (reflective observation); l the theorist (abstract conceptualisation); and

finally l the pragmatist (active

experimentation/testing)”.

To date, empirical evidence for the importance oflearning has been generated mostly for strategic



Figure 3.2: Maslow’s pyramid of needs

Source: following Maslow, 1943

24

environmental assessment (SEA; See: e.g. Jha-Thakur et al. 2009; Fischer et al. 2009). At a moreconceptual level, learning and EIA have beendiscussed by e.g. Diduck and Mitchell (2003) andSinclair et al. (2008).

Individual cognitive styles (these may beestablished through specific questionnaires) haveimplications for teams and on placing people inthe right (i.e. fitting) roles, in line with the needs ofan organisation and the environment. Whenteaching EIA, it is useful to bear in mind thedifferent learning styles of students. In EIApractice, for somebody who is in a facilitatingrole, it might also be important to bear in minddifferent learning styles and Kolb’s learning cycleto facilitate learning processes for different actorsand groups.

While there is no question that individualsconstantly learn, organisations sometimes do notappear to learn and to cope in a dynamicenvironment. Argyris and Schön (1978) broughtthe debate on organisational learning to adifferent level when they started to distinguishbetween single loop and double loop learning.They observed that most organisations appear tobe stuck in a process of single loop learningwhich takes goals, values, frameworks and

strategies for granted. Double loop learning, bycontrast, involves greater questioning of both, theorganisation’s objectives and methods. Doubleloop learning is necessary to identify errors andcorrect them. In order for double loop learning tohappen, however, individuals and groups need

“to be willing to discuss sensitive issuesopenly and to confront differences ofviews and seek ways of clarifying vagueand ambiguous ideas and data” (Brooks2003, p256).

Evaluating spatial plan SEA practices in the UK,Germany and Italy, Fischer et al. (2009)established the types of learning happeningthrough SEA. They found that while basic singleloop, instrumental learning, and here in particularknowledge acquisition and comprehension, wasroutinely happening, there was little evidence forany transformatory, double loop learning (See:Figure 3.4).

3.3.3 Making EIA an effective instrument -the role of powerDifferent sources of power have been identified.Following French and Raven (1959) these include: l Coercive power (threat of disciplinary action

or sanction);l Reward power (being rewarded with a benefit);


Figure 3.3: Kolb’s learning cycle

Source: Posas and Fischer (2008); adapted from Brooks (2003)

Observation and

reflection Concrete

experiences

Abstract conceptualisation Testing

l Expert power (possessing special skills orknowledge);

l Legitimate or position power (holding aformal position); and

l Referent power or charismatic authority(admiration or respect for an individual).

Further sources of power include e.g. control ofknowledge and information, control ofboundaries, control of technology, control of theinformal organisation, and interpersonal alliances(Morgan, 1986).

Robbins (1984) identified bases of power asmeans to exert influence. These include control ofbudgets and rewards, persuasion, rules andprocedures, physical presence or threat, andcharisma.

For the application of effective EIA, it is importantto know where power lies, as this determineswhat can be accomplished. In order for EIA tohave an impact on decisions, it should be astrong legal instrument. In this context, it is

important to remember that even a wellconducted EIA and participation process is

“not a substitute for the regulatory power,political will, and money required to getthings done” (Beierle and Cayford 2002,p.62).

Most economic development and e.g.infrastructure authorities are powerful bodiesrelative to others. In EIA, it can be important tohave those powerful players involved from theearly stages of the process. It is also important toremember, however, that a vital role of EIA oftenis to give a voice to less powerful stakeholdersand interests. This also requires having a goodunderstanding of power relationships to startwith.

3.3.4 Political processes and knowledge onhow to support conflict resolutionAn understanding of political processes andknowledge on how to support conflict resolutionare important when applying EIA as it is often



Figure 3.4: Possible types of learning happening through SEA

Source: Fischer et al. (2009)

Level ofunderstanding

Transformatory Learning --------------- Instrum

ental LearningEvaluation Know why

Questioningunderlyingprinciples

Changing valuesand behaviours

Know howAdjusting the

Plan

Know howAdjusting the

Plan

Know howAdjusting

responses to Plan

Knowhow

SingleLoop

LearningAdjusting SEAProcess

Adjusting SEAProcess

Adjusting inputto SEA Process

Know whyIntegrating

principles intoOrganisational

culture Changingnorms andpractices

Know whyChanging valuesand behaviours

Know whyDoubleLoop

LearningSynthesis

Analysis

Application

Comprehension (Development of individual/organisational capacity–initially likely to be a few ‘experts’)

(Legal/administrative/political procedures)

(Familiarity of terms and concepts)Know that

Knowledgeacquisition

Individual Organisational Social Types ofLearning

26

conducted in situations of conflict and in thepresence of power differences. Generallyspeaking, politics can be described as:

“a process of bargaining and negotiationthat is used to overcome conflicts anddifferences of opinion” (Daft, 1992,p.403).

Conflict often occurs when at least one partyfeels its interests have been frustrated. Conflictoften arises due to: l difference in status; l scarcity of resources (e.g. budget); l dependency on others; l the existence of winners and losers; and l cultural differences.

Conflicts can be avoided or accommodated andEIA may play an important role in this.Furthermore, if conflicts cannot be easily avoidedor accommodated, compromise may benecessary. Collaboration in order to resolveconflict is often seen as the most preferablesolution. Factors likely to influence how to besthandle conflicts include (Brooks, 2003, chapter8): l the time available to resolve the conflict; l the level of importance of the issue

stimulating the conflict; l whether one of the styles is more suitable to

the circumstances; and l issues of commitment, motivation and

precedence.

Since the early 1980s, EIA has been perceived as“a learning and negotiation process betweenmultiple actors” (Fischer 2003a, p.156) and recentstudies have called “resolving conflict amongcompeting interests” (Beierle and Cayford 2002,p.15) as one of the five most important socialgoals of the EIA public participation processes.Politics and conflicts are intrinsic to the EIAprocess, which is both scientific and technical,and also firmly embedded in a political and socialcontext. Particularly for controversial projects,conflict can be a significant issue in EIA. Effective

communication strategies are thereforeincreasingly seen as important for managing andfacilitating EA’s ‘multiple negotiation processes’between stakeholders and decision makers(Gustavo and Partidario, 2006).

3.3.5 Factors for the successfulconstruction of an environmental problemHannigan (2006) outlined six factors forsuccessful construction of an environmentalproblem, including: l Scientific authority and validation of claims;l Existence of ‘popularisers’ who can bridge

environmentalism and science;l Media attention in which the problem is

‘framed’ as novel and important;l Dramatization of the problem in symbolic and

visual terms;l Economic incentives for taking positive

action; andl Recruitment of an institutional sponsor who

can ensure both legitimacy and continuity.

For issues that may not have powerful advocates,such as particulate levels in city air, knowledge ofthe factors may assist in helping to give strongercredibility or drawing attention to them. While anEIA process may not necessarily be doing allthese things, bearing them in mind may helpcommunicate the importance of an issue both,among decision-makers and the public.

In public participation processes, it might behelpful to structure communication along some ofthese lines, i.e. mention scientific authorities andtheir claims, reference popularisers and mediaattention to specific issues, consider how todiscuss problems in symbolic and visual terms.

3.4 Decision-making modelsOne of the main purposes of EIA is to act as adecision-making aid, and as a consequence it isoften defined as a ‘systematic decision supportprocess’ (i.e. Fischer, 2007, p.xiii). Thoughfrequently ‘the decision’ in EIA is portrayed asoccurring between the EIA review and postdecision-making stages, in reality it consists of


many implicit and explicit decision moments(Pischke and Cashmore, 2006) that cover theentire process. In fact, EIA is understood toinfluence decisions in three main ways, including(Fischer 2007, p.17-19): l providing better information; l enabling attitudes and perceptions to change

through participation and involvement; and l changing established routines over a longer

period of time.

In theory, decisions are made via an uninterruptedlinear process that results in rational solutions..Yet in practice, things do not always go that way.Subsequently, four key models of decision-makingthat are of relevance for EIA are thereforeexplored. Then the various influences ondecisions that assessors should be aware of arediscussed. Finally, some generic decision aidsthat may be helpful to anyone involved with EIAprocesses are considered (See: Box 3.1).

3.4.1 Four key decision-making models ofrelevance for EIA

There are four key decision-making models thatare of relevance for EIA. These include: l the rational model; l the bounded rational model; l the garbage can model; and l the political or coalition approach to decision-

making.

In the first – the rational – model, decision-makingis understood as a rational, linear process thatwill produce rational outcomes. It is used toexplain microeconomic behaviour and is theaccepted model in many disciplines up to thepresent. The steps in rational decision-making areas follows (Brooks, 2003, p.36): 1. identifying a problem that requires a decision; 2. gathering information and materials that will

help solve that problem; 3. `generating potential solutions to the problem;

and 4. making a rational choice, selecting the best

solution, and then implementing it.

The rational model is a logical normative model.The main difficulties with it lie not with themodel’s process, but rather with its underlyingassumptions. Thus, the model implies that aperson will:

“always make a rational decision basedon the ability to evaluate all thealternatives and effectively calculate thepotential success of each alternative(Brooks, 2003, p.36).”

In addition, it suggests that the decision is beingmade in a stable, slow-moving environment andthat the decision-maker has ample time to gatherall the information, reflect on all the alternatives,



Box 3.1: Decisions made throughout the EIA Process

Source: based on Weston (2000, p.186)

EIA stage Questions requiring decisionsScreening Is the project one for which an EIA is necessary?Scoping What environmental impacts need to be examined?Prediction What is the size, magnitude or extent of the impacts?Assessment Is the impact significant?Mitigation What can be done to reduce the impact?Review Are the assessment and the environmental statement adequate?Decision Should the project be authorised to proceed?Monitoring andauditing Was the prediction of impacts accurate and do the mitigation measures work?

28

and reach a rational solution. The logical steps inthe model are reminiscent of the EIA process.

In practice, some routine decision processes maynearly follow a rational approach (Butler, 1991).Quite a number of decisions (including many inEIA) however, face more pressures and unknownsthan this model’s assumptions allow for.

This is why the concept of bounded rationalitywas introduced by Simon (1957). This addressesthe rational model’s potential weaknesses andincongruence with many decision-makingcontexts, which are not benefiting from unlimitedtime and perfect information. The boundedrationality model has been shown to be moreconsistent with the way those driving andmanaging processes behave (Brooks, 2003). Inreality, there are often time pressures andimperfect information, causing decision-makersto find solutions that will ‘satisfice’. These maynot necessarily be the best solutions, though.While the rational model can at times explainmore routine decisions, the bounded rationalmodel is more suited to explain unfamiliar, non-routine, and potentially contentious issues (Butler,1991). Its six explicit assumptions are listed inBox 3.2.

The third model is the ‘garbage can model’(Cohen et al., 1972), which is different from thetwo rationality based models in that it is not asequence of steps, starting with a problem andending with a solution. Rather, this model

proposes four independent streams, whichinclude problems, solutions, participants, andchoice opportunities. An organisation acts as a‘garbage can’ in which these streams flow. Adecision will be made when problems andsolutions can be connected during a time whenthere are choice ‘opportunities’ (to be made byindividuals). This model is more random and likelyto be of relevance for volatile processes orenvironments (Brooks, 2003). Butler (1991) notesthat organisations following this model exhibitseveral features, including: l ambiguity in the decision-making process; l difficult to determine cause and effect

relationships; and l fluid participation (i.e. turnover of

participants).

The garbage can model can represent an aptdescription of government policy-making.According to Kingdon (1995) in order for a policyto be successfully implemented, there needs tobe a policy window in which problems, policy,and politics converge (See: also Fischer, 2004).The garbage can model and Kingdon’s policywindow concept are often invoked in the contextof higher levels of decision-making, i.e. in thecontext of policy SEA (World Bank, 2005).

Finally, the political or coalition model oforganisational decision-making was put forwardby Cyert and March in 1963. They viewed theprocess of organisational decision-making as


Box 3.2: Assumptions of the bounded rational model

Source: Adapted from Butler (1991, p.47)

1. Managers respond to problems rather than going out of their way to find them.

2. Cognitive limits exist in the search process - human mind is limited in comprehension of problem.

3. Time pressures frequently apply (decisions have to be made with incomplete information).

4. Disjointed, incremental decision-making often occurs, not a smooth, continuous, rational process.

5. Intuition and judgment may have to be the basis for making a decision rather than computation.

6. Satisficing (satisfactory and ‘will do’) solutions rather than optimal solutions are arrived at.

“involving shifting coalitions of interestsand temporary alliances of decision-makers who can, for the purposes of adecision, come together and sufficientlysubmerge their differences to make adecision” (Butler, 1991, p51).

A coalition may be formed for just one decision,though some quid pro quo and bargaining is likelyto be involved. This kind of decision-making hasbeen known to occur in government contexts.

3.4.2 Choosing the right methodologicalapproach to running EIA

As was explained above, different decisiontheories and models may be applicable todifferent decision-making situations. In particular,the structuredness of a specific decision-makingsituation may help to define an associated actingstrategy. This has been said to depend on theuncertainty of (a) objectives (i.e. what it is that issupposed to be achieved); and of (b) the meansor methods to achieve something. Thecontingency model of organisational decision-making (Thompson and Tuden, 1956) charts thefour decision-making models introduced aboveand assigns them to a specific decision-makingsituation. In this context, it suggests the type oforganisational context for which all of them mightbe appropriately applied (Figure 3.5).

Models of decision-making, particularly therational model, are closely tied to much of therecent theory debates on EIA, including thestructure or flexibility debate mentioned above.EIA’s procedural origins are rooted in rationalplanning theory, which was developed in the mid-1950s and extensively discussed and spread inthe late 1960s and early 1970s (See: Faludi,1973; Fischer, 2003). Some authors have usedthis understanding to argue that EIA processesshould be flexible rather than rational or rigidlystructured. One criticism that could be made ofthis debate, however, is the relatively poor level ofarticulation of which elements of the processshould be flexible. A second criticism relates tothe lack of rigorous testing of whether a flexibleapproach gives better results and in whatcontexts (Fischer, 2007).

Philosophically, the rational model and thedeviations from it have sparked debate aroundHabermas’ notions of ‘communicative rationality’and ‘ideal speech’ which reflect rationalnormative ideals. Habermas’ contextual ideals arenotoriously difficult to attain due in large part tothe existence of power disparities among actors(Flyvbjerg, 2001). In the philosophical and EIAliteratures, Habermas’ ideas are typicallycontraposed to Foucault’s conceptions of power(i.e. Flyvbjerg, 2001; Fischer, 2003a), thoughHealey (2004) goes a long way in establishing the



Figure 3.5: Contingency model of organisational decision-making

Source: Posas and Fischer (2008), based on Butler (1991, p.59) and adapted from Thompson and Tuden (1956)

EndsUncertainty

MeansUncertainty

Computationrationalcrisp

Bargainingcoalitionfuzzier

Inspirationgarbage canfuzziest

Judgementbounded rationalfuzzier

30

complementarities of these two philosophers’ideas. In this regard and relating to EIA beingseen as a rational technical vs. deliberativeinstrument (Owens et al., 2004), there has beenmuch discussion of the role of power and valuesin the EIA process and associated decision-making (Richardson, 2005; Connelly andRichardson, 2005; Wilkins, 2003). Frictionbetween communicative planning theory basedon Habermas’ ideas (See: Healey, 1996; 1999)and rational planning theory has been continuingto influence the EIA world and is still an importantelement of the professional debate (See: Fischer,2003a; Tewdwr-Jones and Allmendinger, 1998).More care in use of terminology may helpsharpen and clarify the debates. For example,people often use the term ‘rational’ when theyreally mean ‘systematic’, a term which ultimatelydoes not invite the same level of controversy.

3.5 Influences on effective decision-makingThe model of bounded rationality introducedabove identified some of the key constraints ondecision-making and rational approaches towardsit, including time pressures and incompleteinformation. Hammond et al. (2002) identifieduncertainties, risk tolerance, and links to futurechoices as critical factors that influencedecisions. Brooks (2003, p.37) singled out whathe called ‘cognitive biases’ as compromising “therationality and objectivity of decision-making”.Cognitive biases are distortions in thinking thatcan develop in an individual’s cognitive structureover time and are influenced by beliefs, attitudes,values, and the person’s own personality.Cognitive dissonance means there isinconsistency between a person’s beliefs andactions. While this may be observed in practice,cognitive biases are more common and lessnoticeable for most people. Common cognitivebiases include e.g. the illusion of control, wherean individual believes he or she can handle acomplex problem but in fact cannot. Furthermore,they include status quo biases, i.e. a tendency toprefer that things stay relatively the same. Also,they include the so-called ‘bandwagon effect’

and ‘groupthink’, representing a tendency to door believe the same things as others do. Finally,they include what has been called ‘professionaldeformation’, namely a tendency to look at thingsonly according to the conventions of one’sprofession, forgetting broader points of view.Cognitive biases can thus decrease the quality ofdecisions and decision-making.

Decision-making is inherent in and frequentlyrequired throughout the EA process. Decisionsmust be made relating to project scope, approval,implementation, evaluation and follow up, amongothers. EIA is a specific ‘systematic decisionsupport process’ (Fischer, 2007, p.xiii) aimed at(a) helping reduce or mitigate negativeenvironmental impacts, (b) enhancingenvironmental opportunities, where possible, and(c) producing more environmentally and sociallysustainable outcomes. But there are also othermore generic aids for decision-making that canbe utilised by all parties in the EIA process. A fewof these from organisational behaviour andmanagement will be introduced below, followingdiscussion of criteria for effective decision-making processes.

Hammond et al. (2002), in their book SmartChoices, propose that an effective decision-making process fulfils six criteria. These arepresented in Box 3.3.

They then introduce a ‘PrOACT approach’ whichrelates to the Problem, Objectives, Alternatives,Consequences, and Trade-offs of decision-making situations and that looks similar to atraditional EIA approach. They devise strategiesfor decision-making that are connected with theconsideration of uncertainty, risk tolerance, andlinked decisions.

3.6 EIA as part of the decision-making process Following on from what has been said above, EIAis part of a larger process of decision-making toapprove major proposals. The resulting decision isbased on information from a number of different


sources. In the context of decision-making, a largenumber of trade-offs are normally made. In thiscontext, a balance should be struck betweenvarious benefits and costs. Environmental,economic and social elements should be weighed,and uncertainties and arguments over thesignificance of risks and impacts should beaddressed. In this context EIA plays an importantrole. The different factors that will be of importancein the final approval of a proposal include: l findings of significant impact contained in the

EIA report; l inputs from economic and social appraisals;

and l other external pressures or political inputs to

decision-making.

As discussed above, EIA is not the onlyassessment instrument used in decision-making.Rather, it is usually applied next to economic andother (social, equality and others) appraisal. Inpractice, this means that the decision madeinvolves trade-offs and may not represent themost environmentally friendly choice. Frequently,environmental considerations carry less weightthan economic issues (See: Fischer, 2003a). Animportant question in this context is whether EIAshould be neutral or rather act as an advocacyinstrument for the environment. The predominantview is that the role of the EIA practitioner is to(following UN, 2006c): l “provide a clear, objective statement of the

environmental impacts and their mitigation; l bring the feasible alternatives and the

environmentally preferred option to the

attention of decision-makers; and, morearguably

l give contestable advice on the environmentalacceptability of the proposal (for example,whether it can be justified in thecircumstances)”.

EIA should enable the input of a wide range ofexternal views and interests into the developmentproject planning process. In this context, it isimportant that many development proposals, inparticular those that are large scale, arecontroversial and encompass a wide range ofissues on which opinion can be divided.

3.7 Practical elementStudents should discuss how public decisionsare made in Pakistan; furthermore, a role-playshould be conducted around decision-making;the suggestion here is to focus on tourismdevelopment in a hypothetical country. While theconcrete outline is for the lecturer to prepare, apossible case could be organised as follows(following a personal communication with AlehCherp from Central European University in 2008):l Think up a hypothetical country, where one

part is fairly well developed and the other isnot; prepare a map with features (mountains,coastline, archaeological sites, sensitiveenvironments, such as wetlands or deserts,towns and infrastructure).

l Use an assumed interest of a developer tobuild a number of big hotels near thecoastline as the basis for your case study;the developer wants to have the hotels near



Box 3.3: Six criteria for an effective decision-making process

Source: adapted from Hammond et al. (2002, p.4)

An effective decision-making process:l Focuses on what is important;l Is logical and consistent;l Acknowledges both subjective and objective factors and blends analytical and intuitive thinking;l Requires only as much information and analysis as is necessary to resolve the particular dilemma;l Encourages and guides the gathering of relevant information and informed opinion; andl Is straightforward, reliable, easy to use, and flexible.

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the coast in an environmentally sensitive areain the less developed part where a largeproportion of people leading traditionallifestyles (indigenous people) live.

l Divide the student cohort into differentgroups which represent national ministries ofe.g. economic development, environment,indigenous people and infrastructure.

l Each of the student groups should discussthe developer’s proposal from the point ofview of the ministries they represent andshould think of ‘counter’ or amendedsuggestions, keeping in mind the importanceof the developer investing in the country.

l Spokespersons’ of the ministries are then toget together and discuss the developmentand their own ‘counter’ / amendedsuggestions in front of all students and try tocome up with a solution that everyone canagree on. The lecturer is to take on the role ofthe country’s president, who needs to beconvinced!

l All students are to reflect on the exercise interms of issues of decision processes, powerand environmental issues; how could EIAhave facilitated this process?




This chapter is sub-divided into six sections. First, physical, biological andsocial aspects of the environment are explored. Then, drivers forenvironmental change are introduced. Existing and emerging environmentalthreats are elaborated on before principles for environmental integration areestablished. In this context, ecosystem services are also covered. Finally,different tools and instruments for environmental integration are introduced.The main sources this chapter draws on include Fischer et al. (2008; chapter7 by Gazzola: 58-69), UNEP (2012), and the UNEP’s Millennium EcosystemAssessment (2005).

4.1 The environment: physical, biological and social aspectsThe term environment is usually understood to include physical, biologicaland social environments. The physical environment refers to theearth/atmosphere system, the biological environment to the biosphere orecosphere (also called living environment), and the social environment to theindividuals living in a certain area. All three environments are interlinked andare affected heavily by economic activities. Environmental problems oftenoccur because society fails to appreciate the interrelationships between thethree environments. Subsequently, the three environments are exploredfurther. All three of these can be divided into ‘micro’ and ‘macro’ levelenvironments, with the former representing localised aspects within e.g. aspecific land parcel, and the latter representing wider regional or evenglobalised aspects.

4.1.1 The physical environment The physical environment includes three components: (1) lithosphere, i.e. the solid inorganic part of the earth’s surface; (2) atmosphere, i.e. the gaseous layer of air surrounding the earth; and (3) hydrosphere, i.e. the various waters on and in the earth’s surface.

The physical environment is the basis for both, biological and socialenvironments and the three components are closely interlinked with eachother. They are further described below.

4 Main environmental problems theinternational community and Pakistanare faced with and instruments forenvironmental integration

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Lithosphere: The lithosphere is the earth’s crusttogether with the underlying rigid part of theearth’s mantle. It is thin beneath the oceans andthick under the continents. The continents havecommon structural features, including shields,folded mountains and plains (Klein, 2002).l Shields are exposed areas of ancient, stable

continental rocks. They are often buried byyounger sediments. Shield areas have mineralpotential, the extraction of which has led tomany environmental problems.

l Folded mountains develop through collisionof continental plates. The collision forcessedimentary rocks upwards and foldsdevelop. Mountain areas are subject to arange of economic uses, including e.g.mining, forestry and hydroelectric powerproduction. Furthermore, they tend to bepopular for tourism. These activities havedeteriorated many mountain areas.

l Plains are composed of sediments erodedfrom nearby shields or mountains anddeposited in sedimentary basins. Thesediments of plains can contain commerciallyvaluable resources, including e.g. coal,petroleum and building materials, such aslimestone and sandstone. Furthermore, plainsare important for agriculture, industry andhuman settlements, all of which are impactingon them.

Atmosphere: This is the layer of gasessurrounding the earth, which is being retained bythe earth’s gravity. The atmosphere consists of78% nitrogen and 20.95% oxygen. Furthermore,0.93% of the atmosphere is made up by argon,0.04% by carbon dioxide and some further tracesof other gases. In addition, the atmosphereconsists of 1% water vapours. Oxygen andnitrogen are essential for any life on earth.Oxygen is absorbed by animals and humansduring respiration in order to generate energythrough combustion and metabolism.Additionally, oxygen also takes the form of ozone,which protects the biosphere from excessultraviolet radiation. Nitrogen is a basic unit of lifewhich can be found in DNA (genetic material),

proteins and amino acids. The atmosphere’snitrogen levels are maintained by a complexcycle, through processes of de-nitrification(putting nitrogen into the air) and nitrogen fixation(the conversion of gaseous nitrogen intoammonia, nitrite and nitrate). Human activitiesdisrupt nitrogen cycles, causing e.g.eutrophication and ozone depletion. Carbondioxide and other gases are very important,despite their small volume (0.04%). Carbondioxide is essential for life on earth, because ofits role in photosynthesis and contributions to thenatural greenhouse effect. From time to timesulphur dioxide, oxides of nitrogen, hydrogensulphide and carbon monoxide becomeconstituents of the atmosphere, causing pollution,photochemical smog, global warming and acidrain.

Hydrosphere: The hydrosphere includes waterfrom the oceans, seas, rivers, lakes, groundwater, water vapour and droplets, as well as thewater contained in the living elements of thebiosphere. As much as 97% of the world’s wateris in the oceans, which support large populationsof marine plants and animals. Despite the smallamount of fresh water (i.e. 3%), terrestrial floraand fauna survive due to the natural recycling ofwater through the hydrological cycle. Thisincludes evaporation, condensation andprecipitation. While the hydrological cycle is aclosed cycle (i.e. human activities cannot depletethe entire system), excessive withdrawal fromrun-off or ground water can create localshortages. Due to the intensity of human waterusage globally there are water quality andquantity problems worldwide.

4.1.2 The biological environment The biological environment is also called theliving environment. This incorporates aspects ofthe lithosphere, atmosphere and hydrosphere andis referred to as the biosphere, which includessoil, plants and animals, ecosystems and biomes.l Soil is linking abiotic (non-living) and biotic

(living) components and consists of a mixtureof mineral and organic matter, air and water.


Compositions vary in time and place.Understanding the characteristics of a specifictype of soil can help deciding what type ofactivity an area of land can best support. Thisis known as land capability or land suitability(For more information, see: Food andAgriculture Organisation - FAO, “Landevaluation for development”, available athttp://www.fao.org/docrep/U1980E/U1980E00.HTM).

l Plants and animals: All plants have commoncharacteristics. Terrestrial plants areconnected with the soil by their roots.Besides providing stability they allow plantsto absorb moisture and nutrients, supportinggrowth. Photosynthesis is the process bywhich light energy is converted into chemicaland food energy. This process is offundamental importance to animal andhuman life on earth. Agricultural activities anddeforestation are reducing the amount ofphotosynthesis taking place. This is one ofthe causes for the rise of carbon dioxidelevels, thus contributing to global warming.Different plants have different physical needs.These are related to a combination ofdifferent aspects and include climate, inparticular temperature and precipitation.Furthermore, they include water, i.e.precipitation evapotranspiration (the sum ofevaporation and plant transpiration) and soilmoisture. Soil is important with regards to itstexture, fertility, acidity and maturity. Finally,other biotic factors play an essential role,through e.g. allelopathy, the phenomenon bywhich an organism produces bio-chemicalsthat influence other organisms, and animalactivities. Animals and humans areheterotrophic, i.e. they depend on greenplants (food) to survive. Most animals aremotile, i.e. they are capable of spontaneousmovement. This is important, because itallows them to look for those environmentalconditions that are most suited to theirneeds. Many animals can migrate, ifnecessary. While animals can adapt in orderto survive e.g. severe environmental

conditions, there are also restrictions due totheir dependence on plants.

l Ecosystems and biomes: The termecosystem refers to the combination of bioticand abiotic components (following Tansley,1935). There are terrestrial and aquaticecosystems. The former incorporatescontinental flora and fauna and the landsurface they occupy. The latter refers to salt-water and freshwater communities, includingthose in coastal and interior wetlands.Ecosystems are inhabited by different typesof organisms, depending on the area’sphysical conditions and geography.Ecologists use the term habitat to defineareas where certain species can be found.Organisms fulfil certain ecological roles and inturn often depend on specific ecologicalniches. A habitat may, thus, indicate wherecertain species live, including whom theyinteract with and by which species they areconstrained by. Within a specific niche, anorganism makes use of the set of conditionsthat are best suited to its survival. Changes inthese conditions can threaten its survival, aswell as potentially the integrity of the wholeecosystem. Groups of ecosystems that definelandscapes, including those made byhumans, form larger regional units which arecalled biomes. Biomes can be terrestrial andaquatic and represent a developedcommunity of plants and animals. Thesedepend on certain environmental conditionsin a given time and space. Terrestrial biomesinclude tropical rain forests, tropicaldeciduous forests, tropical savannahs,deserts, Mediterranean scrub forests,temperate grasslands, temperate mix forests,boreal forests, mountains, and tundra. Thereare transition zones between biomes withcharacteristics of both. These transitionzones are called eco-tones. Aquatic biomesare divided into marine and freshwatercommunities. Depending on their depth orproximity to the shore, they can be furthersubdivided into eco-zones.



36

4.1.3 The social environment The term ‘social environment’ encompassesorganisations of individuals and populations. Inthis context, how species and individuals react toone another is of importance as well as how theygrow. A population is usually defined as a groupof organisms of the same species which occupiesa given space (Odum, 1989). It can be describedin terms of density, dispersion (i.e. random,uniform or clumped), age distribution, geneticfitness or persistence. Population growth ratesare the net result of births, deaths and theirdistribution over a certain geographical area (i.e.their dispersal). With regards to forms of growth,organisms are divided into r-strategists and k-strategists. The former include organisms, suchas insects and small mammals. These have areproductive strategy that allows them to respondto changing conditions that favour them. They arecharacterised by small size, with relatively shortlifespans during which they produce largenumbers of offspring. The latter are usually largeorganisms, including humans and largemammals. They have relatively long lives andproduce only a limited number of offspring. Theyinvest considerable time and energy providing forthe survival of these off-springs, so that they canensure the continuation of the species. Theysurvive best under stable environmentalconditions. Human populations are oftenportrayed as going through a series of sequentialstages of development, including (Molnar andMolnar, 2000):(1) high stationary; (2) early expanding; (3) late expanding;(4) low stationary; and (5) declining.

Each of these stages can be associated withcertain socio-economic and cultural changes e.g.migration, industrialisation, urbanisation andtechnological progress. Changes result inchanging relationships between society and theenvironment, and increasing degrees ofcomplexity. Between 1999 and 2013, 98% of theworld’s major population growth has occurred in

the developing world, i.e. in nations that arealready facing serious socio-economic andenvironmental problems. In Pakistan alone, duringthese 14 years, the population has grown fromabout 131M to over 180M. Understanding therelationship between population growth andenvironmental deterioration is key for tacklingtoday’s environmental problems. The combinationof exponential population growth with theadvances in technology that have increased thedemand for resources has radically changed therelationship between human beings and their life-supporting environment.

4.2 Drivers for environmentalchangeThe main drivers for environmental change areconnected with population growth and economicdevelopment, mainly through the pressures theseexert with regards to energy, transport,urbanisation and globalisation. The global humanpopulation reached seven billion in 2011. It isexpected to grow further to reach ten billion by2100 (UN, 2011).

There are several reasons for the growingpopulation. While global birth rates remain abovethe global replacement fertility rate, fertility isdeclining in almost all countries. At the globallevel, the crude birth rate fell from 37 births perthousand in 1950–1955 to 20 per thousand in2005–2010 (UN, 2012). Furthermore, the numberof children per woman declined from 4.9 in1950–1955 to 2.6 in 2005–2010 (UN 2011).Epidemiological advances mean that globalaverage life expectancy has increaseddramatically over the past five decades; from 47years in 1950-1955 to 65-68 for men and 70 forwomen in 2005-2010 (UN, 2009a).

Birth rates have been observed to decline followingfalling death rates and increased economicdevelopment. However, in most countries orsocieties there is a period of rapid populationgrowth when birth rates remain high. This has beendescribed as ‘demographic transition’ period whichis shown below in figure 4.1


Migration is another aspect of this demographictransition. This is characterised by a shift fromrural to rural migration at early stages of thedemographic transition to rural-urban migrationand also international migration at later stages ofthe transition. According to the UN (2012),migration may have the following directenvironmental impacts:l “rural-rural migration produces direct

household impacts on natural resources,often through agricultural expansion;

l rural-urban migration and associatedlivelihood changes are often accompanied bychanging patterns of energy use andincreased meat and dairy consumption, whichcan intensify land pressures in productiverural areas; and

l international migration, with remittances senthome, can have a direct impact through land-use investments or an indirect impact throughincreased meat, dairy and materialconsumption”.

While in 1950 below 30% of the world populationlived in urban areas (only New York and Tokyo hadpopulations of more than 10 million people) in2010 this had grown to 50%. Also, in 2010 therewere 20 cities with populations of over 10 Million,

predominantly in Asia and Latin America. In 2013,Karachi had around 23 Million inhabitants and isexpected to grow to over 26 Million by 2025.Another mega-city in Pakistan is Lahore whichhad around 8 million inhabitants in 2013. Recently,urban growth rates have been high in both Asiaand Africa, with highest rates being observed inmiddle-sized cities (Montgomery 2008). Despitethese numbers, however, only 0.5% of the world’sland surface area is currently occupied by urbansettlements with over 37% of the surface beingused for agricultural production purposes (Foley etal. 2011).

A rising human population and associatedincreased economic activities are seen as thereason for many environmental problems relatedto water, air, soils, and fauna and flora. Withregards to water, overall, humans use more thana quarter of terrestrial evapotranspiration forgrowing crops. More than half of the accessiblewater run-off is used for this purpose (Postel etal., 1996). Climate change has been said to haveled to an increase in water scarcity, in particularin Africa and the Middle East. The ensuing crisishas been said to be worsening with growingpopulations (Sowers et al. 2010). During the 20thcentury, global economic output grew by a factor



Figure 4.1: the demographic transition

Source: UN, 2012, p7

Total population

Death rate

Birth rate

Time

High birth rate declining death declining birth low death rate and high but rate and and death rates and low but fluctuating continuing fluctuating death rate high birth rate birth rate

38

of more than 20 (Maddison 2009). This wasaccompanied by growing raw material extraction,and increasing levels of emissions (fluid andgaseous) that are often harmful to theenvironment. While some have hypothesised thatenvironmental degradation decrease withincreasing income levels (See the so-called‘environmental Kuznets curve’, shown in Figure4.2). In reality, processes do not always seem thatsimple with some environmental degradationpersisting even in highly developed economies.

Another aspect with regard to environmentalimpacts associated with population growth andeconomic development is a change in foodconsumption, described by Popkin (2002) as thenutrition transition. He described this in terms ofthree states: l decreased occurrence of famine with rising

incomes; l the emergence of chronic diet-related

diseases due to changes in activity and foodconsumption patterns; and

l behavioural change where diet and activitylevels are better managed for prolongedhealthier lives.

In order to reduce the environmental impacts ofthe increased production of goods and services,

technology plays an important role, in particularfor increasing efficiencies. However, to date aproblem has been that technological advanceshave not been enough to offset the impacts ofpopulation growth and the increase of productionand consumption. Therefore, some behaviouralchanges by humans are also seen to be vital forreducing environmental impact.

The three major economic sectors in terms ofenergy consumption (IEA, 2011) are:l manufacturing (33%);l households (29%); andl transport (26%).

4.3 Existing and emergingenvironmental threatsAs explained above, growing populations,economic development and the lack of sufficienttechnological advancements to increaseefficiencies to levels needed have radically alteredthe relationship between the environment andsociety. This has led to an increasing number ofconflicts (Redclift, 1991). Many environmentalobservers today suggest that society wants morefrom the environment than what the environmentcan provide. This generates numerousenvironmental problems, some of which have


Figure 4.2: Environmental Kuznets curve

Source: UNEP,2012, p12

Turning Point

Envir

onm

enta

l deg

rada

tion

Im

provement

Environmental

Envir

onm

enta

l

deg

rada

tion

Income per person

already been described above. Main globalenvironmental problems are discussed here.

4.3.1 Land resources The world’s land area covers 29% of the earth’ssurface and not all of it is suitable for humanhabitation. It currently supports over seven billionpeople and provides for mineral resources,sustains agriculture, supports urban andindustrial development, absorbs waste andprovides space for recreation. If these activitiesare not appropriately planned and managed, or ifthe limits of the land’s ability to handle them arenot acknowledged, significant negativeenvironmental impacts and problems can occur(Odum, 1975). Three groups of human activitiesthat create pressure on land can be distinguished(Kemp, 2004):1. Resource extraction and depletion, including

the deliberate removal and redistribution ofmaterials through mining and quarrying;depletion can occur inadvertently, e.g. as aresult of poor planning or unsuitable land-usein the case of soil erosion;

2. Urbanisation, infrastructure development andwaste disposal; including general urbansprawl, transport infrastructure - roads,airports and pipelines, sanitary landfill andhazardous waste disposal; and

3. Forestry and agriculture can disturb flora andfauna, if not done sustainably; furthermore,industrial harvesting of fish can destroymarine habitats; finally, there is generalwildlife and habitat destruction.

Suitable policy initiatives and spatial or land-useplanning can help the environment to be takeninto account. This can be particularly effective ifenforceable legislation is implemented. In thiscontext, environmental assessment can play acrucial role.

4.3.2 Wildlife A wide range of contemporary human activitiesalter ecosystems (Odum, 1989). Associatedimpacts on wildlife include:l A loss of wilderness - while naturally, plant

and animal communities within their abioticenvironment are capable of responding tonatural change, their ability to adapt is notinfinite. Many ecosystems are altered,disrupted and fragmented by humanactivities;

l The destruction of habitats - natural changeis an integral part of all habitats, but humaninterventions are causing habitat change andloss, particularly if no time for recovery isprovided; and

l Biodiversity or biological diversity loss - thisis one of the main consequences of humanimpacts on habitats due to human inducedactivities; biodiversity refers to the variety oflife forms that inhabit the earth; biodiversityincludes habitat diversity, plant and animalspecies diversity within various habitats andthe genetic diversity of individual species. Itcan be measured in terms of the number ofspecies or of the overall distribution orrelative mix of species. Agriculture, industryand urbanisation are major threats tobiodiversity.

There is worldwide concern for the current levelsof habitat destruction and loss of biodiversity.Despite recent attempts at valuing ecosystemservices, weighing the costs and benefits ofmaintaining and protecting the environmenteffectively remains elusive in the presence of theGross Domestic Product (GDP) paradigm. GDP isan unsustainable way to measure sustainabledevelopment, as every accident, such as an oilspill (destroying wildlife and plants) ultimatelycounts as GDP growth, due to the clean-upoperations. With regards to more information onthe protection of wetlands, see the RamsarConvention (http://www.ramsar.org). Furthermore,for the protection of wildlife, see the Conventionon International Trade on Endangered Species ofwild fauna and flora (http://www.cites.org).

4.3.3 Availability and quality of water Water is essential for any society, no matter howdeveloped or technologically advanced it is.While the amount of water on earth is constant, it



40

changes state and location regularly.Furthermore, it is naturally recycled because ofthe hydrological cycle. Human interferences are,however, affecting the efficiency of the hydrologiccycle and altering the availability and quality ofwater. Interferences include e.g. river dammingand river flow regime changes. Also, increasingly,certain changes are said to arise from globalclimate change. This includes changes toprecipitations, warming oceans and sea-level rise.Agricultural, industrial and domestic demandsalso affect the availability and quality of run offand groundwater. For more information on waterquality, See:http://www.unece.org/env/water/.

4.3.4 Drought, famine and desertificationDrought, famine and desertification can havedisastrous impacts on societies. Drought is apermanent dryness and occurs when there isinsufficient moisture to meet the needs of plants,animals and humans. Famine is a protracted foodshortage that leads to widespread starvation,disease and death. Many factors can play a rolein its occurrence, e.g. general poverty, civilunrest, and war. It can also be associated withinadequate food distribution or transportsystems. Drought can be associated with famine,causing crops to die or reducing local foodsupply. Desertification is the degradation of landin arid, semi-arid and some dry sub-humid areas.It can be associated with natural environmentalchange (e.g. extended drought). Furthermore,ecologically inappropriate human activities canalso be a major factor. Desertification is oftenassociated with extended periods of drought, e.g.when land adjacent to tropical deserts becomemore and more arid until desert conditionsprevail. Desertification is further explained in e.g.http://www.unccd.int.

4.3.5 Air and rain qualityThe atmosphere consists of a mix of gases,liquids and solid particles in varying proportions.Furthermore, it has the ability to cleanse itself ofsolid, liquid or gaseous materials released into it.Pollution occurs when the atmosphere is unable

to cleanse itself of materials that have been addedto it. Air pollution can impact human health, cropsand buildings. At a global scale, there is a build-up of particulate matter or aerosols. Theaccumulation of human released carbon dioxideinto the atmosphere has led to global warming.Additionally, the release of chlorofluorocarbons(CFCs) has led to a thinner ozone layer, exposingthe earth’s surface to excess solar radiation. Atthe local or regional level, air pollution in urbanareas has caused health problems and hasimpacted on the quality of life.

Locally produced pollutants can cause widerregional or continental problems. This includesacid rain which occurs when sulphur dioxideemissions are carried downwind by atmosphericcirculation, leading to environmental damagehundreds or even thousands of kilometres awayfrom the pollution source. Acid rain (snow, hail,fog) and dry gases or soot and fly-ash lead to thedeposition of acidic substances on the earth’ssurface. Acid gases, such as sulphur dioxide, arereleased into the atmosphere as a by-product ofsmelting processes, of the burning of coal and oilfor e.g. thermal electric power stations, and fortransport systems’ internal combustion engines(see also the UNECE Convention on Long RangeTransboundary Air Pollution protocol (1999), andthe Gothenburg Protocol designed to abateacidification, eutrophication and ground levelozone by setting country-by-country emissionthresholds to be achieved by 2010;http://www.unece.org/env/lrtap/ multi_h1.htm).

4.3.6 Ozone depletion and global warmingOzone depletion describes the steady decline ofthe total amount of ozone in the Earth’sstratosphere since 1980. Furthermore, there is amuch larger seasonal decrease in stratosphericozone at the Earth’s polar regions (i.e. the ozonehole). CFCs (chlorofluorocarbons), halons andother contributory substances are commonlyreferred to as ozone-depleting substances (ODS).The ozone layer prevents most harmfulwavelengths of ultraviolet light (UV light) frompassing through the Earth’s atmosphere. Ozone


depletion generated worldwide concern and ledto the ban of CFCs and halons and of otherozone depleting chemicals, such as carbontetrachloride and trichloroethane (also known asmethyl chloroform). Increased UV exposure dueto ozone depletion can cause skin cancer,damage to plants, and reduction of planktonpopulations.

Global warming consists of an increase of theaverage temperature of the earth’s surface, airand oceans. According to the IPCC(Intergovernmental Panel on Climate Change), anunusual increase in global average temperatureshas occurred since the mid-20th century. This isdue to the increase of anthropogenic greenhousegas emissions which is leading to the greenhouseeffect. This describes the rise in temperature thatthe earth experiences because certain gases inthe atmosphere trap energy from the sun. Theincrease in global temperatures causes sea-levelrise, changes in precipitation patterns resulting infloods and droughts. Changes in the frequencyand intensity of extreme weather events are alsothought to occur. Other effects include changesin agricultural yields, glacier retreats, reducedsummer stream flows, species extinctions andincrease in diseases. Not all world regions areexperiencing the same effect. In Europe, forexample, global warming could lead to cutting offthe gulf stream which would mean a drasticreduction in average annual temperatures in largeparts of Europe (for further information, See:http://unfccc.int/2860.php).

4.3.7 Noise pollutionNoise pollution is connected with excessive levelsof noise that may ultimately have an impact onhuman and animal health. Sources of noisepollution are often machines, including inparticular motor vehicles, planes and trains. Nextto the sources of noise, poor planning ofsettlements and infrastructures can be animportant reason for noise pollution.

“High noise levels can contribute tocardiovascular effects in humans, a rise in

blood pressure, and an increase in stressand vasoconstriction, and an increasedincidence of coronary artery disease. Inanimals, noise can increase the risk ofdeath by altering predator or preydetection and avoidance, interfere withreproduction and navigation, andcontribute to permanent hearing loss”(http://en.wikipedia.org/wiki/Noise_pollution).

4.4 Principles for environmentalintegrationGiven the dependence of humans on the earth astheir life-supporting system, the importance ofintegrating the environment into human activitiesand decision-making has become widelyacknowledged. There are different ways in whichenvironmental integration can occur. Theseinclude environmental movements, environmentalregulations, treaties and agreements andenvironmental tools, such as planning,management and assessment.

4.4.1 Environmental movements Concerns for the environment grew, as theimpact of human activities became clearer andtheir magnitude more significant. Concerns wereraised by individuals and groups of concernedpeople with scientific, social and politicalagendas, generating the basis for environmentalmovements. The first environmental movement inmodern times occurred in the 1960s and 1970s,resulting in the creation of new environmentalorganisations (e.g. Friends of the Earth andGreenpeace), the celebration of the first “Earthday” (April 22nd, 1970) and the publication ofvarious books (Rachel Carson’s 1962 “SilentSpring”; Paul Ehrlich’s 1968 “The PopulationBomb”; Aldo Leopold’s 1949 “A Sand CountyAlmanac”; Ian McHarg’s 1969 “Design withNature” and Meadows et al.’s 1972 “The Limits toGrowth”). The origins of the modern dayenvironmental movement go back more than 200years earlier with the work of numerousindividuals (See: Box 4.1).



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Subsequently, environmental concerns were alsobrought forward through conferences andmeetings (See: Box 4.2) as well as internationalagreements and protocols. The Kyoto Protocol,for example, is an agreement made under theUnited Nations Framework Convention onClimate Change (UNFCCC). It is an amendmentto the international treaty on climate change andit assigns mandatory emission limitations for thereduction of greenhouse gas emissions to thesignatory nations (See also:http://unfccc.int/2860.php).

The further development of the environmentalmovement witnessed a growing awareness of thescope and complexity of environmental issues,stressing the importance of understanding theeconomic and political components (Fischer andHajer, 1999). This resulted in the concept ofsustainable development, according to which

development must occur in an economically andenvironmentally sustainable manner i.e. ‘meetingthe needs of the world’s current populationwithout jeopardising those of future generations’;(the definition of the World Commission from1987). The concept of sustainable developmentis, however, not accepted among allenvironmentalists (Fischer and Hajer, 1999;Kemp, 2004; Berkhout, Leach and Scoones,2003). On the one hand, the so-calledtechnocratic environmentalists support theconcept. They believe that using technology andmanagerial techniques, environment can beadministered for the benefit of society. On theother hand, eco-centric environmentalists believehumans are not the only or most importantspecies. Therefore, priority should not be given tohuman needs over the needs of other species.Those who embrace eco-centrism are often seenas unrealistic in their demands, because they


Box 4.1: Precursors of environmentalism

Source: after Gazzola, 2008, p 64

James Hutton (1726-1797) and Charles Lyell (1797-1875): looked at the dynamic nature of the lithosphere,emphasising how it could contribute to environmental change;Charles Darwin (1809-1882) and Alfred Russel Wallace (1832-1913): recognised the importance of gradual andcumulative change in plant and animal communities. Darwin, with his publication “On the Origin of Species”(1859) developed the theory of evolution, including the concept of natural selection, which was also a study onenvironmental change;Thomas Malthus (1766-1834): studied the relationship between population growth and food supply;Alexander von Humboldt (1769-1859): recognised that the environment was being changed by human activities;Jean Jacques Rousseau (1712-1778) and Johann Wolfgang von Goethe (1749-1832): explored the relationshipbetween society and nature at a cerebral level;Henry David Thoreau (1817-1862): best known for his work “Walden” (1854), rejected materialism and studiednature to improve the quality and meaning of life. Through his observations he became aware of the concept offorest succession and subsequently advocated the creation of wilderness parks for the preservation of nature;George Perkins Marsh (1801-1882): in 1864 he published “Man and Nature”, where he included details of theimpact of human activities on the environment;John Muir (1838-1914): one of the first environmental activists to use writing and political contacts to promotethe preservation of the western wilderness. He was a founding member and the first president of the SierraClub;Aldo Leopold (1878-1848): is regarded as the father of wildlife management and founding member of theWilderness Society. He appreciated the interrelationships among the various components of the environmentand considered the concept of ecosystem as central to the management of nature (see his book ‘A SandCounty Almanac’, published in 1949);Rachel Carson (1907-1964): author of the best-seller ‘Silent Spring’ (1962) drew attention to the environmentalimpact of chemicals.

create a false equality amongst the componentsof the biosphere, ignoring that humans havetechnical and intellectual attributes that makethem different from other living organisms (Seealso: Ntsime, 2004).

4.4.2 Environmental regulations, treaties,protocols and agreementsThere are a number of environmental regulations,treaties, protocols and agreements that havebeen developed worldwide to support theconsideration of the environment in development,including e.g. the outputs of the 1992 UnitedNations Conference on Environment andDevelopment or NGO treaties, such as the EarthCharter which consisted of eight principles forsustainable development intended to parallel theRio Declaration (See:http://www.earthcharter.org). Following Kemp(1994), treaties can be grouped according tovarious clusters:l NGO cooperation and institution-building

cluster, including treaties on technology,sharing of resources, poverty,communications, global decision-making andproposals for NGO action;

l alternative economy issues cluster, includingtreaties on economic models, trade, debt,consumption and lifestyles;

l major environmental issues cluster, includingtreaties on climate, forests, biodiversity,energy, oceans, toxic and nuclear waste;

l food production cluster, including treaties onsustainable agriculture, food security andfisheries; and

l cross-sectoral issues cluster, includingtreaties on racism, militarism, women’sissues, population, youth, environmentaleducation, urbanisation and indigenouspeoples.

The commitment to treaties and protocols oftenrefer to the time in which the summits orconferences took place. Climate changeconventions tend to maintain a very high profile,due to the constant issues concerning globalwarming, while other types of environmentalissues are progressing slowly (Redclift, 1991;Fischer and Hajer, 1999; Jordan, 2005). Forcomprehensive lists of environmental treaties,conventions and protocols,See:http://www.chanrobles.com/environmentreaties.htm

4.5 Environmental integrationthrough different tools andinstrumentsThere are different tools through which theenvironment can be taken into account. Theseinclude environmental planning, policy-making,management and assessment. Environmentalplanning aims to ensure all planning activities arepreserving or enhancing environmental values orresources (www.fao.org/docrep/V8350E/v8350e0f.htm), encouraging, for example,sustainable development, green buildingtechnologies and the preservation ofenvironmentally sensitive areas. Environmentalplanning is often closely linked with spatial orland-use planning.



Box 4.2: International environmental conferences

1972 United Nations conference on the human environment, Stockholm: the need to acknowledge and tacklethe growing threats to the environment was recognised through the signing of the Declaration of the HumanEnvironment and the creation of the UN Environment Programme;1987 World Commission on Environment and Development (the Brundtland Commission): sustainabledevelopment was introduced, which required development to be economically and environmentally sound;1992 UN conference on environment and development (the Earth Summit), Rio de Janeiro: a blueprint forsustainable development in the 21st century was produced, including the Rio Declaration, Convention onClimate Change, Convention on Biodiversity, Statement of Forest Principles and Agenda 21;Since then, UN conferences Rio +5; +10; +20

Source: authors

44

Environmental policies represent statements ofintentions or principles, defining a framework foraction and for the setting of environmentalobjectives and targets. These can then beimplemented through planning and theirconsistency and performances evaluated throughenvironmental assessments. Any environmentalplanning, management or assessment system isusually framed by environmental policy.

Environmental management involves themanagement of all components of the bio-physical environment, with the purpose ofconserving the environment for humandevelopment. It can be implemented throughenvironmental management systems orstandards, which attempt to reduceenvironmental impact as measured by someobjective criteria. The ISO 14000 standard iswidely used in environmental risk management. Itis used in companies and administrations.

Environmental assessment (EA), consisting ofenvironmental impact assessment (EIA), strategicenvironmental assessment (SEA), and morerecently sustainability assessment (SA) andothers is the most widely used instrument for theassessment of environmental impacts ofdevelopment projects. EA is used throughout theworld and is closely connected withenvironmental policy and planning. Furthermore,links with environmental management instrumentsare also essential.

4.6 The ecosystem servicesapproach and its potential usefulnessin EIAThe concept of ecosystem services has beendeveloped for various reasons. Many of itsadvocates believe that valuing services inmonetary ways is the only way to giveenvironmental issues a voice that they otherwisedon’t have. In this context, they point out that

many development decisions are made based oncost-benefit analysis and that any issues notrepresented in it loose out. Ecosystem servicesare thus meant to aid our understanding of thehuman use and management of natural resources(www.ecosystemservices.org.uk). The main reason why ecosystem services areconsidered important is that human health andwellbeing depend upon them and thecomponents that contribute to them - water, soil,nutrients and organisms. Ecosystem services aredefined in various ways. The MillenniumEcosystem Assessment defined ecosystemservices as follows(www.milleniumassessment.org): l Supporting services: These are necessary for

the production of all other ecosystemservices including soil formation,photosynthesis, primary production, nutrientcycling and water cycling;

l Provisioning services: These are theproducts obtained from ecosystems,including food, fibre, fuel, genetic resources,bio-chemicals, natural medicines,pharmaceuticals, ornamental resources andfresh water;

l Regulating services: These describe thebenefits obtained from the regulation ofecosystem processes, including regulation ofair quality, climate, water, erosion, waterpurification, disease, pest, pollination, naturalhazards; and

l Cultural services: These are the non-materialbenefits people obtain from ecosystemsthrough spiritual enrichment, cognitivedevelopment, reflection, recreation andaesthetic experiences – thereby takingaccount of landscape values

Boxes 4.3 to 4.6 explain the four types ofservices in further detail (following UNEP – TEEB;http://www.teebweb.org/resources/ecosystem-services/):




Box 4.3: Provisioning ecosystem services

Source: http://www.teebweb.org/resources/ecosystem-services/

l Food: Ecosystems provide the conditions for growing food. Food comes principally from managed agro-ecosystems but marine and freshwater systems or forests also provide food for human consumption. Wildfoods from forests are often underestimated.

l Raw materials: Ecosystems provide a great diversity of materials for construction and fuel including wood,biofuels and plant oils that are directly derived from wild and cultivated plant species.

l Fresh water: Ecosystems play a vital role in the global hydrological cycle, as they regulate the flow andpurification of water. Vegetation and forests influence the quantity of water available locally.

l Medicinal resources: Ecosystems and biodiversity provide many plants used as traditional medicines aswell as providing the raw materials for the pharmaceutical industry. All ecosystems are a potential source ofmedicinal resources.

Box 4.4: Regulating ecosystem services


l Local climate and air quality: Trees provide shade while forests influence rainfall and water availability bothlocally and regionally. Trees or other plants also play an important role in regulating air quality by removingpollutants from the atmosphere.

l Carbon sequestration and storage: Ecosystems regulate the global climate by storing and sequesteringgreenhouse gases. As trees and plants grow, they remove carbon dioxide from the atmosphere andeffectively lock it away in their tissues. In this way forest ecosystems are carbon stores. Biodiversity alsoplays an important role by improving the capacity of ecosystems to adapt to the effects of climate change.

l Moderation of extreme events: Extreme weather events or natural hazards include floods, storms, tsunamis,avalanches and landslides. Ecosystems and living organisms create buffers against natural disasters,thereby preventing possible damage. For example, wetlands can soak up flood water while trees canstabilize slopes. Coral reefs and mangroves help protect coastlines from storm damage.

l Waste-water treatment: Ecosystems such as wetlands filter both human and animal waste and act as anatural buffer to the surrounding environment. Through the biological activity of microorganisms in the soil,most waste is broken down. Thereby pathogens (disease causing microbes) are eliminated, and the level ofnutrients and pollution is reduced.

l Erosion prevention and maintenance of soil fertility: Soil erosion is a key factor in the process of landdegradation and desertification. Vegetation cover provides a vital regulating service by preventing soilerosion. Soil fertility is essential for plant growth and agriculture and well-functioning ecosystems supplythe soil with nutrients required to support plant growth.

l Pollination: Insects and wind pollinate plants and trees which is essential for the development of fruits,vegetables and seeds. Animal pollination is an ecosystem service mainly provided by insects but also bysome birds and bats. Some 87 out of the 115 leading global food crops depend upon animal pollinationincluding important cash crops such as cocoa and coffee (Klein et al. 2007).

l Biological control: Ecosystems are important for regulating pests and vector borne diseases that attackplants, animals and people. Ecosystems regulate pests and diseases through the activities of predators andparasites. Birds, bats, flies, wasps, frogs and fungi all act as natural controls.

The Institute for Environmental Management andAssessment (IEMA) explains the potentiallybeneficial role of making ecosystem services oneof the inputs into EIA (See:http://www.iema.net/readingroom/e-briefings/considering-ecosystem-services-environmental-impact-assessment). They explainthat the consideration of ecosystem services inEIA can help increase the understanding ofsecondary and cumulative effects on ecosystemsand the services they provide to society andidentifying issues that may otherwise have beenmissed.

4.7 Practical elementGroups of students should reflect on specificenvironmental problems in Pakistan and how theyare being aggravated or not by human activities -directly, i.e. construction, as well as indirectly, i.e.climate change. Green Living Association:http://www.greenlivingasc.org/?p=1 and WorldBank (2006b). Pakistan Strategic CountryEnvironmental Assessment, http://siteresources.worldbank.org/SOUTHASIAEXT/Resources/Publications/448813-1188777211460/pakceavolume2.pdf.


Box 4.5: Habitat or supporting ecosystem services


l Habitats for species: Habitats provide everything that an individual plant or animal needs to survive - food;water; and shelter. Each ecosystem provides different habitats that can be essential for the lifecycle of aspecies. Migratory species including birds, fish, mammals and insects all depend upon differentecosystems during their movements.

l Maintenance of genetic diversity: Genetic diversity is the variety of genes between and within speciespopulations. Genetic diversity distinguishes different breeds or races from each other thus providing thebasis for locally well-adapted cultivars and a gene pool for further developing commercial crops andlivestock. Some habitats have an exceptionally high number of species which makes them more geneticallydiverse than others and are known as ‘biodiversity hotspots’

Box 4.6: Cultural ecosystem services


l Recreation and mental and physical health: Walking and playing sports in green space is not only a goodform of physical exercise but also lets people relax. The role that green space plays in maintaining mentaland physical health is increasingly being recognised, despite difficulties of measurement.

l Tourism: Ecosystems and biodiversity play an important role for many kinds of tourism which in turnprovides considerable economic benefits and is a vital source of income for many countries. In 2008, globalearnings from tourism summed up to US$ 944 billion. Cultural and eco-tourism can also educate peopleabout the importance of biological diversity.

l Aesthetic appreciation and inspiration for culture, art and design: Language, knowledge and the naturalenvironment have been intimately related throughout human history. Biodiversity, ecosystems and naturallandscapes have been the source of inspiration for much of our art, culture and increasingly for science.

l Spiritual experience and sense of place: In many parts of the world natural features such as specific forests,caves or mountains are considered sacred or have a religious meaning. Nature is a common element of allmajor religions and traditional knowledge, and associated customs are important for creating a sense ofbelonging.



This chapter introduces environmental policies, as well as the legal andadministrative framework for EIA in Pakistan. It is divided into eight sections.First, a brief review of the National Conservation Strategy and EnvironmentalPolicy is provided. EIA related provisions within the Federal and ProvincialEnvironmental Protection Acts and Review of IEE and EIA Regulations arethen introduced. This is followed by an overview of the EPAs’ guidelines,policy and procedure for EIA report preparation and checklist. Finally, theadministrative setup and environmental tribunals as well as problems inenforcement of EIA related legal provisions are outlined.

5.1 Environmental Policies

5.1.1 National Conservation StrategyPakistan’s National Conservation Strategy (NCS) was formulated in 1992 incollaboration with the IUCN. Numerous experts from various backgroundspertaining to the natural and built environment contributed to the formulationof this policy. The process involved consultations with some 3000stakeholders from various walks of life over a period of three years throughseveral workshops funded by the Canadian International DevelopmentAgency (CIDA) and the UNDP. While taking stock of the natural, human andfinancial resources, institutional capacity and considering the gravity ofenvironmental and socio-economic challenges facing the country, the strategyidentified the following three main objectives: l Conservation of natural resources;l Sustainable development; andl Improved efficiency in the use and management of resources.

Its operating principles aspire to:l Achieving greater public partnership in development and management; l Merging environment and economy in decision-making; andl Focussing on durable improvements in the quality of life (GoP/IUCN,

1992).

Moreover, it presents reviews of policies, legal instruments and programmesrelated to the environment existing at the time of formulating this strategy. It

5 Environmental Policies, Legal and Administrative Framework for EIA in Pakistan

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identifies and recommends 14 core areas forpriority implementation (Box 5.1).

The Strategy further identifies 68 specificprogrammes pertaining to these priority areas andsuggests a seven-level strategy for itsimplementation. The main emphasis of the Strategyis its implementation through the people ofPakistan, including: Individuals, corporate sector,government organisations, political leadership andNGOs. It aims at raising their awareness andinvolving them in various programmes. Significanttasks and resources required for implementationhave also been identified.

More importantly, the NCS recognises thesignificance of EIA in assessing potential adverseenvironmental impacts of development projectsand its role in making informed decisions. Itsuggests that large development projects shouldundergo EIA at an early stage of the projectplanning process to identify suitable sites andtypes of facility prior to making any decisions. Itfurther suggests that EIA should be incorporatedin government planning cycles to minimizeenvironmental deterioration and identifyappropriate mitigation measures. Publicparticipation in EIA has been especiallyemphasised and considered compatible with thecultural and socio-political norms of Pakistanisociety. By and large, this 405 page document isone of the most comprehensive and well thought-out strategies of the country. This can prove to bea good source of learning for the students.

A mid-term review of the NCS, however, revealedthat it has significantly raised environmentalawareness and has helped strengthening publicand civil society institutions. But it was notoperating adequately as a national sustainabledevelopment strategy due to lack ofimplementation capacity. It has been suggestedthat “improvements to the environment over thelonger term are likely to come about through acombination of poverty reduction and economicimprovements” (IUCN, 2000, p.2). The reviewrecommended the preparation of NCS2 and aNational Sustainable Strategy.

5.1.2 National Environmental Policy Pakistan’s National Environmental Policy wasframed in the year 2005. It recognises thatenvironmental issues pertain to the loss ofbiodiversity, deforestation, air, noise and waterpollution. The policy aims at protecting,conserving and restoring the environment of thecountry in order to improve the quality of life of itscitizens and advocates sustainable development.To achieve its aims, the policy establishes fiveobjectives, including: (i) conservation, restoration and management of

natural resources; (ii) integration of environmental consideration in

policy-making; (iii) capacity-building of institutions and

stakeholders; (iv) meeting the international obligations; and (v) raising environmental awareness though

community mobilisation (GoP, 2005).

The policy provides sectoral and cross-sectoralguidelines to the federal, provincial and localgovernments for managing the existing as well aspotentially expected environmental problemsrelating to several environmentally sensitive andimportant development sectors. These are listedin Table 5.1.


Box 5.1: Core programme areas recommendedby the NCS for priority implementation

Source: GoP/IUCN, 1992

1. Maintaining soils in cropland2. Increasing irrigation efficiency3. Protecting watersheds4. Supporting forestry and plantations5. Restoring rangeland and improving livestock6. Protecting waster bodies and sustaining fisheries7. Conserving biodiversity8. Increasing energy efficiency9. Developing and deploying renewables10. Preventing and abating pollution11. Managing urban wastes12. Supporting institutions for common resources13. Integrating population and environment programmes14. Preserving the cultural heritage

The sectoral guidelines provide lists of specifictasks - further policies, programmes,rules/regulations, environmental qualitystandards, etc., to be undertaken for effectivemanagement of natural resources and addressingenvironmental concerns relating to each of thesectors. It is important that the policy suggestskey instruments to be employed to achieve itsobjectives. Most of the instruments are akin tothe objectives of the policy itself. In addition, itsuggests economic and market-basedinstruments and public-private-civil societypartnership. Moreover, the promotion of SEA as atool for integrating environment into decision-making in the country and inclusion of theconcept of participatory approaches andpractices in the curriculum of environmentaleducation and training programmes are some ofthe key suggestions.

Furthermore, the policy proposes animplementation and monitoring the framework.This includes an “Action Plan” to be prepared bythe Ministry of Climate Change (formerlyEnvironment) along with preparation of plans andprogrammes by all the relevant Ministries andDepartments for its implementation. For effectivecoordination of the policy implementation,establishment of a Federal level “NationalEnvironment Policy Implementation Committee”is also suggested. The proposed Committee iscomposed of the following nineteen members,including its Chairman and Secretary:

l Six Secretaries of relevant Federal Ministries(Environment, P and DD, Finance, Industries,Food/Agriculture and Livestock, Health);

l Secretaries of all the Provincial/AJK/NorthernAreas (Gilgit Baltistan) EnvironmentDepartments;

l Three representatives from CorporateSector/Chambers of Commerce and Industry;

l Three representatives from Civil SocietyOrganisations; and

l Director General Environment, Ministry ofClimate Change formerly known as FederalMinistry of Environment.

Overall, this tries to be a holistic policy. How farthe implementation committee is succeeding inachieving its policy objectives has not yet beenfully explored.

5.2 Environmental legislationPakistan’s Constitution (Eighteenth Amendment)Act 2010, grants provincial governmentsexclusive powers to legislate on the subject ofenvironmental pollution and ecology(Pastakia/NIAP, 2012). As a consequence of thisamendment, provinces are in the process ofmaking various laws to ensure environmentalprotection. Provincial Environmental ProtectionActs shall be introduced later in this section. It ispertinent to mention here that FederalEnvironmental Laws/Regulations shall remaineffective but within the jurisdiction of FederalArea including Islamabad Capital Territory (ICT)



Table 5.1: Sectoral guidelines provided in the National Environmental Policy, 2005

Source: GoP, 2005; for further detail see: http://www.mocc.gov.pk/

Sectoral Policy Guidelinesl Water supply and managementl Air quality and noisel Waste managementl Forestryl Biodiversity and protected areasl Climate change and ozone depletionl Energy efficiency and renewablesl Agriculture and livestockl Multilateral agreements

Cross-sectoral Policy Guidelines l Poverty and environmentl Population and environmentl Gender and environmentl Health and environmentl Trade and environmentl Environment and local governance l Natural disaster management

50

which is not included in any province. Concerninglegal provisions for EIA, the PakistanEnvironmental Protection Ordinance (PEPO) 1983was the first legal instrument introducing EIA inthe country (GoP, 1983). Being an ordinance, itwas replaced by the Pakistan EnvironmentalProtection Act (PEPA) 1997 (GoP, 1997a). Therewas, however, a need to have detailed regulationsto facilitate enforcement of various steps oractivities involved in the EIA process. For thispurpose, the Pak-EPA (Review of IEE and EIA)Regulations 2000 were promulgated. Thefollowing two sub-sections introduce these twoenvironmental legislations, mainly focussing onthe provisions pertaining to EIA.

5.2.1 Pakistan Environmental Protection Act The Pakistan Environmental Protection Act (PEPA)1997 has been the core legislation for EIA in thecountry. Prior to approval by the then Parliament,consultative meetings and seminars were held tosolicit views of stakeholders from academia,industry, environmental NGOs and the public(Nadeem, 2010). Under section 12 of PEPA, noproponent can initiate construction or operationof a project, likely to cause adverseenvironmental effects, prior to submission of aninitial environmental examination (IEE) or anenvironmental impact assessment (EIA) whateveris deemed necessary by the concerned EPA, andits approval thereof (GoP, 1997a). According tothe Act, IEE means a preliminary environmentalreview is needed to determine whether theproposed project is likely to cause adverseenvironmental effects and necessitates an EIA.The Act defines EIA as “an environmental studycomprising collection of data, prediction ofqualitative and quantitative impacts, comparisonof alternatives, evaluation of preventive,mitigatory and compensatory measures,formulation of environmental management andtraining plans and monitoring arrangements, andframing of recommendations as such othercomponents as may be prescribed” (GoP, 1997a, p.2).

EPA is also authorised to impose conditions ofapproval, require re-submission of EIA or ‘rejectthe project as being contrary to environmentalobjectives’. However, if an EPA admits an IEE orEIA as complete, it “shall communicate itsapproval or otherwise within four months, failingwhich it shall be deemed to have been approvedto the extent to which it does not contravene theprovisions of PEPA or any other relevantrules/regulations” (GoP, 1997a). Contravening anyprovision of the Act shall be considered apunishable offense with a fine of up to one millionRupees. If contravention continues, an additionalfine of up to one hundred thousand Rupees perday shall be taken under section 17 of this Act.

The Federal Government has been empoweredunder section 20 of PEPA to establish as manyEnvironmental Tribunals as it considersnecessary. Any aggrieved person includingproject proponents may file an appeal with theEnvironmental Tribunal under section 22 againstthe decision of EPA within 30 days of the date ofcommunication of the decision/order. The personmay also appeal to the High Court against thesentence/order of the Environmental Tribunal, butagain within 30 days of its communication. Anoverview of the IEE/EIA related sections andprovisions of PEPA 1997 is presented in Box 5.1.

Some sections of the PEPA provide for otheraspects such as additional fine, action againstoffenses made by corporate bodies andgovernment agencies, delegation of power by theFederal Government to any provincialgovernment or agency and the powers to makerules/regulations for the implementation ofinternational agreements and nationalenvironmental quality standards, etc.


5.2.2 Pakistan Environmental ProtectionAgency (Review of IEE and EIA) RegulationsThese Regulations were made as the maininstrument to effectuate the IEE and EIA relatedprovisions of the 1997 PEPA. In fact, the IEE/EIArelated provisions of PEPA became operationalafter the promulgation of these Regulations(Nadeem and Hammed, 2008). Regulations 3 and4 require an IEE or EIA of projects falling in anycategory listed in Schedule-I and II (see alsoboxes 7.3 and 7.4 in chapter 7). Regulation 6authorises the Federal Agency to issue guidelinesfor preparation of an IEE/EIA. Detailed provisionsof the Regulations are discussed in relevantsections later in this curriculum. Main provisionsof the Regulations pertaining to the IEE/EIA filing,review, approval and monitoring are presented inthe Box 5.2. These help to comprehend theprocess and the minimum number of daysallocated to each step or activity at a glance. By the time of writing this curriculum, ProvincialEPAs’ were in the process of formulating IEE/EIARegulations for their respective jurisdictions. As

an interim arrangement, Pak-EPA’s Regulationswere being followed. The Environment ProtectionDepartments (EPAs) of Punjab and Balochistan,however, succeeded in amending PEPA 1997.The respective ProvincialAssemblies/Governments had approved andnotified their Provincial Environmental Acts. TheProvincial Environmental Protection Councilswere also being established with the respectiveChief Minister as its Chairperson.

While the AJK EPA was already operating underthe AJK Environmental Protection Act 2000,Sindh and Gilgit-Baltistan EPAs/relevantdepartments have yet to present environmentalprotection acts to their respective assemblies.The following section presents amendmentsmade in the Pakistan Environmental ProtectionAct 1997 to adopt it as the Punjab EnvironmentalProtection Act 1997 also known as the PunjabEnvironmental Protection (Amendment) Act, 2012(Box 5.3) and the Balochistan EnvironmentProtection Act 2012 (Box 5.4).



Box 5.2: IEE/EIA related sections and provisions of PEPA, 1997

Section 12 Requires initial environmental examination (IEE)/EIA of projects likely to cause adverseenvironmental effects.

Section 12(a)(b)(4) Govt. Agency to review IEE/EIA and accord approval within 4 months.Section 12 (3) Review of EIA to be carried out with public participation.Section 17 (1) Provides for penalty up to one million rupees in case of violation of IEE/EIA requirement

with an additional fine of one hundred thousand rupees per day in case of continuingcontravention.

Section 17 (4) Provides for an additional fine commensurate with the amount of monitory benefits, ifany, accrued by proponent.

Section 20 Authorises Govt. to establish Environmental Tribunals. Section 22 Aggrieved person may file an appeal with Environmental Tribunal within 30 days of the

communication of decision.Section 23 Aggrieved person may file an appeal against the order of the Environmental Tribunal to

the High Court within 30 days.Section 26 Federal Govt. may delegate any of its or Federal Agency’s powers to any Provincial

Govt., Local Council or Local Authority.Source: GoP, 1997a


Box 5.3: Legal provisions for IEE/EIA review, approval and monitoring in Pakistan

Regulation 8 Filing of an IEE and EIA- ten paper copies and two electronic copies.Regulation 9 Preliminary scrutiny within 10 days of filing of an IEE/EIARegulation 10 Public participation by seeking comments on the EIA report and arranging a public

hearing after publishing notices in two newspapers but not earlier than 30 days from thedate of publication of notices.

Regulation 11 Review of IEE by EPA within 45 days and of the EIA within 90 days. EPA may constitutea committee of experts and should also consider comments of stakeholders.

Regulation 12 Communication of decision by EPA to the proponent.Regulation 13 Conditions of approval also stating that the project shall be designed and constructed,

and mitigation measures adopted in accordance with the IEE/EIA.Regulation 14 Request by the proponent for confirmation of compliance of the conditions of approval

accompanied by an Environmental Management Plan. EPA may carry out site/plantinspection and confirm compliance within 15 days of request.

Regulation 17 Approval shall be valid for commencement of construction for a period of 3 years. Uponcommencing construction within three years, validity of approval shall extend that timefor a further period of three years.

Regulation 18 Authorised staff of EPA entitled to enter and inspect the project site, building, plant etc.during construction and operation of project for verification of the implementation ofconditions of approval. Proponent is bound to ensure full cooperation.

Regulation 19 Proponent required to submit report of completion of construction. In addition,proponent shall submit annual monitoring report with respect to conditions of approval.

Source: Derived from the Pak-EPA’s (Review of IEE and EIA) Regulations, 2000 (GoP, 2000).

Box 5.4: Main amendments related to IEE/EIA made in the PEPA 1997 by the Punjab Govt.

Section 17 (1) Provides for penalty up to [five million] rupees in case of violation of IEE/EIA requirementwith an additional fine of one hundred thousand rupees per day in case of continuingcontravention.

Section 26 Govt. of Punjab may delegate any of its or of the Provincial Agency’s powers to anyGovt. Agency, Local Council or Local Authority.

Section 2 (xxxviia) NEQS have been substituted by the Punjab Environmental Quality Standards (PEQS).

Source: GoPb, 2012

Box 5.5: IEE/EIA/SEA related sections and provisions of the BEPA, 2012

Section 13 (1) Regulates the conditions, methods and procedure according to which assessment ofenvironmental impacts (strategic assessment) or SEA of plans and programmes shall becarried out.

Section 13 (2) Government at all levels of administration and in every sector shall incorporateenvironmental considerations into policies, plans programmes and strategies.

Section 15 (1) Requires IEE/EIA of projects likely to cause adverse environmental effects. Section 15 (a)(b)(4) Government Agency to review IEE/EIA and accord approval within 4 months.Section 15 (3) Review of EIA to be carried out with public participation.Section 25 (1) Provides for penalty up to one million rupees in case of violation of IEE/EIA requirement

with an additional fine of one hundred thousand rupees per day in case of continuingcontravention.



Section 25 (2) Provides for an additional fine commensurate with the amount of monetary benefits, ifany, accrued by proponent.

Section 28 Authorises Government to establish Environmental Tribunals. Section 30 Aggrieved person may file an appeal with Environmental Tribunal within 30 days of the

communication of decision.Section 31 Aggrieved person may file an appeal against the order of the Environmental Tribunal to

the High Court within 30 days.Section 34 Government of Balochistan may delegate any of its or of the Provincial Agency’s powers

to any Government Agency, Local Council or Local Authority.

Source: GoB, 2013

The Government of Punjab has increased theamount of penalty from one million Rupees to fivemillion Rupees on violation of IEE/EIArequirement. On the other hand, BalochistanGovernment has made SEA/consideration ofenvironmental impacts of provincial policies,plans and programmes a mandatory requirement.This is a very important and much neededaddition to the Environmental Protection Act.Hopefully, other Provincial Governments as wellas the Federal Government shall also make SEAa mandatory requirement. One may expect thatthe Provincial SEA and EIA regulations would beformulated soon.

5.3 Pak-EPA’s Guidelines forIEE/EIAPrior to the enactment of the PEPA in December1997 and Review of IEE and EIA Regulations2000, the Pakistan Environmental ProtectionAgency published a comprehensive set ofguidelines known as “The Pakistan EnvironmentalAssessment Package” in November 1997. Inaddition to the policy and procedures for thefiling, review and approval of environmentalassessment, it included the following:l Guidelines for preparation and review of

environmental reports;l Guidelines for public consultation;l Guidelines for sensitive and critical areas; andl Guidelines for preparing environmental

reports of 8 specific sectors.

The overall purpose is said “to facilitateenvironmentally sound proposals by minimising

adverse impacts and maximising benefits to thecommunity” (GoP, 1997b). This documentestablishes necessary and very detailedprocedures and specific responsibilities ofproponents and officials of responsibleauthorities. The proponent is not allowed to startany construction work relating to the project untilthe responsible authority issues environmentalapproval for that project. Duties of theresponsible authority are as described in the Pak-EPA’s Review of IEE and EIA Regulations 2000.Lists/schedules of projects requiring an IEE or EIAalong with necessary forms for approval andagreement with the proponent and EPA are alsoincluded. Most of the guidelines, includingschedules of projects that were described in thisdocument were, later on, made part of theIEE/EIA Regulations. The four guidelines arefurther described and discussed in chapters 8, 9and 11 of this curriculum.

5.3.1 Guidelines for sensitive and criticalareas Sensitive and critical areas refer to ecosystemsand sites of archaeological or culturalsignificance. Ecosystems mainly include wildlifereserves, national parks and forests or gamereserves. Archaeological sites includemonuments, building and cultural heritage orworld heritage listings. The guidelines identifysensitive and critical areas of the country, as wellas relevant legislation, and provide guidance toprospective proponents, concerned officials andother stakeholders so that “the proposed projectsare planned and sited in a way that protects the

values of sensitive and critical areas” (GoP,1997e).

The following procedure should be adopted priorto environmental approval of any project situatednear any notified sensitive and critical areas:a) The proponent/EIA consultant should identify

whether the site for the proposeddevelopment is within the precincts, or 200feet, of a protected archaeological site ormonument as listed/notified by theGovernment (also provided in the guidelines);

b) If it is an archaeological site that appears tobe of importance, but the site is not listed,the proponent/consultant should discuss thesite with the relevant conservation authority;

c) If the site falls within the boundaries of aprotected area/archaeological site ormonument, then depending on its

classification the relevant conservationauthority will determine whether thedevelopment is prohibited or allowable withcertain conditions;

d) Concerned conservation authorities shallinform the responsible EPA about theassessment of the significance of the likelyimpacts of the proposed project. The EPA willthen decide the level of reporting required inthe light of the advice from the archaeologydepartment; and

e) It is the responsibility of the concerned EPAto coordinate with the relevant conservationauthority to ensure that identified impactsand proposed mitigation measures detailed inthe EIA report are well based, andaccordingly frame the conditions ofenvironmental approval so as to protect thevalues and assets of listed area.


Table 5.2: Legislation related to conservation of ecosystem in Pakistan

Wildlife Protection 1. West Pakistan Ordinance, 19592. Sindh Wildlife Protection Ordinance, 19723. Punjab Wildlife Act, 19744. Balochistan Wildlife Protection Act, 19745. NWFP Wildlife Act, 19756. Islamabad Wildlife Ordinance, 19807. Export and Control Order, 1982

Forest Conservation 1. Forests Act, 19272. Punjab Forest Act, 19133. NWFP Hazara Forest Act, 19364. Punjab Plantation and Maintenance of Trees Act, 19745. Cutting of Trees (Prohibition) Act, 19756. NWFP Management of Protected Forests Rules, 19757. NWFP Forest Development Corporation Ordinance, 1980

Land Use Location 1. Punjab Soil Reclamation Act, 19522. Punjab Local Government Ordinance, 20013. Punjab Land use (Classification, Reclassification and Redevelopment) Rules, 20094. Balochistan Local Government Act, 20105. Sindh Local Government Ordinance, 20126. Khyber Pakhtunkhwa Local Government Act, 2012

Fisheries Protection 1. West Pakistan Fisheries Ordinance, 19612. Balochistan Sea-Fisheries Ordinance, 19703. NWFP Fisheries Rules, 19764. Territorial Waters and Maritime Zones Act, 1976

Source: GoP, 1997e, p.7



Another very important part of these guidelines isthe list of various laws relevant to theconservation of the ecosystems in Pakistan. Someof these laws require environmental clearancebefore starting construction of a project. Anupdated list is presented in the Table 5.2.

5.4 Environmental guidelines andchecklists by Provincial EPAsSome of the Provincial EPAs in the country haveformulated sub-sectoral guidelines to assist thepublic and private sectorproponents/departments, environmentalconsultants and EPA staff involved in reviewingthe environmental reports. The KhyberPakhtunkhwa EPA (KPK-EPA) has taken the leadin this respect and formulated 22 sub-sectoralguidelines (Box 5.4). The Balochistan EPA could,so far, formulate only one sub-sectoral guidelineon dairy farms and slaughter houses. Other EPAsare still in the process, while following theseguidelines as an interim arrangement.The guidelines are also being used as screeningcriteria to ascertain whether an IEE or an EIA isrequired for a specific project. That is why, all theproponents are obliged to fill in the environmentalimpact assessment form and provide thefollowing information (KPK-EPA, 2004): a) Provide information on the project;b) Determine applicability of IEE or EIA;c) Describe the physical, biological and social

environment;d) Assess potential impacts and applicable

mitigation measures; ande) Provide undertaking to the EPA on mitigation

measures and compliance.

Specific impacts of each type of project andmitigation measures have been identified in therelevant guidelines. Environmental assessmentchecklists containing several questions havebeen provided in each set of guidelines. Thechecklists are quite comprehensive and containboth qualitative and quantitative criteria. Figure5.1 shows a section of the 15-page longchecklist.

5.5 Administrative set up forimplementation of EIA related legalprovisions and guidelines

Environmental Protection Councils, Ministries andDepartments for formulation of environmentalpolicies, Acts etc. exist at both the Federal andProvincial levels in Pakistan. These oversee andfacilitate their enforcement in the country. Prior tothe establishment of EPAs, the functions ofenvironmental protection/pollution control etc.were exercised by variousministries/organisations since 1975, as a follow-up of Stockholm Declaration of 1972 (e.g. formerMinistry of Environment in the Federal Area andEnvironmental Pollution Control Organisation inthe Punjab Province).

Box 5.6: Sub-sectoral environmentalguidelines and checklists by KPK-EPA

Source: Pak-EPA Website, 2013(http://www.environment.gov.pk/info.htm)

1. Brick kiln units2. Construction or expansion of bus terminal3. Carpet manufacturing units4. Canal cleaning5. Flour mill6. Forest harvesting operations7. Forest road constructions8. Housing schemes9. Marble units10. Petrol and CNG stations11. Poultry farms12. Rural schools and basic health units13. Sanitation schemes14. Solid waste management15. Stone crushing units16. Sound plantation17. Tourist facilities in ecologically sensitive areas18. Tube-well construction for agriculture and

irrigation purposes19. Urban areas road construction20. Watercourses construction and lining21. Water reservoirs in arid zones22. Water supply schemes

Afterwards, the EPAs established under the PEPO1983, have been entrusted with the task ofimplementing several environmental protection,conservation and improvement measuresincluding EIA related legal provisions followingtheir respective Environmental Protection Acts,Regulations and Guidelines within theirjurisdictions.

The Pak-EPA (Federal) was established in 1984. Itis attached to the Ministry of Climate Change. Itis responsible for implementing the PEPA 1997within the Islamabad Capital Territory and theareas not included in any province. It is alsoentrusted with the duty to coordinate with linedepartments/agencies of the Federal Governmentas well as the Provincial EPAs especially for those


Figure 5.1: A section of the environmental assessment checklist for stone crushing units

Source: Pak-EPA Website, 2013 (http://www.environment.gov.pk/info.htm)

Stone Crushing Units

No: Version: B Date: 21 May 2004 Page 13 of 15

Section IV: Impact Assessment

Potential Negative Environmental Impacts

Tick, if relevant Mitigation Measures Tick, if proposed

Monitoring

Siting Station is not located within ___ m of any educational institution or health facility

Traffic Plant is located such that ingress of heavy vehicles does not block the traffic

Noise and Dust Dust containment enclosures will be provided for:

Primary Crusher discharge area

Vibratory screen

Product storage hoppers

Belt Conveyors

Dust suppression system will be installed for:

Spray on the stones while unloading from the truck/dumper

Spray at the primary crusher feeder chute

Spray at the secondary/tertiary crusher inlet chute/hoppers

Spray at the transfer points from one belt conveyor to another

Spray at crusher discharge points

Payload area of trucks will be covered by tarpaulins when transporting crush to prevent fall out of fines and emissions of dust

Noise wall will be built dna lairetam fo noitarepo thgin etal dna gninevE

product trucks will be avoided

Wastewater Volume and strength reduction of the effluent is to be achieved by preventing mixing of waters from washing activities and processing activities

noitatnemides yb detaert eb ot si tneulffe diuqiL process meaning subjecting the effluent to flow through settling tanks

si taht noitalugaoc yb detaert eb ot si tneulffE adding any coagulant to the settling tanks

dna noitalugaoc yb detaert eb ot si tneulffE filtration

Occupational safety Workers will be provided with protective equipments

projects which extend within the jurisdiction ofmore than one EPA (e.g. National Highways). Itsorganisational set up mainly comprisesdirectorates of EIA/Monitoring, Lab/NEQS, andLegal/Enforcement as well as technical and othersupport staff etc. The Environment Section ofPlanning Commission is also responsible forensuring that environment considerations areincluded in the national plans and public sectordevelopment projects.

The Punjab-EPA was created in July 1987. It wasthe first provincial EPA in the country. Both, theSindh EPA (SEPA) and KPK-EPA were establishedin 1989. The third EPA was created in 1992 inBalochistan (BEPA). Azad Jammu and KashmirEnvironmental Protection Agency (AJK-EPA) wasestablished in July 1998. The most recent EPAthat emerged during October, 2007, in thecountry belongs to Gilgit-Baltistan (GBEPA). TheEPAs are attached with their respectiveEnvironment Protection Department/Ministry andthe names and combination ofdepartments/ministries vary from province toprovince. Hence, the country has seven EPAs.The EPAs have EIA responsibilities. The FederalEPA is responsible for implementing the IEE/EIArelated requirements, grant IEE/EIA approval andcarry out compliance monitoring of the conditionsof approval. Environmental monitoringequipment/laboratories are also provided but at alimited scale, together with technical staff.However, most of the EPAs have their field officesat District level working in association withDistrict/Local Governments. In addition,environment sections have been created in theProvincial Planning and DevelopmentDepartments to ensure environmentalconsiderations in public sector developmentplans and projects (also See: Section 15.5.2).

5.6 Environmental Tribunals The Federal and Provincial EnvironmentalProtection Acts authorise governments toestablish Environmental Tribunals (See: Box 5.1and 5.4). These have the same powers as arevested in the Court of Session under the Code of

Criminal Procedure, 1898 (Act V of 1898). Theirpowers and functions include but not limited to: l trial all punishable offences under the

Environmental Protection Act; l entertain complaints of environmental

offences lodged by the environmentalprotection agency or any aggrieved person;

l issue bail able warrant for the arrest of anyperson against whom reasonable suspicionexists, of them having been involved incontraventions punishable under the law;

l take action against a complainant uponmaking a false complaint, if proven. TheTribunal may direct the complainant to pay tothe person complained against compensatorycosts up to one hundred thousand rupees;and

l entertain appeals of any person aggrieved byany order or direction of the concernedProvincial Agency (GoP, 1997a; GoPb, 2012;GoB, 2013).

As indicated in Box 5.1, an aggrieved person mayfile an appeal against the order of theEnvironmental Tribunal to the concerned HighCourt within thirty days of the communication ofsuch order or sentence.

Initially, the Environmental Tribunals’ Rules 1999were notified for the appointment of aChairperson and two members with at least onetechnical member. The Punjab (Lahore) and Sindh(Karachi) Environmental Protection Tribunals wereestablished in 1999, whereas, the KPK(Peshawar) and Balochistan (Quetta)Environmental Protection Tribunals wereestablished in 2005. Earlier, the Punjab and SindhTribunals had been dealing with the cases ofIslamabad, KPK and Balochistan respectively.Working of these Tribunals varied due to lack offinancial resources and delayed appointment ofChairpersons, members and support staff (See:NIAP/IUCN, 2012). After the devolution ofenvironmental pollution and ecology to theprovinces, each province is now making its ownrules (e.g. GoPb, 2012a). Under the respectiveProvincial Environmental Protection Acts, a



58

Government may establish as manyEnvironmental Tribunals as it considers necessary(GoPb, 2012; GoB, 2013).

5.7 Problems in Implementation ofEIA related Provisions ofEnvironmental ProtectionActs/Regulations A study on the impact of constitutionalamendments on environmental protectionlegislation also including an analysis of laws inforce and assessment of implementation issues,conducted as a part of NIAP, revealed severalproblems facing EPAs in the implementation ofthe laws described above (Pastakia/NIAP, 2012).Following are some of the key issues related tothe implementation of EIA related provisions: l Fines and fees collected pertaining to

IEE/EIA, environmental reports and laboratoryanalysis should be deposited in separateaccount;

l IEE/EIA Regulations 2000 need to be revisedincluding Schedules I and II with the additionof further categories (even some small scaleprojects) should be required to undergo anIEE or at least an environmental report;

l DG EPA should have the power to stop(temporarily or permanently) project activitiesand to impose fines on the spot;

l Provisions on selection of the members ofEnvironmental Tribunal should be amended;

l Penalties/pollution charges are low and needto be revised on the basis of environmentalimpact of offence rather than type of offence;

l Certain types of discharges/emissions are notincluded in the NEQS. Discharge fromprocesses and the receiving sources are nottaken into account;

l Sectoral guidelines for environmental reportsneed to be reviewed and amended orimproved;

l Guidelines and codes of conduct, such asaccreditation mechanisms forenvironmental/EIA consultant should beformulated;

l Environmental audits should be required forall types of projects (industrial, commercial)

having significant environmental impactsduring operation, regardless of project size;and

l Strategic Environmental Assessment ofpolicies, plans and programmes need to beintroduced in the country (Pastakia/NIAP,2012).

Other studies found some other weaknesses ofthe current EIA system, including inadequatetechnical and financial resources, weakcoordination among the EPAs and linedepartments/agencies of the government andother stakeholders, poor quality of EIA reports,weak public participation, weak implementationof mitigation measures as well as post EIAmonitoring (World Bank, 2006; Nadeem andHameed, 2008; Nadeem, 2010, Nadeem andFischer, 2010; Saeed et al. 2012). Despite theseweaknesses, the existence of EIA in Pakistan ispositive and some organised efforts are underwayto improve the EIA system and the practice (See:NIAP, http://www.niap.pk/).

5.8 Practical element Students should review the literature with regardsto evidence provided on the effectiveness,successes and problems of the Pakistanilegislative context for EIA. In addition, studentsmay be given scenario based exercises todetermine clauses of IEE/EIA regulations followedor violated by certain projects.




This chapter first introduces EIA requirements by the World Bank and theAsian Development Bank. Then, requirements of other organisations aresummarised. Social and environmental safeguard policies of literally alldevelopment organisations include requirements for EIA and SEA.

6.1 IntroductionMany countries have guidelines in place on how to apply EIA which is usuallyprepared by the overseeing authority. They are normally also responsible forensuring compliance with EIA requirements. When guidelines are notavailable, ToRs are developed that often refer to guidelines prepared by othercountries (those that have e.g. the same national language) or internationalagencies. The IIED Directory of Impact Assessment Guidelines provides for alist summarising those guidelines (see http://pubs.iied.org/pdfs/7785IIED.pdf).This directory also contains guidelines from development banks, bilateral andmultilateral-donors, inter-governmental and UN organisations. Furthermore,the World Bank (1991) has released an Environmental AssessmentSourcebook. What is important is that usually World Bank and otherDevelopment Bank standards have to be met when project are financed bythem.

In many jurisdictions, more than one set of EIA procedures may thus beapplicable to a specific development proposal. In this context, a possible lackof coherence between different requirements can lead to confusion, frictionand possibly uncertainty. According to the UN University (2006e), “problemscommonly occur when: l countries receive aid from a number of donors, each having its own

prescribed assessment process; or l a proposal is trans-boundary in nature, requiring compliance with EIA

procedures in two or more countries, states or levels of government(Espoo Convention).”

The Working Party of the Development Assistance Committee of the OECDdeveloped a practical guide for aiding both, officials in bilateral donoragencies and their counterparts in developing countries for co-ordinating theiractivities. It summarises the various EIA procedures used by the differentagencies and provides two key means of promoting coherence:

6 EIA requirements by internationaldevelopment banks and organisations

60

l a framework Terms of Reference for the EIAof development assistance projects; and

l a comprehensive checklist for managing EIA.

The UN University (2006e) suggests that “Indeveloping countries experience has shown anumber of underlying conditions will determinewhether and how an EIA system is instituted.These are interrelated and reinforcing, andinclude: l a functional legal regime; l sound administration and flexible policy-

making; l stakeholder understanding of the aims of the

process and its potential benefits; l political commitment; l institutional capacity for implementation; l adequate technical capacity, data and

information; l public involvement; and l financial capacity.”

6.2 World Bank The World Bank has well-established EIAprocedures in place. These are used in theirlending activities and development projects

undertaken by the countries borrowing money.While requirements may vary slightly, overalldevelopment banks follow a more or lessstandard procedure for the preparation andapproval of an EIA report. This follows thetraditional EIA stages as introduced in thiscurriculum. Borrowing countries are normallyresponsible for the preparation of EIAs. It isthrough these requirements that EIA has beenintroduced in many developing countries.

The World Bank has environmental and socialsafeguard policies in place. These are aboutminimising the adverse effects of its projects.Furthermore, the use of SEA is propagated aspart of a strategy to promote long-termsustainability and integration of the environmentinto sector programmes and macro policies.Cornerstones of the World Bank EnvironmentAgenda are shown in Table 6.1. In 2012, theWorld Bank also published their EnvironmentStrategy. This is based on three main aspects,namely a green, clean and resilient environment.

The International Finance Corporation (FC), whichis part of the World Bank Group, has also


Table 6.1: The World Bank Environment Agenda

PolicyDo-No-Harm

Targeted EnvironmentalAssistance

Mainstreaming theEnvironment at the Level of Policy and Programmes

AimsTo mitigate the potential adverse effects of the Bank’s investment projects on theenvironment and vulnerable populations, EIA procedures and safeguard policiesare applied. In many cases, these have contributed to better project design andenvironmental management plans have helped to improve projectimplementation.

To foster long-term environmental sustainability and improve conditions indeveloping countries, designated Bank projects target the following areas:sustainable natural resource management, including watershed protection andbiodiversity conservation; pollution management and urban environmentalimprovements; environmental institution and capacity-building, and globalenvironmental actions, in accordance with international environmentalconventions and commitments.

To integrate environmental concerns at the macro level, the Bank has reviewedthe policies of the energy-, rural development- and other sectors, established anenvironmental framework for its country assistance strategies and intends tomake greater use of SEA at the programme and regional level.

Source: UN University (2006e), citing World Bank (1999: 8-10)

released a range of performance standards.Standard 1: Assessment and Management ofEnvironmental and Social Risks and Impacts is ofparticular relevance with regards to EIA. Theassociated Guidance Note 1: ‘Assessment andManagement of Environmental and Social Risksand Impacts’(http://www.ifc.org/wps/wcm/connect/b29a4600498009cfa7fcf7336b93d75f/Updated_GN1-2012.pdf?MOD=AJPERES) refers to theapplication of both, EIA and SEA several times.

6.3 Asian Development Bank: EArequirements and guidelinesWhile discussing environmental problems andpoverty in Asian countries, Lohani et al. (1997,p.4) suggested that “the EIA has an importantrole to play in resolving these environmentalproblems through its ability to contribute toenvironmentally sound and sustainabledevelopment. Developing countries in Asia haverecognised the importance of incorporating EIAprocesses into development planning”. The AsianDevelopment Bank (ADB) requires environmentalassessment (EA) of all projects, programmes andsectoral development programmes financed by it.ADB’s EA process starts as soon as the potentialprojects/programmes are identified for loaning,and covers all project components whetherfinanced by ADB, co-financed, or Governmentfinanced. The level of environmental assessment(whether an IEE or EIA or SEA) is determined onthe basis of the size of the project and thesignificance of potential environmental impacts.This section is based on ADB’s EnvironmentalAssessment Guidelines 2003 (ADB, 2003). Themore recent Safeguard Policy Statement by theADB (2009) includes extensive references to EIAand also refers to the usefulness of SEA(http://www.adb.org/sites/default/files/pub/2009/Safeguard-Policy-Statement-June2009.pdf).

6.3.1 Specialised Guidelines for EAThe ADB has formulated specialised guidelinesfor environmental assessment. These suggestmethods and approaches that might be used inthe conduct of a specific aspect of the

environmental assessment as well as thepotential environmental impacts and mitigationmeasures for specific types of projects. It hasbeen suggested environmental considerations beintegrated into the country’s developmentstrategy and programme as well as SEA ofindividual policies, plans and programmes. Theguidelines may be used for the followingpurposes pertaining to various levels and aspectsof EA: l Country Environmental Analysis; l Determination of the Environment Category; l Environmental Management Plan; l Environmental Assessment of Programme

Loans; l Environmental Assessment of Sector Loans;l Environmental Assessment of Financial

Intermediation Loans and Equity Investments;l Public Consultation and Information

Disclosure; l Environmental Standards and Emission

Levels;l Social Dimensions; l Environmentally Responsible Procurement; l Cultural Heritage; l Strategic Environmental Assessment; l Cumulative Effects Assessment in

Environmental Assessment; l Managing and Administering an

Environmental Assessment Study; l Economic Analysis in Environmental

Assessment;l Multilateral Environmental Agreements; andl Environmental Auditing.

In the next section, ADB’s categorisation ofprojects for determining the level of required EAand the basic EA requirements for project loansare discussed.

6.3.2 Categorisation of projects fordetermining the level of EAAll the project loans and investments arecategorised to determine EA requirements.Categorisation is done using Rapid EnvironmentalAssessment (REA). For this purposecategorisation forms have been developed. “REA



62

uses sector-specific checklists developed andbased on the ADB’s past knowledge andexperience. These checklists consist of questionsrelating to (i) the sensitivity and vulnerability ofenvironmental resources in project areas, and (ii)the potential for the project to cause significantadverse environmental impacts”. The checklistshave been appended with the ADB’s guidelines(ADB, 2003).

Following are the four main categories: Category A: includes the projects which mayhave the potential to cause significant adverseenvironmental impacts. A detailed EIA is requiredfor all such projects.

Category B: includes the projects which may havea comparatively lesser degree of adverseenvironmental impacts than those of the CategoryA projects. An IEE is required for such projects. Ifthe IEE identifies significant adverse environmentalimpacts then an EIA will be required.

Category C: includes the projects which may nothave the potential to cause adverseenvironmental impacts. Neither an IEE nor an EIAis required for such projects but possible

environmental implications would remain undercontinuous review.

Category FI: includes projects involving a creditline through a financial intermediary or an equityinvestment in a financial intermediary. It is,however, required to apply environmentalmanagement systems.

This categorisation is used to prepare projectscreening lists as shown in Table 6.2.

The ADB’s guidelines suggest that EIA should beundertaken as part of the feasibility study. “TheEIA team should work closely with the technicalplanning and design group to ensure thatenvironmental considerations are integrated intothe project design. Representatives of theexecuting agency should participate as membersof the environmental assessment team. Theirparticipation in the field work, publicconsultations and report writing will increase theirunderstanding of environmental issues and willhelp build institutional capacity in EIA” (ADB,2003, p.15). Table 6.3 illustrates the basicenvironmental assessment requirements forproject loans.


Table 6.2: Sample categorisation of projects

Category Al Dams and reservoirsl Forestry and

production projectsl (large-scale)l Industrial plants

(large-scale)l Irrigationl drainage, and flood

control (large-scale)l Mineral development

(oil and gas)l Port and harbour

developmentl Thermal and

hydropowerdevelopment

Category Bl Agro-industriesl Rural electrificationl Electrical

Transmissionl Urban water supply

and sanitationl Rural water supply

and sanitationl Irrigation and

drainage (small scale)l Watershed projectsl Renewable energy

Category Cl Forestry research and

extensionl Rural health servicesl Marine researchl Family planning

programmel Microfinance projects

likely to have minimalor no adverseimpacts

Category FIl Credit linesl Equity investments

Source: ADB, 2003

(SEIA- summary environmental impactassessment; SIEE- summary initial environmentalexamination; RRP- Report and Recommendationsto the President)* Public consultation required at least twiceduring EIA (i) once during the early stages of EIAfield work; and (ii) once when the draft EIA reportis available, and prior to loan appraisal by theADB.

6.3.3 Environmental impact assessmentprocess for category A projects The EIA team is required to follow these steps(ADB, 2003, p.15):i. “Coordinate with the government concerned

and environment agencies;ii. Prepare project description, define the study

area, collect environmental baseline data,prepare site maps, and other relevant mapsfor the study area;

iii. Identify potential environmental impactsbased on the information obtained on theproposed project and the baseline

environmental conditions of the study area;iv. Identify alternatives and analyse the

environmental impacts of each alternative andpropose measures to avoid or preventimpacts;

v. Estimate the magnitudes of environmentalimpacts and assess the significance of theimpacts;

vi. Recommend environmental mitigationmeasures and estimate the mitigation costs;

vii. Prepare an EMP to be implemented by theexecuting agency during projectimplementation, operation and abandonment;

viii. Prepare the EIA and SEIA reports;ix. Conduct public consultation and ensure

information disclosure; and develop plans forpublic consultation and information disclosureduring project implementation;

x. Assess the executing agency’s capacity toundertake an environmental review of theenvironmental assessment report and EMPrecommendations, and recommend measures



Table 6.3: Environmental assessment requirements for project loans

Category

A. Projects with potential forsignificant adverse environmentalimpacts

B. Projects judged to have someadverseenvironmental impacts but oflesser degree and/or significancethan category A

C. Projects unlikely to haveadverse environmental impacts

Basic Environmental Assessment Requirements

- EIA- Public consultation (at least twice)*- EIA report to be prepared- Environmental management plan and budget to be prepared- SEIA to be circulated to the Board 120 days prior the Board consideration- SEIA to be disclosed to public- EIA available to public on request

- IEE- Public consultation- IEE report to be prepared - For projects deemed to be environmentally sensitive(i) SIEE to be circulated to the Board 120 days prior to Board consideration(ii) SIEE to be disclosed to public(iii) Environmental management plan and budget to be prepared- IEE available to public on request- if it is not circulated, the SIEE is normally to be attached as a coreappendix to the RRP

No IEE or EIA- Environmental implications to be summarised in the RRP

Source: ADB, 2003

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for capacity-building, if necessary; andxi. Ensure that the proposed project, with EIA

and EMP implementation, conforms to theGovernment and ADB environmentalassessment requirements, policies andregulations”.

The suggested outline/contents of the EIA reportare presented in Box 6.1.

6.4 EIA requirements of otherdevelopment banks and organisationsThere are numerous development banks andorganisations that are active in Pakistan and otherdeveloping countries. All of these apply EIA andhave associated requirements and guidelines inplace. The Canadian International DevelopmentAgency (2004) has summarised environmentalassessment policies and procedures fordevelopment assistance activities for numerousdevelopment banks and agencies, includingthose from Australia, Austria, Belgium, Canada,Denmark, the EC, Finland, France, Germany,Ireland, Italy, Japan, New Zealand, Norway,Sweden Switzerland, UK, US and others.Subsequently, a few of these are summarised.

In Australia (see http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/ $file/Aus.pdf), development aid isdriven by AusAID. In its activities, EIA is routinelyapplied according to the Environmental

Assessment Guidelines for Australia’s AidProgramme from 1996.

In Canada, the Canadian InternationalDevelopment Agency (CIDA) has releasedenvironmental requirements and procedures(http://www.acdi-cida.gc.ca/acdi-cida/acdi-cida.nsf/eng/REN-218123433-NN8). This followsclosely the national Canadian EA requirements.

In France, responsibility for official developmentco-operation is shared between the Ministry ofForeign Affairs, the Ministry of Co-operation (MC)and the French Development Fund (AFD), andTrade and Development. EIA requirements forman important part of their activities (See: http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/Fra.pdf).

In Germany, responsibility for development co-operation is with the Ministry for Economic Co-operation and Development (BMZ). Furthermore,the Society for International Co-operation (GIZ)fulfils an important role. EIA is interpreted asfollows (http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/Ger.pdf): ‘The assessment focuses on the directand indirect effects on human health (includingoccupational health aspects) and the naturalenvironment as well as social and culturalaspects, such as the consequences ofresettlement and influences on local populationsor cultural monuments.’ (p.4). Generally speaking,requirements follow traditional EIA stages closely.

Dutch development assistance is theresponsibility of the Ministry of Foreign Affairs(see http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/Net.pdf). Here, generallyspeaking, EIA in development co-operation hasto comply with the EC EIA Directive. In thiscontext, the Dutch EIA Commission plays animportant role. A Dutch policy documentpublished in 1990 and subsequent new policydocuments set poverty alleviation as the main


Box 6.1: Outline/contents of EIA report for theADB funded projects

Source: ADB, 2003

IntroductionDescription of the ProjectDescription of the EnvironmentAlternativesAnticipated Environmental Impacts and MitigationMeasuresEconomic AssessmentEnvironmental Management PlanPublic Involvement and DisclosureConclusions

policy objective for development cooperation.Environmental assessment is considered animportant contribution to sustainabledevelopment.

In the USA, the National Environmental Policy Act(NEPA), which came into effect on January 1,1970, has required all agencies of the UnitedStates Government to integrate environmentalfactors into their decision-making processes,including the United States Agency forInternational Development (USAID). Requirementsare summarised by http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/US.pdf.

In Sweden, development co-operation is drivenby one Agency, namely SIDA, (SwedishInternational Development Co-operation Agency)which was formed in 1995. The use of EIA isadvocated through three main assessment steps,including screening, initial and in-depthassessment (http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/Swe.pdf ).

In Japan, development co-operation isimplemented by the Japan International Co-operation Agency(JICA). This Agency is responsible for technicalassistance, and the Overseas Economic Co-operation Fund (OECF), which administersdevelopment loans. JICA uses a system of

‘environmental consideration’ in its activities,which includes screening and scoping, and whichmay lead to Initial Environmental Examination(IEE), a pre-EIA or a full EIA (http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/Japan.pdf).

In the UK, the body responsible for developmentassistance is the Department for InternationalDevelopment (DFID). Environmental Assessmentprocedures closely follow those appliednationally, i.e. a traditional EIA process is followed(http://www.acdi-cida.gc.ca/INET/IMAGES.NSF/vLUImages/ea%20summaries/$file/UK.pdf).

Generally speaking, there are only few differencesbetween the requirements of differentorganisations and World Bank as well as AsianDevelopment practice can be seen as a proxy forprocedures of other development organisations.EIA core elements tend to be very similar andfollow a standard EIA approach as outlined insections 6.2 and 6.3.

6.5 Practical element Students to go to World Bank / AsianDevelopment Bank / international developmentorganisations’ websites and summarise what theyfind on EIA i.e. how these institutions areattempting to promote good practice.




In this chapter, screening is described first. Next, checklists for screening andproject categorisation for Initial Environmental Examination (IEE) and EIAunder Pakistani regulation are introduced. Thirdly, the rapid environmentalassessment (REA) checklists of the ADB are presented. This is followed by anintroduction to the purpose, objectives and guiding principles of scoping.Ways of undertaking scoping and in this context, the role of the public, aswell as criteria of good practice are introduced next. Then, types of impactsare established before and finally baseline data needs are explored. The mainsources this chapter draws on include the Asian Development Bank (2003i;iii), Environmental Law Alliance Worldwide (2012), Fischer et al. (2008; chapter13 by Fischer and Phylip-Jones: 136-142), European Commission (1999), andGovernment of Pakistan (GoP, 1997c).

7.1 What is screening and how is it done?Screening is the first stage of the EIA process which results in a key EIAdecision being made, namely to either conduct the assessment, based on thelikely significant impacts, or not to conduct it in the anticipated absence ofsuch impacts. Screening itself requires a procedural approach, as it isconducted for many potential development projects.

In order to carry out screening, some basic information about thedevelopment proposal along with the environment in which it is set isrequired. This means that some basic baseline data on e.g. flora and fauna,water, air and soil quality also needs to be available. The effort (in terms oftime and other resources) for screening is likely to depend on the specifictype of proposal, the specific legal requirements for screening and theunderstanding of potential environmental impacts. If it is based on a projecttype checklist, it can be done quickly. If, on the other hand, it is done on acase-by case basis, it may take some more time. In the latter case, at times, ascreening report may look similar to a full EIA report. Box 7.1 shows the twomain screening approaches as used in most EIA systems worldwide.

7 Screening/project categorisationand scoping

Box 7.1: Main EIA screening approachesl prescriptive or standardised approach in which development proposals that either

require or are exempt from EIA are listed in legislation and regulations; andl discretionary or customised approach in which proposals are screened on an

individual or case-by-case base, using indicative guidance.Source: authors

Screening will result in some projects requiringfurther assessment and others being screenedout which in many systems is the majority ofproposals. While there are exceptions, in manycountries only major proposals are considered togive rise to significant environmental impacts.These impacts may potentially affect e.g. humanhealth, endangered species, protected areas,fragile ecosystems, biological diversity, thequality of air and water, or the livelihood ofcommunities.

The outcome of a screening process can havedifferent outcomes. What exactly is possible orpermitted is prescribed in the specificrequirements of an EIA system. According to theUN (2006f), the following four outcomes arepossible:l no further level of EIA is required; l a full and comprehensive EIA is required; l a more limited EIA is required (preliminary or

initial assessment); or l further study is necessary to determine the

level of EIA required e.g. an initialenvironmental evaluation or examination (IEE).

If an EIA is found to be necessary, screeningprovides the basis for scoping. This establishesthe key impacts and alternatives to be consideredin assessment, thus providing for the terms ofreference for an EIA. While many EIA systemshave formal screening and scoping procedures inplace, some leave the specifics to either theproponent or the authority dealing with the EIA.At times, screening and scoping stages may alsooverlap in order to have greater certainty aboutwhether potential impacts are significant enoughto justify conducting a full EIA.

It is usually the proponent’s responsibility toprepare a screening report, often with support ofthe responsible authority. At times, it is also theauthority itself that completes screening. What isof great importance is that screening should bedone as early as possible in the development ofthe proposal in order for the proponent and otherstakeholders to be aware of possible EIA

obligations. It is also important that screening isapplied systematically and consistently, so thatthe same decision would be reached if others didthe screening. There are some specific methodsapplied to screening, which reflect prescriptiveand/or discretionary approaches. These areshown in Box 7.2

Both, prescriptive and discretionary approachesto screening fulfil important roles and are oftenused in combination. For example, for projectsthat are on the borderline of a prescriptivethreshold it makes sense to also have somediscretionary freedom for deciding whether anEIA was required. For example, a threshold fornew highways’ EIA of ten kilometres in lengthwould mean a new road of 9.95 kilometres wouldnot require one, if there was no possibility toapply some discretion.

Many EIA systems use project lists to screenproposals. Most of these are inclusionary lists,describing project types and size thresholds(thresholds may vary between projects). Anyproposed project that is of the type specified andfalling within the defined thresholds wouldautomatically require an EIA to be conducted.Exemption checklists are also known, whichwould include projects that are known not to giverise to significant environmental impacts.



Box 7.2: Specific methods used in screening

l legal (or policy) definition of proposals towhich EIA does or does not apply;

l inclusion list of projects (with or withoutthresholds) for which an EIA isautomatically required;

l exclusion list of activities which do notrequire EIA because they are insignificantor are exempt by law (e.g. national securityor emergency activities); and

l establishing criteria for case-by-casescreening of proposals to identify thoserequiring an EIA because of their potentiallysignificant environmental effects.

Source: UN, 2006f

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Inclusion lists differ between countries andinternational organisations with regards tocontent, comprehensiveness, threshold levels andother specific requirements for application.Internationally, reference is often made to twolists, namely (according to UN, 2006f):l Annexes I and II of the European EIA

Directive, which lists projects subject tomandatory EIA and non-mandatory EIA; and

l Annex E of the World Bank OperationalDirective on EA, which is illustrative andprovides a framework for screening.

The World Bank (1993) reported that these listsare a reliable aid to the classification of proposalsinto one of three categories: l “projects requiring a full EIA because of their

likely environmental effects; l projects not requiring a full EIA but warranting

a further level of assessment; and l projects not requiring further environmental

analysis”.

It is important that screening lists are not static,but that they need to be revised in the light of theexperiences gained. Also, environments may bechanging and new demands may arise whichshould lead to an adaptation of lists. Screeninglists should always be designed having a certainsystem or jurisdiction in mind. Transferability toother systems requires adaptation.

7.2 Checklists for screening andproject categorisation for IEE / EIAunder Pakistani regulation

The Pakistan Environmental Protection Agency(Review of IEE and EIA) Regulations 2000 (GoP,2000) specify projects requiring EIA, as well asthose requiring a leaner IEE (Initial EnvironmentalExamination). A proponent of a project from acategory listed in Schedule I needs to prepare anIEE. One listed in Schedule II needs to prepare anEIA. Furthermore, for those projects not listed ineither schedule I or II, no IEE or EIA need to beconducted, provided the project is unlikely tocause an adverse environmental effect. Also, forthose projects that are not listed in eitherschedule I or II, but for which the Federal Agencyhas issued guidelines for construction andoperation, an application for approval needs toshow how these guidelines have been compliedwith. Furthermore, the Federal Agency may ask aproponent to prepare an IEE or EIA. Schedule 1 islisted in Box 7.3 and schedule 2 in Box 7.4. Withregards to Pakistani practice, keeping in mind theconcerns of the EPAs, it is expected thatcategories of some projects shall be shiftedbased on scale or capacity of project fromSchedule I to II, along with an additional fewmore categories in forthcoming Provincial IEE/EIARegulations (for further detail, see: Pastakia/NIAP,2012).




Box 7.3: IEE/EIA Regulations: Schedule I list of projects requiring an IEE

A. Agriculture, Livestock and Fisheries1. Poultry, livestock, stud and fish farms with total cost more than Rs.10 million2. Projects involving repacking, formulation or warehousing of agricultural products

B. Energy1. Hydroelectric power generation less than 50 MW2. Thermal power generation less than 200 KW3. Transmission lines less than 11 KV, and large distribution projects4. Oil and gas transmission systems5. Oil and gas extraction projects including exploration, production, gathering systems, separation and

storage6. Waste-to-energy generation projects

C. Manufacturing and processing1. Ceramics and glass units with total cost more than Rs.50 million2. Food processing industries including sugar mills, beverages, milk and dairy products, with total cost less

than Rs.100 million3. Man-made fibres and resin projects with total cost less than Rs.100 million4. Manufacturing of apparel, including dyeing and printing, with total cost more than Rs.25 million5. Wood products with total cost more than Rs.25 million

D. Mining and mineral processing1. Commercial extraction of sand, gravel, limestone, clay, sulphur and other minerals not included in Schedule

II with total cost less than Rs.100 million2. Crushing, grinding and separation processes3. Smelting plants with total cost less than Rs.50 million

E. Transport1. Federal or Provincial highways (except maintenance, rebuilding or reconstruction of existing metalled roads)

with total cost less than Rs.50 million2. Ports and harbour development for ships less than 500 gross tons

F. Water management, dams, irrigation and flood protection1. Dams and reservoirs with storage volume less than 50 million cubic metres of surface area less than 8

square kilometres2. Irrigation and drainage projects serving less than 15,000 hectares3. Small-scale irrigation systems with total cost less than Rs.50 million

G. Water supply and treatmentWater supply schemes and treatment plants with total cost less than Rs.25 million

H. Waste disposalWaste disposal facility for domestic or industrial wastes, with annual capacity less than 10,000 cubic metres

I. Urban development and tourism1. Housing schemes2. Public facilities with significant off-site impacts (e.g. hospital wastes)3. Urban development projects

J. Other projectsAny other project for which filing of an IEE is required by the Federal Agency under sub-regulation (2) of

Regulation 5

Source: GoP, 2000


Box 7.4: IEE/EIA Regulations: Schedule II list of projects requiring an EIAA. Energy1. Hydroelectric power generation over 50 MW2. Thermal power generation over 200 MW3. Transmission lines (11 KV and above) and grid stations4. Nuclear power plans5. Petroleum refineriesB. Manufacturing and processing1. Cement plants2. Chemicals projects3. Fertilizer plants4. Food processing industries including sugar mills, beverages, milk and dairy products, with total cost of

Rs.100 million and above5. Industrial estates (including export processing zones)6. Man-made fibres and resin projects with total cost of Rs.100 M and above7. Pesticides (manufacture or formulation)8. Petrochemicals complex9. 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,with total cost more than Rs.10 million

10. Tanning and leather finishing projectsC. Mining and mineral processing1. Mining and processing of coal, gold, copper, sulphur and precious stones2. Mining and processing of major non-ferrous metals, iron and steel rolling3. Smelting plants with total cost of Rs.50 million and aboveD. Transport1. Airports2. Federal or Provincial highways or major roads (except maintenance, rebuilding or reconstruction of existing

roads) with total cost of Rs.50 million and above3. Ports and harbour development for ships of 500 gross tons and above4. Railway worksE. Water management, dams, irrigation and flood protection1. Dams and reservoirs with storage volume of 50 million cubic metres and above or surface area of 8 square

kilometres and above2. Irrigation and drainage projects serving 15,000 hectares and aboveF. Water supply and treatmentWater supply schemes and treatment plants with total cost of Rs.25 million and aboveG. Waste Disposal1. Waste disposal and/or storage of hazardous or toxic wastes (including landfill sites, incineration of hospital

toxic waste)2. Waste disposal facilities for domestic or industrial wastes, with annual capacity more than 10,000 cubic

metresH. Urban development and tourism1. Land use studies and urban plans (large cities)2. Large-scale tourism development projects with total cost more than Rs.50 millionI. Environmentally Sensitive AreasAll projects situated in environmentally sensitive areasJ. Other projects1. Any other project for which filing of an EIA is required by the Federal Agency under sub-regulation (2) of

Regulation 5.2. Any other project likely to cause an adverse environmental effect

Source: GoP, 2000

7.3 The rapid environmentalassessment (REA) checklists of theADBThe Asian Development Bank (ADB, 2003iii)provides online access to a range of screeningchecklists that are called here ‘rapidenvironmental assessment (REA)’ checklists forthe following sectors: l Agro Industrial Projects l Airports l Buildings l Chemical-based Industrial Projects l Fisheries l Forestryl General l Governance and Financel Hydropower l Irrigation l Mining Industry l Petrochemical Industrial Projects l Ports and Harbours l Power Transmission l Roads and Highways l Sewage Treatment l Solar Energy l Solid Waste Management l Thermal Power Plants l Urban Development l Water Supply l Wind Energy

Each sector has associated checklists that areseveral pages long. All checklists start withinstructions for the screening team, as follows:(i) The project team completes the checklist to

support the environmental classification of aproject. It is to be attached to theenvironmental categorisation form andsubmitted to the Environment andSafeguards Division (RSES) forendorsement by the Director, RSES and forapproval by the Chief Compliance Officer;

(ii) This checklist focuses on environmentalissues and concerns. To ensure that socialdimensions are adequately considered, referalso to ADB’s (a) checklists on involuntaryresettlement and indigenous peoples; (b)poverty reduction handbook; (c) staff guideto consultation and participation; and (d)gender checklists; and

(iii) Answer the questions assuming the “withoutmitigation” case. The purpose is to identifypotential impacts. Use the “remarks”section to discuss any anticipatedmitigation measures.

Each of these checklists consists of a number ofspecific questions that help the screening team todecide whether significant impacts are likely. Asan example, the forestry sector screeningchecklist is presented in Box 7.5.




A. Project SitingIs the Project area adjacent to or within any of the following environmentallysensitive areas?l Cultural heritage sitel Protected Areal Wetlandl Mangrovel Estuarinel Buffer zone of protected areal Special area for protecting biodiversityB. Potential Environmental ImpactsWill the Project cause…l increase in soil erosion and siltation?l increase in peak and flood flows?l loss of downstream beneficial uses (water supply or fisheries)?l impairment of ecological and recreational opportunities?l impairment of beneficial uses of traditional forests?l any loss of precious ecology?l possible conflicts with established management policies?l dislocation or involuntary resettlement of people?l loss of downstream ecological and economic functions due to any

construction of social infrastructure (e.g., road, training or information centre,office or housing)?

l displacement of people or reduce their access to forest resources?l disproportionate impacts on the poor, women and children, Indigenous

Peoples or other vulnerable groups?l uncontrolled in-migration, including the influx of workers and their followers,

with opening of roads to forest area and overloading of social infrastructure?l unnecessary loss of ecological value and decreased biodiversity by

replacement of natural forest with plantation with limited number of species?l technology or land use modification that may change present social and

economic activities?l ecological problems as well as community health and safety hazards due to

land clearance prior to reforestation (e.g., soil erosion, disruption ofhydrological cycle, loss of nutrients, decline in soil fertility)?

l other ecological problems as well as community health and safety hazards(e.g., pollution of water bodies from fertilizers, pesticides, and herbicidesused in the plantation)?

l dangers to a safe and healthy working environment due to physical,chemical and biological hazards during project construction and operation?

l social problems and conflicts related to land tenure and resource use rights?l social conflicts if workers from other regions or countries are hired? l risks to community health and safety due to the transport, storage and/or

disposal of materials such as explosives, fuel, pesticide and other chemicalsduring construction and operation?

Box 7.5: Screening checklist for forestry sector

Yes No RemarksScreening Questions

Each of the checklists is followed by an appendixon anticipated hazards and climate changes fordifferent environments.

7.4 Scoping - Purpose, objectives,guiding principlesScoping is the EIA stage at which issues, impactsand preliminary alternatives are determined thatshould be addressed at subsequent stages. Itdirectly follows the screening stage and is asystematic exercise that establishes theboundaries and Terms of Reference (ToR) for theEIA. A quality scoping study reduces the risk ofincluding inappropriate components or excludingcomponents which should be addressed.

While scoping has been defined by manydifferent terms, there is general agreement onwhat scoping seeks to achieve. The definitionadopted in recent guidance on project EIA,developed for the European Commission, setsout its meaning in its broadest sense as follows:

“Scoping is the process of determiningthe content and extent of the matterswhich should be covered in theenvironmental information to besubmitted to a competent authority forprojects which are subject to EIA.”(European Commission, 2001)

Scoping relates to addressing the impacts andissues to be studied during the EIA process and,in addition, covered within the report submittedas part of that process. This EIA report willdocument both, the project and the environmentin which it is to be located, together withdescriptions and assessments of the likelyconsequences of the development on variousenvironmental parameters.

Scoping involves decisions concerning what islikely to be significant impacts of a particularproject, and what alternatives should beaddressed (Wood, 2003; Weston, 2000; Glasson etal., 1999). There are, therefore, elements of both,identification and prioritisation within scoping.Furthermore, there is a need to engage in thedebate as to how significance might be defined.

There may be overlaps with the screening stage.Essentially, scoping takes forward the preliminarydetermination of significance made in screeningto the next stage of resolution – determining whatissues and impacts require further study. In doingso, scoping places limits on the information to begathered and analysed in an EIA and helps tofocus the approach to be taken.

In the early years of the development of EIA, littleattention was given to scoping, resulting in a lack



Climate Change and Disaster Risk QuestionsThe following questions are not for environmental categorisation. They areincluded in this checklist to help identify potential climate and disaster risks.l Is the Project area subject to hazards such as earthquakes, floods,

landslides, tropical cyclone winds, storm surges, tsunami or volcaniceruptions and climate changes (see Appendix I)?

l Could changes in precipitation, temperature, salinity, or extreme events overthe Project lifespan affect its sustainability or cost?

l Are there any demographic or socio-economic aspects of the Project areathat are already vulnerable (e.g. high incidence of marginalised populations,rural-urban migrants, illegal settlements, ethnic minorities, women orchildren)?

l Could the Project potentially increase the climate or disaster vulnerability ofthe surrounding area (e.g., increasing traffic or housing in areas that will bemore prone to flooding, by encouraging settlement in earthquake zones)?

Yes No RemarksScreening Questions

Source: Asian Development Bank, 2003

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of focus in most EIA reports. This made the EIAprocess slower, less efficient and less effectivethan might otherwise have been the case. Inresponse, for the first time in 1978, the U.S.Council on Environmental Quality (CEQ) issuedregulations, establishing “scoping” as a formalrequirement for EIAs.

In introducing EIA systems into legislation, theEuropean Union, in line with many otherjurisdictions, initially omitted scoping as a specificrequirement in the EIA Directive 85/337/EEC.Successive five-year reviews undertaken in 1992and 1997, however, recommended theintroduction of scoping as a means to strengthenits effectiveness. Subsequently, an amendment tothe Directive (97/11/EC) introduced scoping as anon-mandatory step in the EIA procedure withinthe EU from 1999 onwards.

There are numerous scoping guidelines availableonline (See e.g. EC, 2001a).

7.4.1 Purpose of scoping Scoping is a distinct, early stage within EIA whichdefines its proposed action, involves cooperatingagencies, identifies what is and what is notimportant, and seeks to set time limits onassociated studies. Furthermore, scoping is usedto determine staff requirements of theassessment team, collecting backgroundinformation, identifying other regulatoryrequirements and determining the range ofalternatives to be considered. Public input inscoping helps to ensure that important issues arenot overlooked when preparing the ToR and/orinitiating the EA study. Box 7.6 explains thepurpose of scoping.

Not all EIA systems make provision for thegeneration or review of alternatives during thescoping stage. These may follow, instead, fromthe issues that are identified as important.Consideration of alternatives during scoping is,however, clearly becoming acceptedinternationally as an EIA ‘good practice’ element.

While in scoping, significant effects are identified,subsequently these continue to be re-interpretedthroughout an EIA study, as well as in thedecision-making process, project implementationand monitoring. Unforeseen issues that requirefurther consideration may arise in any of thesephases. The work undertaken for an EIA on aparticular issue (the impact of toxic effluent onaquatic species and human health, for example)may uncover further questions, some of whichmay become contentious later on in the process.

Scoping is completed when the detailed studiesrequired in the EIA have been specified (i.e. whenthe ToR have been prepared), ultimately providingthe foundations for an effective and efficient EIAprocess. When carried out systematically,scoping highlights the issues that matter andprovides for a clear direction to the proponent onwhat is required. This increases the likelihood ofan adequately prepared EIA report. It helps toavoid the problem of unfocused, voluminousreports and the attendant delay while theirdeficiencies are addressed and corrected.Scoping helps to make sure that resources aretargeted on collecting the information necessaryfor decision-making and that they are not wastedon undertaking excessive analysis.

In so far as scoping involves the initial collectionand analysis of information about the


Box 7.6: The purpose of scoping

The purpose of scoping is:l to identify the important issues to be considered in an EIA, Including the baseline and alternatives;l to determine the appropriate time and space boundaries of the EIA; l to establish the information necessary for decision-making; andl to anticipate the significant effects and factors to be studied in detail.

Source: Fischer and Phylip-Jones, 2008

environment and actions that might affect it, itcan be seen as a rational activity that has often inthe past relied on the judgement and experienceof professionals. The determination of what islikely to be ‘significant’ in environmental termslies at the heart of scoping, and the public andother stakeholders base this not only onevidence-based impacts, but also on theperception of impacts. It is because of thepolitical nature of the wider process that theimportance of consultation and participation inscoping is now receiving increased emphasis(Weston, 2000).

Scoping involves two potentially mutuallyconflicting tasks. First, it is necessary to explorethe potential relevance of as wide a range ofissues (alternatives, impacts, approaches) aspossible. However, scoping is also concernedwith focussing the subsequent assessmentprocess, and therefore ‘scoping in’ significant

issues and ‘scoping out’ issues unlikely to be ofrelevance to the decision on the project. Theconsequences of balancing these two aspectsare that scoping establishes the scope ofadditional studies, assists in staffing andscheduling of study activities, and promotes thecompliance with all applicable legislativerequirements within an integrated study anddocument (Marriot, 1997).

7.4.2 Key objectives, guiding principles,elements, multi-dimensional aspects andoverall requirements for effective EIA scopingThe scoping exercise itself can vary in complexityand time taken. A comprehensive approach toscoping may be needed for large-scaleproposals, which have a range of impacts thatare potentially significant. In other cases, scopingwill be a more limited and restricted exercise.Depending on the circumstances, the scopingexercise can be tailored to include some or all ofthe key objectives listed in Box 7.7.



Box 7.7: Key objectives of scoping

The key objectives of scoping are to: l inform the public about a proposal;l identify the main stakeholders and their concerns and values; l define reasonable and practical alternatives to be addressed; l focus the important issues and significant impacts to be addressed by an EIA; l define the boundaries for an EA in time, space and subject matter; l set requirements for the collection of baseline and other information; and l establish the Terms of Reference (ToR) for an EIA study.


Box 7.8: Guiding principles for carrying out the scoping stage

Principles for carrying out the scoping stage include:l to recognise scoping is a process rather than a discrete activity or event; l to design the scoping process for each proposal, taking into account the environment and people

affected; l to start scoping as soon as sufficient information is available; l to prepare an information package or circular explaining the proposal and the process; l to specify the role and contribution of the stakeholders and the public; l to take a systematic approach but implement flexibly; l to document the results to guide preparation of an EIA; and l to respond to new information and further issues raised by stakeholders.


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There are a number of guiding principles forcarrying out the scoping stage of EIA. These aresummarised in Box 7.8.

The elements of scoping differ to some degreefrom EIA requirements established by differentcountries and international agencies. Acomprehensive scoping process will includevarious distinct elements. These are summarisedin Box 7.9.

Public involvement at the scoping stage isbeneficial, as this may lead to all the significantissues being identified, local information aboutthe project area be gathered, and alternative

ways of achieving the project objectives to beconsidered. The terms of reference (ToR) for anEIA provide a means of responding to andchecking against these inputs and should outlineany specific public involvement requirements.Overall, scoping is a multidimensional problem,requiring consideration of various aspects. Theseare summarised in Box 7.10.

To be successful and of benefit to the overallassessment process, scoping requirescommitment, participation, communication,information and flexibility. Box 7.11 explains whatthose involve.


Box 7.9: Elements for a comprehensive scoping process

Elements of a comprehensive scoping process include:l the identification of the range of community and scientific concerns about a proposed project or action; l the evaluation of these concerns to identify the significant issues (and elimination of those issues that are

not important); and l the organisation and prioritisation of those issues to focus the information that is critical for decision-

making, and that will be studied in detail in the next phase of EIA. Source: Fischer and Phylip-Jones, 2008

Box 7.10: Multidimensional aspects to be considered in scoping

Scoping may include a range of multi-dimensional elements, as follows:l Scope of the assessment, including:

- project alternatives; - design alternatives; and- justification for a policy, plan, programme, project.

l Scope of the project, including: - phases (development, operation, closure); and - components (dams, transmission lines, roads).

l Scope of issues, including: - project versus non-project issues; - range of environmental issues considered and their priorities (definition of “environment” has

implications);- cumulative effects; - cultural perspectives; and context (sustainable development; equity).

l Scope of factors - temporal/geographic boundaries for individual issues/cumulative effects; and - range of projects/activities/events considered in cumulative effects.


The format and detail of a scoping report varies.In principle, it should identify the content andextent of the information to be provided by thedeveloper to the competent authority. Inparticular, it should always identify the types ofenvironmental impacts to be investigated andreported in the environmental information.

It is important that the scoping process is wellplanned and managed, with a structured andcarefully planned approach involving provision ofinformation. Failing to manage the process couldlead to tensions between different stakeholders’priorities at this early stage of the EIA process.

In Pakistan, the sectoral guidelines for preparingEIA of projects of different development sectorshave been prepared for deciding on what issuesshould be included in an EIA (GoP, 1997d). Theresponsible EPA provides a typical list of stepsfor scoping and directs the proponent (if theycontact the EPA early for thorough discussionwith key stakeholders, assembling availableinformation from concerned departments andagencies, consulting with possible affectees,considering alternatives, and identifyinginformation gaps (Nadeem, 2010, p101).

7.5 How scoping is undertaken andthe role of the publicScoping may be undertaken in various ways, forexample:(1) by a developer or a developer’s EIA Team. A

draft Scoping Report is prepared andcirculated among consultees before it isfinalised and issued as the agreed terms ofreference for the EA. The consultees may bejust the environmental authorities or may

include other interested parties and thegeneral public; and

(2) by the competent authority or by anindependent body such as an EIACommission or a panel of EIA experts onbehalf of the competent authority. Thecompetent authority will then issue a scopingopinion to the developer which forms theterms of reference for the EIA. Prior tofinalising the Scoping Opinion, the competentauthority will consult the environmentalauthorities and may consult other interestedparties and the general public.

In some countries, a developer may request ascoping opinion from a competent authority atthe same time as requesting a screeningdecision. Such an approach can speed up theEIA process. However, the provision of a scopingopinion does not preclude the competentauthority from subsequently requiring thedeveloper to submit further information, if this isconsidered necessary. Scoping proceduresnormally involve some measure of consultation.In more developed systems consultation isextended widely to all interested parties includingthe general public. It may include publication ofdraft scoping reports for comment and evenpublic hearings. In others, consultation is lessextensive and focuses on seeking the views ofthe relevant environmental authorities.

It is imperative that all stakeholders in theprocess are fully aware of their responsibilitiesduring this stage so that an efficient, effective andcoordinated scoping stage is undertaken. Table7.1 shows the possible roles in scoping of variousstakeholders in the EIA process.



Box 7.11: Overall requirements for successful scopingOverall requirements for successful scoping include:l Commitment - agencies and organisations must be committed to the process of scoping and assessment;l Participation - many decisions are based on value judgements and thus the involvement of the public is

important to ensure that the public’s value judgements are incorporated;l Communication - among agencies, companies and the public;l Information - the timing and level of information available to participants must be appropriate; andl Flexibility - no one method for determining key issues is appropriate or effective in all circumstances.


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Involving the public in scoping helps to buildconfidence into the EIA process at all levels ofdecision-making. Often, the scoping process isthe first major point of contact with thestakeholders who are affected by or interested ina proposal and its alternatives. It provides animportant opportunity to inform them about theproposal and the EIA process, to understand theirconcerns and to set out the role and contribution

of public involvement in decision-making.Experience indicates that where scopingresponds to stakeholder and public inputs, eventhough it cannot always accommodate them,there is likely to be increased acceptance of thedecision-making processes.

In Pakistan, the role of stakeholders in thescoping process is mentioned. However, the


Table 7.1: Possible roles in scoping of different stakeholders

StakeholdersProponent/competentauthorities

EIA administering bodies

Other responsible agencies

EIA practitioners andexperts

People affected by theproposal

Wider community

Possible RolesKnow most about the proposal, and have a strongly developed view about thefactors that will influence the site selection and other aspects of decision-making. It is common for the proponent or the competent authority to haveresponsibility for scoping. The scoping process helps them to recognise theperspective of others, to consider alternatives and concerns of those affected,and to make changes to the proposal, which will address these inputs.

Generally establish and oversee statutory or procedural requirements forscoping. The requirements for scoping may cover the matters to be addressed,the people to be consulted, and the form of consultation. The administeringbody may issue terms of reference for the EIA, and/or review and approve theEIA report submitted by the proponent, checking it against the agreed scope.

Contribute relevant information about specific issues and matters within theirjurisdiction. This information may include specific legislative requirements, policyobjectives, and standards, technical knowledge and expertise, and experiencewith similar projects or local conditions. Certain agencies other than the competentauthority may also have the role of providing licences, permits, approvals orleases. Knowledge of these requirements is essential at the scoping stage.

May act directly for the agencies involved or for the proponent as consultantsretained for the EIA work, or they may function in an advisory or review capacityon behalf of scientific, NGO or professional bodies. Their involvement can be ofparticular value in providing specialist knowledge.

Have a major role in identifying concerns and issues and providing localknowledge and information. Their views should be taken into account inchoosing between alternatives, in deciding on the importance of issues, and inidentifying mitigating measures, compensation provisions and managementplans. Affected communities may need help in understanding the proposal, itsalternatives, and their likely effects, and in organising and articulating theirconcerns to those involved in the EIA process.

Will also provide information and views that are relevant to scoping. Thisgrouping includes those indirectly affected by the proposal, and local, nationaland sometimes international NGOs and interest groups. Further information onundertaking a dialogue with stakeholders can be found in Section 3 – Publicinvolvement.

Source: Institute for Environmental Management and Assessment, 2004

guidelines put the responsibility of formulating theterms of reference on the proponents.Stakeholders are rarely involved during scopingthrough the areas of concerns of affectees andconcerned government departments are not trulyreflected in EIA reports (Nadeem, 2010, p.101).

7.6 Criteria of good practice,methods and techniques It is widely accepted good practice for the resultsof scoping to be presented as a formal report orletter. Such a document is valuable for anyproject and requires e.g. detailed ecologicalsurveys, particularly where stakeholder-input isessential in defining terms of referenceacceptable to all parties. A scoping report orletter may be used as the basis for applying for aformal scoping opinion.

Governments often establish criteria for decidingwhether a negative effect is acceptable (i.e.insignificant) in terms of regulatory standardswhich reflect society’s values. Examples include:l Legal and Policy Criteria - policies stated in

legislation, regulations and policy statements;l Functional Criteria - consider how much

environmental systems are changed byproject actions;

l Normative Criteria - based on the valuessociety places on certain environmentalfeatures and qualities; and

l Controversy - an issue may also beconsidered because it is controversial.

An effective consultation process in scoping willfollow a number of steps. These may look likethose shown in Box 7.12 (following EuropeanCommission, 2001):

There are a variety of methods and techniquesthat can be utilised in order to define the scopeof an EIA. Such methods range from quantitativeto qualitative, and complex to simple. Thefollowing three main types of methods arefrequently used in scoping (see also Fischer,2007): l Indicators, checklists, matrices; l Public involvement methods; for example

open houses, surveys, interviews, hotlines;and

l Group process techniques; for examplegroup meetings, brainstorming, Delphimodels.



Box 7.12: EIA scoping consultation process

1. Identify a list of organisations and individuals that are interested in the project and update this as theproject develops.

2. Contact each consultee to request their help in scoping.3. Send them information about the project in the form of an attractive leaflet or brochure. Give contact

details for information and comment.4. Make the leaflet widely available in local centres (libraries, town halls, mosques); possibly provide a copy

to every household and business in the area.5. Collate and analyse all responses and take them into account in planning the environmental studies.6. Write back to each respondent thanking them for their help and explaining how their comments have been

addressed.7. If appropriate, arrange to telephone or meet them in person to discuss the issues they raise.8. If there is substantial local interest, consider holding a public exhibition or a community meeting at which

the project will be presented and staff will be on hand to answer questions.9. If there are several groups with a common interest consider setting up a special forum for them to meet

you at intervals.10. If the EIA process is lengthy, issue a regular newsletter to keep consultees up to date with what is

happening.11. Always record the views expressed in consultations in the environmental report.

Source: European Commission, 2001

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7.7 Types of impacts to be identifiedThere are different types of impacts EIA needs toconsider, representing a range of dimensions,including e.g. physical and non-physical, direct,indirect, cumulative and induced, short and longterms, local or regional/national/global, adverseand beneficial, reversible and irreversible,quantitative and qualitative, actual and perceived.

Non-physical impacts are, for example, socio-economic impacts. Impacts on cultural, religiousand other values also fall into this category.Physical impacts include those environmentalimpacts that traditionally have been considered inEIA (i.e. flora and fauna, water, air, soils). Directimpacts are those impacts which are caused bythe action and occur at the same time and placeof the development. Indirect impacts are impactson the environment, which are not directlyconnected with a project, but are rather the resultof complex pathways. The following examples ofindirect impacts are from the EuropeanCommission 1999 Guidelines for the Assessmentof Indirect and Cumulative Impacts as well asImpact Interaction:l a development changes the water table and

thus affects a nearby wetland causing animpact on the ecology of that wetland;

l visual impact from the use of noiseattenuation barriers as a mitigation measure;and

l the development of a project, which in turn,attracts ancillary developments.

Furthermore, cumulative impacts are described inthe same guidelines as resulting from incrementalchanges caused by other past, present orreasonably foreseeable actions together with theproject. Examples for cumulative impacts are:l incremental noise from a number of separate

developments;l combined effect of individual impacts, e.g.

noise, dust and visual, from one developmenton a particular receptor; and

l several developments with insignificantimpacts individually but which together havea cumulative effect, e.g. development of agolf course may have an insignificant impact,but when considered with several nearby golfcourses there could be a significantcumulative impact on local ecology andlandscape.

Induced impacts can result from reactionsbetween different impacts from one or severalprojects. For example (EC, 1999):


Figure 7.1: Main impact of air pollutants related to spatial scale

Source: Fischer, 2006, based on EC (1999b: 78)

POLLUTANTImpactLOCALair qualityREGIONALacidificationphotochemicalGLOBALgreenhouse effect

PM H|M SO2 NO2 NMVOC CO CH4 CO2 N2O

l a chemical plant producing two streams ofwaste that are individually acceptable butreact in combination producing highlysignificant levels of pollution;

l emissions to air from one project reactingwith emissions from an existing development;and

l two major developments being constructedadjacent to one another and duringoverlapping time periods will have manyinteractive impacts, from land use issues toconstruction and operational noise.

Short term impacts may occur e.g. only duringconstruction or may only lead to temporaryenvironmental impacts of a few weeks or months.Long term environmental impacts can occurwhen particularly sensitive environments areaffected. Marshlands, for example, takethousands of years to develop, so if these aredestroyed, the impact is very long term.

Regarding the geographical scale of impacts,some may be purely local (e.g. land-take), whileothers can go way beyond the local scale.Carbon emissions for combustion engines, forexample, have an effect on the global climate.

Adverse impacts are often thought of in terms ofnegative impacts. Beneficial impacts, on theother hand are normally thought of in terms ofpositive effects. In an ideal situation,

development should result in positive economic,social and environmental effects. Reversibleimpacts mean the original situation of theenvironment can be reinstated after e.g.construction activities. Irreversible impacts areseen as those that cannot be reversed inreasonable time scales. Taking the abovementioned example of marshlands, if those weredestroyed, this would normally be considered anirreversible effect. Quantitative impacts are thosethat are measurable (e.g. amount of emissions).Qualitative impacts, on the other hand, arenormally considered to be not (easily)measurable, but may still be very real, e.g. mentalillnesses out of fear from a certain development,e.g. a nuclear power station. Finally, there areactual and perceived impacts which are notalways in line. The estimated loss of life due tothe nuclear industry is e.g. extremely low ifcompared with risks of other activities. Smokingtobacco poses a particularly high risk.

7.8 Establishing what baseline dataneed to be considered The Asian Development Bank (ADB) provides alist of what baseline environmental informationshould be included in EIA (ADB, 2003, p.6). Thisincludes physical resources, ecological resources,economic development as well as social andcultural resources. Box 7.13 shows examples foreach of these.



As far as possible, baseline information should bepresented in maps, figures, and tables. In thiscontext, a detailed method should be providedon how information was gathered. This includesthe specification of data sources.

7.9 Practical element:Students are to conduct scenario basedexercises to determine the requirement of an IEEor EIA and scope for a hypothetical project inPakistan e.g. a road or a factory.


Box 7.13: Baseline environmental information that should be included in EIA

(i) Physical Resources, for example:l atmosphere (e.g. air quality and climate);l topography and soils;l surface water;l groundwater; andl geology / seismology.

(ii) Ecological Resources, for example:l fisheries;l aquatic biology;l wildlife;l forests;l rare or endangered species;l protected areas;l coastal resources;

(iii) Economic Development, for example:l industries;l infrastructure facilities (e.g. water supply, sewerage, flood control);l transportation (e.g. roads, harbours, airports, and navigation);l land use (e.g. dedicated area uses);l power sources and transmission; andl agricultural development, mineral development, and tourism facilities.

(iv) Social and Cultural Resources, for example:l population and communities (e.g. numbers, locations, composition, employment)l health facilities;l education facilities;l socio-economic conditions (e.g. community structure, family structure, social wellbeing);l physical or cultural heritage;l current use of lands and resources for traditional purposes by Indigenous Peoples; andl structures or sites that are of historical, archaeological, paleontological, or architectural significance.

Source: Asian Development Bank, 2003



In this chapter, methods and techniques used for assessing impacts in EIAare introduced. In this context, frequently used methods are distinguishedfrom moderately used and rarely used methods and techniques. The mainsources that this chapter draws on include Sadler (2005) and Fischer et al.(2008; chapter 16 by Belcakova: pp 157-165).

8.1 Methods and techniques used for assessing impacts in EIAOver the years, numerous methods have been developed to ensure thatvarious stages of the EIA process are carried out in a comprehensive andsystematic way. Generally speaking, EIA methods should allow for theorganisation of information and be beneficial for practitioners with limitedexperience. The most frequently used EA methods are listed in Box 8.1.

8 Methods and techniques forassessment of impacts

Box 8.1: Methods used in EA

Types of methods Use in EIAAnalogs HChecklists HDecision-focused checklists MEnvironmental cost benefit analysis LExpert opinion HExpert system LIndices or indicators MLaboratory testing MLandscape evaluation MLiterature reviews MMass balances HMatrices HBaseline monitoring LField monitoring LNetworks MOverlay mapping MPhotographs/photomontages MQualitative models HQuantitative models MRisk assessment LScenario building LTrend extrapolation LH= high use; M= moderate use; L= low use; O=limited use; NA=not applicable

Source: Belcakova (2008), based on Canter and Sadler (1997, p.95)

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Methods are subsequently described in moredetail, first those that are frequently used in EIA,followed by those of moderate and low usage.

While the use of assessment methods andtechniques would normally be left to thediscretion of practitioners, however, they mayalso be prescribed in regulation or guidelines. Inthis context, EA methods and techniques willdiffer, according to the sector and tier ofapplication. SEA of a regional land use plan, forexample, will require the application of differentmethods and techniques as compared to EIA fora road construction project (see Fischer, 2007).

8.2 The most frequently used EIAmethods and techniquesSubsequently, the most frequently used EIAmethods and techniques are introduced. Theseinclude analogues, checklists, expert opinions,mass balances, matrices and interactiondiagrams, as well as qualitative models.

AnaloguesAnalogues are used in EIA to draw onexperiences of similar actions in other policies orjurisdictions, countries or regions. In this context,observed impacts are taken as the basis formaking judgments on the proposal that is beingassessed. In this context, monitoring data shouldbe used to provide for a sound analogy to thepossible impacts of a proposed development.

ChecklistsChecklists have been described as a typical ad-hoc method (Sadar, 1996). Within EIA checklists,prescribed lists of environmental parameters areused that are to be checked for possible impactsof the proposed development. The potentialbenefits of simple checklists include (Sadar, 1996):l to apply a simple method for identifying

relevant environmental factors forconsideration in EIA;

l to encourage discussion during the earlystages of the assessment process; and

l to represent the collective knowledge andjudgement of those who developed them.

Checklists may range from simple listings ofenvironmental factors to listings that incorporatemathematical modelling. There are certainlimitations when using checklists. For example,checklists are neither able to discoverinterdependencies, connectivities or synergismsbetween interacting environmental components,nor are they able to describe variations ofenvironmental conditions. Finally, they do notprovide information on specific data needs.

Expert opinionOpinions and perspectives from recognisedexperts in relevant fields are often used in anattempt to resolve complex situations in arelatively short period of time. In this context,consultations or workshops may be used.Consultations are frequently conducted with theaid of questionnaires. Workshops may includestructured meetings, for example, with a problemsolving focus on developing alternatives.

Mass balancesFollowing Canter (1998), mass balancecalculations refer to the analysis of existingsituations and conditions with those that mayresult from proposed actions. They are mostlyused in the context of air and water emissions aswell as solid and hazardous wastes. Massbalance methods have a particularly highutilisation in project EIA processes.

Matrices and interaction diagramsMatrices usually take the form of a grid diagramor a two-dimensional table for cross-referencing alist of actions with environmental impactparameters. In this context, activities associatedwith various phases of a project or strategicaction can be listed along one axis, withenvironmental components listed on the other.Inputs into a matrix can either be qualitative orquantitative. The simplest matrices indicate onlythe occurrence of an impact without anyreferences to magnitude or significance. In moresophisticated matrices, quantitative estimates ofimpact magnitude and significance can becombined with a weighting scheme, leading to an


‘impact score’. The advantages of using matriceshave been described by Sadar (1996) to include:l a visual description of the relationship

between two sets of the proposal beingassessed;

l an identification of the impacts of differentphases of a project; and

l an identification of separate site-specificimpacts affecting a region as a whole (eventhough it may be better to describe differentaspects of a proposal, using separatematrices).

Several types of matrices have been used in EApractice, for example, Leopold matrix, Petersonmatrix, Component Interaction Matrix. The bestknown example is probably the Leopold Matrix(Leopold et al., 1971, See: Figure 8.1),representing a pioneering approach to EIA. Thismatrix was designed for the assessment ofimpacts associated with most types ofconstruction projects, listing 100 different projectactions along one axis and 88 environmentalcharacteristics and conditions along the other,including aspects of both, the biophysical andsocio-economic environments. Also, it involvesqualitative as well as quantitative informationabout cause and effect relationships. Severalauthors have stressed that the determination ofrelative importance or significance of an impact isa highly subjective process, and ideally shouldreflect consensus of opinion among experts froma variety of disciplines.

Qualitative modelsQualitative models refer to descriptive methodswhere relevant information is utilised to address

the implications of actions that can result inchanges to environmental components. It is amethod usually based on expert opinion, i.e.professional judgement.

8.3 Moderately used methods andtechniquesThis section focuses on methods and techniquesthat are moderately used in EIA. These includedecision-focused checklists, indices or indicators.

Decision-focused checklistsThese are basically lists of environmental factors,including information on measurement, impactprediction and assessment. They are particularlyhelpful in the comparative evaluation ofalternatives, and may be used, for example, forranking environmental factors and associatedimpacts in order of their relative importance, thusproviding a basis for selecting the preferredaction.

Indices or indicatorsIndices or indicators comprise selected featuresor parameters of environmental media orresources, representing broader measures of thequality/quantity of such media or resources.Indices may specifically refer to either, numericalor categorised information which can be used indescribing the affected environment and impactprediction and assessment, typically based onselected indicators and their evaluation (Canter,1998).

Laboratory testing This method is useful for impact identification andimpact prediction at the project (i.e. EIA) level. It



Source: following Leopold et al., 1971

A B C d E

a 2 81 5

b 2 8 3 92 8 1 7

Figure 8.1: Leopold matrix

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involves conducting specific tests or experimentsto gain both, qualitative and quantitativeinformation on predicted impacts of a certaintype of project in a given location, for example,the impact of high rise buildings on wind.

Landscape evaluation Methods and techniques of landscape evaluationare being used for visual and amenity assessmentwhen focusing on the description of affectedenvironments. Landscape evaluation is based onindicators, criteria and thresholds. Importantinformation can be aggregated into overallscores. Landscape impacts include direct andindirect impacts of actions uponlandscape elements andfeatures, as well as impacts onthe general landscape characterand quality of surrounding areas.

Figure 8.2 shows visibilitymapping for grading of viewsinto a site.

Landscape evaluation can belinked with carrying capacityassessment. This is a tool usedin land use planning assessmentfor setting developmentthresholds according tosensitivities of environmentaland social systems. This methodis particularly useful in theassessment of cumulativeimpacts and sustainabilitythresholds.

Literature reviewsLiterature reviews can be used inboth, EIA and SEA processes atdifferent procedural stages (e.g.impact identification, impactprediction, impact assessment).Similarly to analogues, thismethod is about the collection ofinformation on types of actionsand their impacts. Literature

reviews may allow EA practitioners to identify thelinks between policy actions and environmentalimpacts, using documents like state of theenvironment reports and/or environment policyplans.

NetworksThese are used to identify the structure, keyelements and interactions in a given system,using e.g. decision flowcharts and loop analysis.A network diagram visually describes cause-effect links. In this context, different levels ofinformation can be displayed. The relativedependence of one factor on the condition of


Source: Belcakova, 2008; IEA, 1995

Figure 8.2: Visibility mapping into a specific site

another may be indicated by various arrow widthsand heights (See: Figure 8.3). Negative andpositive feedback loops can also be identified, ifthe nature of the interrelationship is indicated.

Overlay mappingThe overlay mapping technique is based onproducing sets of maps of project effects, orenvironmental characteristics or themes(biophysical, social, aesthetic), for example, inorder to provide for a composite characterisationof a regional environment. Impacts can then beidentified by noting the affected environmentalcharacteristics within the project area boundaries.Overlay mapping is normally used to identifyareas which are compatible with the proposedaction. There are some limitations when usingthis method, as follows (Sadar, 1996):maps tend to oversimplify;specific interrelationships between environmentalfactors are not readily obtainable using traditionalmap overlays; andmap overlays cannot effectively describeecosystem dynamics through time.

Photographs and photomontagesPhotographs and photomontages are

visualisation methods related to landscapeevaluation (Canter, 1998) that can be applied inorder to describe affected environments, as wellas for impact prediction. They are helpful foranalysing the visual quality of the project site oraffected area and the potential visual impacts ofproposed actions. Their advantage is that theycan show the development within the reallandscape and from known viewpoints. VariousCAD systems can help with their application.Photomontages are the superimposition of animage onto a photograph for creating a realisticview of proposed potential visual changes. Figure8.4 shows examples of computer generated andhand-painted photomontages.

Quantitative modelsThese are based on mathematical models thatare used specifically for addressing expectedchanges in environmental media or resources.They range from simple to very complicatedmodels (for example three dimensional computer-based models) that may require extensive datainput. In most cases, models are used for thedescription or prediction of changes in propertiesof the system over a time period. Quantitativemodelling is most effective when environmental



Figure 8.3: Networks System Diagrams

Source: Belcakova, 2008; following Sadar, 1996

Salmonoidpopulations

Fishing Spawning

Temperature

Flow Water quality

Access

Dredging Clearing

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factors are easily quantifiable, so that they caneasily be assigned a mathematical value.

8.4 Low use of methods andtechniquesIn this section, low-use methods and techniquesare introduced. These consist of environmentalcost-benefit analysis.

Environmental cost-benefit analysisThis is used to select the best option forachieving set targets or goals at least cost(environmental or financial). It is based onidentifying a benefit–cost ratio for choosingbetween different options.

Expert systemsExpert systems represent task-specific modelswhich may or may not be computer based. Theyincorporate both, knowledge and experience ofexperts from different fields and from relevantdisciplines. Knowledge is fed into a structureddecision-making analytical tool. Expert systemsare based on value judgements and best-guessesabout likely outcomes.

Baseline monitoring and field studies monitoringBaseline monitoring is a measurement methodutilised to establish existing environmentalconditions and to interpret the significance ofanticipated changes of proposed activities. Fieldstudy monitoring represents a specialised

approach. Here, monitoring of actual impacts,resulting from specific types of projects can beconducted.

Risk assessmentThis is a method focusing on the assessment ofstrategic risks of a proposed action. In thiscontext, trends that may undermine objectivesand quality standards generating potentialrelevant damages and costs need to beconsidered.

Scenario buildingScenarios are used for projections to outline andcompare means and conditions of theimplementation of a proposed action based onreasoned assumptions. It is commonly used inland use and transport planning.

Trend extrapolationFollowing Canter (1998), this method refers toutilisation of historical trends, extending them intothe future based upon assumptions. These arerelated to either continuing or changed conditions.

8.5 Practical element: For different types of developments e.g. roads,airports, power plants, waste managementfacilities, small groups of students should jointlyconsider what methods may be suitably appliedto assess impacts of different alternatives andthen report back to the whole class.


Figure 8.4: An example of photograph/photomontages technique

Source: Belcakova, 2008; IEA, 1995



In this chapter, first the key role of public participation and consultation in theEIA process is explained. Then the notions of ‘the public’ and ‘public interest’are explored. How to establish the interests of the public and of stakeholdersis discussed. Subsequently, the history and rationale for EIA and publicdecision-making is described before international legislation pertaining to EIAand public decision-making is introduced. Participation and consultationtechniques and their suitability for different situations are explained and anoutline of trans-boundary considerations is provided. The final sectionelaborates on public participation in Pakistan. The main sources that thischapter draws on include Fischer et al. (2008; chapter 15 by Aschemann: pp151-156), Nadeem (2010), UNECE (2006) and UNEP (2002b).

9.1 Explain the key role of public participation andconsultation in the EIA processPublic participation and consultation are key stages in the EIA process. Theyare important sources of information in EIA for e.g. the identification ofimpacts, potential mitigation measures and the establishment of alternatives.Participation and consultation make the EIA process open, transparent androbust (UNEP, 2002b, p.161). Nearly all EIA systems world-wide haveprovisions for some type of public involvement. Public participation is aninteractive and intensive process of engagement, whereas public consultation(or dialogue) is about listening to public concerns. EIA processes often onlyinvolve consultation rather than participation. There is some consensus,though, that at a minimum, public involvement should provide an opportunityfor those affected by a proposal to express their opinions on the proposal andits impacts.

The purpose of public involvement is to (UNEP, 2002b, p.161):l “inform the stakeholders about the proposal and its likely effects;l canvass their inputs, views and concerns; andl take account of the information and views of the public in the EIA and

decision-making”.

The key objectives of public involvement are to (UNEP, 2002b, pp161-162):l “obtain local and traditional knowledge that may be useful for decision-

making;

9 Public participation andconsultation in EIA


l facilitate consideration of alternatives,mitigation measures and trade-offs;

l ensure that important impacts are notoverlooked and benefits are maximised;

l reduce conflict through the early identificationof contentious issues;

l provide an opportunity for the public toinfluence project design in a positive manner(thereby creating a sense of ownership of theproposal);

l improve transparency and accountability ofdecision-making; and

l increase public confidence in the EIAprocess.”

A range of stakeholders are involved in EIA.These include the individuals, groups andcommunities affected by a proposal, theproponent of the development along with thoseassociated with it, e.g. government departments,interest groups (including e.g. NGOs), and otherse.g. donors and academics.

The professional literature on public participationhas used different expressions and terms,including e.g. “public participation”, “publicinvolvement”, “stakeholder involvement”,“consultation”, “expressing opinions”,“communication”, “reporting”, “access toinformation”, “participatory approaches” andothers. Fischer (2007) differentiates between fourmain categories; participation, consultation,communication and reporting. These terms arefurther explained in Box 9.1.

Each word implies a different level of commitmentto and involvement of the public in decision-making. Different levels of citizen participationwere first conceptualised by Arnstein (1969). Sheidentified eight stages of participation, which areshown in Figure 9.1.

Box 9.1: Participation, consultation, communication and reporting

Participation: Engagement process, in which external persons (for example, the public) are called tocontribute to the decision-making process by exchanging information, predictions, opinions, interests andvalues.Consultation: Engagement process, in which external persons (for example, the public) are called to commenton documentation.Communication: One-way process, in which the objective is to inform and assist third parties and the publicto understand problems, alternatives, opportunities and solutions.Reporting: Documentation process in which results are made available in a written document, on the basis ofwhich third parties/the public can make their comments, providing for feedback on the analyses made,alternatives and decisions.

Source: Fischer, 2007

Box 7.2: Specific methods used in screening(UN, 2006f)

8 Citizen Control 8

7 Delegated Power 7

6 Partnership 6

5 Placation 5

4 Consultation 4

3 Informing 3

2 Therapy 2

1 Manipulation 1

Source: following Arnstein, 1969



Petts and Leach (2000) discuss what appropriatelevels of involvement may be in differentsituations. They recommend ‘fitting methods topurpose’, depending on the specific aims ofinvolvement along the lines described in Table9.1. They point out that there may be differentaims at different stages of the EIA processranging, for example,

“from the elicitation of values relevant tosite selection at a project design stage tothe optimisation of trust and credibility atthe monitoring stage.” (Petts and Leach,2000, p.20)

The exact format of public involvement is goingto depend on the specific EIA situation. However,as a ground rule, it should commence during thepreparatory stages of a project proposal andshould continue throughout the EIA process. Thisis subsequently described further.

9.1.1 Involvement during screeningIn certain cases, either the project proponent or theresponsible authority may want to involve thepublic as early as possible during screening inorder to obtain an idea about likely impacts. Thiscan help to decide whether an EIA or an IEE isrequired. Also, information obtained in this way canassist in setting up scoping and other later stages.

Table 9.1: Matching public participation aims with appropriate involvement levels

AimTo satisfy statutoryrequirements to consult

To resolve conflicting views

To increase transparency

To increase defensibility

To change people’s viewsabout an issue througheducation

To improve services

To determine needs anddesires

To empower citizens

To enable social learning

Applicable method levelApplicable method level1: Education and information provision and/or2: Information feedback

4: Extended involvement

1: Education and information provision and/or2: Information feedback and/or3: Involvement and consultation and/or4: Extended involvement

2: Information feedback and/or3: Involvement and consultation and/or4: Extended involvement

1: Education and information provision and/or4: Extended involvement

2: Information feedback and/or3: Involvement and consultation

2: Information feedback and/or3: Involvement and consultation and/or4: Extended involvement

1: Education and information provision and 4: Extended involvement

1: Education and information provision and/or4: Extended involvement

Source: Petts and Leach (2000, p.20)


9.1.2 Involvement during scopingWhile public involvement during EIA screening isstill somewhat unusual, it is a common feature atthe scoping stage. This can help the identificationof all potentially significant issues. The terms ofreference for the EIA can thus be designed in atransparent and responsible manner. In thiscontext, requirements for public involvementduring the forthcoming stages of EIA should beformulated. A good starting point to publicparticipation at this stage is to conduct astakeholder analysis. What this means is furtherexplained below.

9.1.3 Stakeholder analysis There are various ways to involve the public inpublic decision-making. Many academics andpractitioners involved with EIA consider astakeholder analysis to be a prerequisite first stepfor sound public participation (World Bank 2007;Schwartz and Deruyttere 1996). A stakeholderanalysis can be done, using various straight-forward methods (DFID 1995, section 2) and isundertaken in order to

“identify and understand the subgroupswithin the population to be consulted,relations of power among thesesubgroups, and the extent to whichcommunity organisations represent allinterest groups” (Schwartz andDeruyttere, 1996).

The outcome of a stakeholder analysis thusinforms the mix of methods to be used forconsultation (See: DFID 1995, section 2, forexample). International development agenciesnaturally place a high importance on stakeholderanalysis, as it is needed for orientation to thesituation on the ground and to understand theneeds, interests, and relative strengths of thevarious stakeholders.

The involvement of the public at the actualassessment stage i.e. when the EIA report isbeing prepared, can help to (UNEP, 2002b,p.169):

l “avoid biases and inaccuracies in analysis;l identify local values and preferences;l assist in the consideration of mitigation

measures; andl select a best practicable alternative”.

This is the stage where most EIA systemsglobally have provisions for public involvement.Obtaining feedback from the public on the EIAreport is crucial, as this should combine allexisting information on baseline data, the projectand its alternatives, as well as mitigation. It isimportant to keep in mind that asking for writtencomments may be daunting for parts of thepublic, e.g. the part which is not well educatedand literate. Public hearings or meetings may beheld at this stage. In this context, it is importantto consider that some people may not becomfortable speaking in public.

9.1.4 Involvement during implementationand follow upEnvironmental impacts of projects should bemonitored during construction and operation.Representatives of local communities shouldparticipate in this follow up process. This canhelp devising remedial action in case problemsarise. Furthermore, it can help promote goodrelations with local people or communitiesaffected by a development.

9.2 ‘The public’ and ‘public interest’The ‘public’ is not a monolithic entity. Rather, it isa diverse set of people and groups that tend tohave a wide range of interests. However, despitethis diversity of interests, with regards toenvironmental issues, it is still possible to speakof a ‘public interest’ (Taylor, 1994). Thus,addressing environmental issues such as ozonedepletion, global warming, and pollution andresource depletion that threaten health andwelfare clearly is in the public interest. EIA is,therefore, an instrument designed to enhancepublic interest. The concept of ‘public interest’ isdiscussed further below.

9.2.1 What is public interest?The notion that there is a ‘public interest’ has



been debated for at least 100 years. The firstauthor contesting that there is something akin toa public interest was Bentley (1908), who hasbeen labelled the ‘father’ of interest group theoryin political science. According to him, “society isnothing other than the complex of groups thatcompose it…”, concluding that “we shall neverfind a group interest of … society as a whole (inTaylor, 1994, p.88).” Today, authors withpostmodern leanings are following in Bentley’sfootsteps, contesting and deconstructing theconcept and ultimately denying the existence of acommon welfare or ‘public interest’ (See:discussion and references in Campbell andMarshall, 2000).

However, many authors have challenged theclaim that there is no public interest. Taylor (1994,p.89), for example, suggested that the fallacy ofsuch arguments lies in

“the twin assumptions that society iscomposed only of groups with conflictinginterests, and that where conflicts ofinterest exist between groups therecannot also be areas of consensus co-existing within the conflicts.”

He explored several arguments around these twoideas and concluded that some interests are sofundamental that they must be recognised tosome degree in any community. Taylor thusrejected the argument that there can be noconceptually coherent theory of the publicinterest. Different interests notwithstanding, heproposes that the interests shared in common byany group or person constitutes the publicinterest. However, he also suggested that theremay be occasions when an action is in the publicinterest, but where, say, due to limited resources,

“we think it morally right (or of greatermoral priority) to do something whichpromotes the interests of a particulargroup – say, a group which is especiallydisadvantaged…”

This also means that public interest doesn’tnecessarily represent the interest of the ‘majority’in a society.

9.2.2 Implications for EIAThe argumentation above provides a firm basisfor defending environmentally sound decision-making and actions aimed at by EIA, as these arein the public interest. Overall, the concept of apublic interest is useful and necessary ifprofessional endeavours are to have anycoherence at all and be anything other thanpartisan and arbitrary (Posas and Fischer, 2008).

9.3 The public, stakeholders andtheir representativesThe section above established that while there isa heterogeneous public, there are actions thatcan be said to be in the interest of the public.This does not mean, though, that minorityopinions or actions should not be protected.Since in EIA it is not possible to consult everyonethat might be considered to constitute ‘thepublic,’ current practice is to identify stakeholderswho can collectively be seen to represent it(Abaza et al., 2004). Stakeholders are individualsand groups who have a ‘stake’ or ‘interest’ thatmay be affected by a decision on a proposedproject (Abaza et al., 2004, p.69). Often, whenstakeholders are being identified, broadcategories will be defined and individualsassigned to one of them. Stakeholders arecommonly divided into primary and secondarystakeholders, where the former are likely toexperience direct effects and the latter may beindirectly affected or have the ability to influencethe decisions taken (i.e. international conservationNGOs or media). Public participation as practicedin EIA can be defined as:

“any of several ‘mechanisms’ intentionallyinstituted to involve the lay public or theirrepresentatives in administrative decision-making” (Beierle and Cayford 2002, p6).

Public participation thus refers to organisedbureaucratic processes, excluding individual


actions. It is at times distinguished fromstakeholder involvement, in that it is seen as:

“a popular democratic notion of laycitizens’ involvement in local issues…’

Whereas the latter is:“… a more pluralist notion of interestgroup involvement in policy questions”(Beierle and Cayford 2002, p.6).

9.4 History and rationale of publicinvolvement in EIA Various authors have written about the historyand reasons for public involvement in decision-making, including environmental related decision-making in the 20th Century (Beierle and Cayford,2002; Abaza et al., 2004; Petts and Leach, 2000;Webler and Renn, 1995). Based on theirperspectives, subsequently an outline is providedon the history and rationale of public involvementin EIA (following Posas and Fischer, 2008).

9.4.1 Public participation, an evolvingaspect of participatory democracyWebler and Renn (1995) raised several points onthe historical development of public participationin environmental decision-making. Theysuggested that:l In countries of Anglo-Saxon tradition, public

participation is synonymous with participatorydemocracy, and that people in such countries“associate the very concept of democracywith the activity of participating ingovernmental decision-making” (Webler andRenn, 1995, p17);

l Public participation has been a major topic ofdebate in the U.S. and all European countriessince the beginning of the 19th Century; theearly development of democracy in theaftermath of the French and Americanrevolutions resulted in gradual integration ofcitizens in the political system, starting withvoting;

l In addition to citizens fighting for equal rightsin the political sphere, attention also turned toparticipation within the economic system (i.e.labour movements); and

l Although social movements and citizens’initiatives have been advocating for moredirect influence in political decision-makingsince the 1920s, their efforts, with a fewexceptions, were not effective until theecological movements of the 1970s.

9.4.2 Expanding role for the publicPetts and Leach (2000) saw a convergence ofdifferent pressures for public participation,including the need to consider sustainabledevelopment, a falling trust in experts, publicfears about risks to the environment and health,among others. They traced the roots of growinginterest in public participation in various areassuch as land use planning and regeneration,among others. In a development cooperationcontext, still other factors were identified asproviding impetus for greater public participation.These include trends at the global political levels,policies in multi- and bi-lateral developmentorganisations, and lessons learned fromevaluations of projects and policies. Publicinvolvement and consultation have been integralto EIA since 1970.

9.4.3 Three models of public decision-makingBeierle and Cayford (2002) wrote about the historyof public participation from a U.S. perspective,which simultaneously mirrored global trends inmany democratic societies. They charted ahistorical progression from managerialism (late1800s to 1950s) to pluralism (1960s to 1990s) topopular democracy (1990s to present): l Managerialism rested on the managerial

model in which government administratorswere entrusted with identifying and pursuingthe common good, particularly in the form ofsocial welfare maximisation i.e. the greatestgood for the greatest number for the longesttime;

l Pluralism began to replace managerialismwhen government administrators stoppedbeing seen as objective decision makers inthe public interest, but rather as arbitersamong different interests within the public.Unlike welfare maximisation, pluralism does



not recognise an objective sense of the‘public good’ but rather a “contingent publicgood to be debated and arrived at bynegotiation among interests”; and

l The third stage resting on popular democratictheory stresses the importance of the act ofparticipation, “not only in influencingdecisions but in strengthening civic capacityand social capital” (Beierle and Cayford,2002, p.4).

It is important that while the three perspectivesreflect a time sequence, they continue to coexistand compete in contemporary debates regardinghow environmental policy should be made andimplemented. The strength of commitment toeach of the three models varies by country andrelates to cultural traits, agency organisationalculture, and sector, e.g. transport planning tendsto be driven by a more managerial approachwhile spatial or land use planning is influenced bypluralism and popular democracy.

Beierle and Cayford (2002) gave justifications forpublic involvement in each of the abovementioned three perspectives. They suggestedthat during the managerial era, the purpose ofpublic participation was to ensure thatgovernment agencies were acting in the publicinterest. In pluralism and popular democracy, onthe other hand, public participation is seen asnecessary for establishing what the publicinterest actually is, i.e. the purpose of publicparticipation is not merely to provideaccountability but help develop the substance ofpolicy. This characterisation of the changing roleof public participation is reflected in manyliteratures, including that on EIA. It is in line withthe recent emphasis in the EIA literature on sociallearning (Sinclair and Diduck 2001; Jha Thakur etal. , 2009; Fischer et al. , 2009). This means thatin addition to increasing the quality of decisions(Beierle, 2002), it is clear that public participationrationales are now going even one step furtherwith the expectations around social learning, i.e.mutual learning and transformation of values.

9.4.4 Importance of public participation inpublic decision-makingHeiland (2005) provided for a selective summaryof rationales for public participation in the EIAprocess. Among them is ‘enhancing thetransparency of decision-making processes’ and‘enhancing the completeness, validity andreliability of the relevant information’. The beliefthat the public and their participation is importantand helps create better decisions is not just atheoretical idea. An analysis led by Beierle (2002)of over 239 U.S. published case studies ofstakeholder involvement in environmental publicdecision-making indicated that the quality ofdecisions tends to improve with stakeholderinvolvement.

Important issues not raised in Heiland’s table arementioned by Wilkins (2003) in relation to thesubjective elements of EIA. Specifically, heargued that EIA opens opportunities for sociallearning and development of less individualisticand more communitarian values. EIA, he says,provides

“a temporary community forum at whichvarious perspectives and viewpoints canbe considered in the decision-makingprocess and in discourse, likely resultingin stronger community values and thepossibility that longer-term environmentaldiscourse can be fostered and generatedin other fora” (Wilkins 2003, p.410).

He sees EIA’s strengths in its qualities of publicparticipation, transparency, promotion ofdiscourse, social learning, and transformation ofvalues. These latter kinds of ideas are still youngin EIA, but are becoming increasingly popular(Jha-Thakur et al., 2009).

9.5 (International) legislationpertaining to EIA and public decision-makingLegislative changes parallel the historicaldevelopment of public participation. Francis-Nishima (2003) traced the development of


international instruments that govern informationaccess and participation in environmentaldecision-making, starting from the 1948 UniversalDeclaration of Human Rights, elaborated by theUN General Assembly. She cited over two dozeninstruments, but particularly singled out the 1992Earth Summit’s Rio Declaration on Environmentand Development as the most historicallyimportant. Its international acceptance - 178nations adopted it at the Earth Summit - andparticularly its Principle 101 on participation inenvironmental matters are of particularimportance. They underpin numerous subsequentregional initiatives and national laws, as well asinternational institution procedures andapproaches to public participation.

Agenda 21, a comprehensive action plan to betaken globally, nationally and locally, was alsolaunched at the Rio Summit. It

“relied heavily on the role of civil societyin developing, implementing, andenforcing environmental laws and policies… [and it also emphasised] access toinformation, public participation, andaccess to justice (Francis-Nishima, 2003,p.10).”

The same author also reviewed regionalagreements in addition to international ones. TheUNECE Aarhus Convention is the only regionalagreement of its kind. This is further elaboratedon below.

The United Nations Economic Commission forEurope (UNECE) Convention on Access toInformation, Public Participation in Decision-making and Access to Justice in EnvironmentalMatters was adopted on June 25th, 1998, inAarhus, Denmark at the Fourth MinisterialConference in the ‘Environment for Europe’process. The Aarhus Convention, as it is more

commonly referred to, entered into force onOctober 30th, 2001. As of April 22nd, 2013, therewere 47 parties to the convention and it has beenratified by nearly all European countries (UNECE,2007).

Although regionally focused, the AarhusConvention has global significance. The formerUN Secretary General, Kofi Annan, called it an“impressive” elaboration of Principle 10 of the RioDeclaration and “the most ambitious venture inthe area of environmental democracy so farundertaken under the auspices of the UnitedNations” (UNECE website). The AarhusConvention’s significant features include:l linking environmental rights and human rights

and government accountability andenvironmental protection;

l establishing that sustainable developmentcan be achieved only through theinvolvement of all stakeholders; and

l granting rights to the public and imposingobligations on parties and public authoritiesregarding information access, publicparticipation and access to justice.

These features make the Aarhus Conventionmore than an environmental agreement, but alsoa Convention about government accountability,transparency and responsiveness. Both, EIA andSEA are covered in the Convention; EIA in Article6: Public participation in decisions on specificactivities; and SEA in Article 7: Publicparticipation concerning plans, programmes, andpolicies relating to the environment. Severalprinciples are common to both EIA and SEAsections, including reasonable time-frames forparticipation, early public participation, and thatdecisions need to take due account of theoutcome of the public participation. It isnoteworthy that the Convention specifies that“the public which may participate shall beidentified by the relevant public authority”

1 Principle 10 states: “Environmental issues are best handled with participation of all concerned citizens, at the relevant level. At the nationallevel, each individual shall have appropriate access to information concerning the environment that is held by public authorities, includinginformation on hazardous materials and activities in their communities, and the opportunity to participate in decision-making processes.States shall facilitate and encourage public awareness and participation by making information widely available. Effective access to judicialand administrative proceedings, including redress and remedy, shall be provided (UNCED, 1992).”



(UNECE 2007; see also Chapter 15 of thishandbook), thus recognising the diversity ofpublics from which an appropriate ‘public’ willneed to be chosen and involved.

9.6 Participation and consultationtechniques and their suitability fordifferent situationsThere are many different methods and techniquesfor public participation. Aschemann (2004)allocated methods to the three categories“information”, “consultation” and “more activemeasures/methods”. These are shown in Table 9.2.

Westman (1985) provided for a comprehensiveoverview of public involvement methods. He alsolooked at the effectiveness of these methods withregards to the overall objective of a particularparticipation exercise. This is shown in Table 9.3.

Techniques that may be used when involving thepublic include e.g. the use of GeographicInformation Systems (GIS) along with otherinformation and communication technology (ICT)tools (See e.g. Fischer, Kidd and Thakur, 2008).Furthermore, the Delphi method may be used,which is a structured communication technique,

originally developed as a systematic, interactiveforecasting method which relies on a panel ofexperts. In a particular EIA, methods andtechniques should be chosen, depending on thespatial and administrative level of the project. Formajor projects in small municipalities, the wholepopulation could be invited to attend workshopsor hearings. In a large municipality, this may notbe possible. The use of the internet should beseen as an additional measure for participation,however, a public participation exercise shouldnot entirely depend on it as, for example, elderlypeople and other (disadvantaged) groups may nothave access to it. Any confidentiality issuesshould be disclosed in advance.

There is no ‘cookbook’ approach for selecting themost suitable and appropriate participationmethods and techniques. Rather, tailor-madesolutions have to be found that should take intoaccount the subject of EIA, considering itscontents and level of detail as well as its stage inthe decision-making process. Moreover, thatdifferent methods and techniques require differentamounts of time and money needs to be takeninto account, e.g. to set up an internet homepageis normally cheap, while a TV spot tends to be

Table 9.2: Participation methods and their allocation to three categories

Information methods andtechniques

Consultation methods andtechniques

More active and mutualparticipation methods

l Making a project or PPP related map or plan publicly accessiblel Information on a project or PPP via flyers, leaflets, newspapers, radio,

television and/or internetl Information on and presentation of a project or PPP through models,

exhibitions and/or public displays

l Possibility to comment on documents related to a project or PPPl Hearings, meetings and/or workshops on a project or PPP with discussionl Use of a qualified public (e.g. NGOs, experts) representing the general

public

l Mediationl Mediated modellingl Consensus conferencel Citizens’ jury; andl Roundtable.

Source: Adapted from Aschemann, 2004


very expensive. The maintenance and update ofan internet homepage could be time consuming,while the public display of a map could be donequickly. Additionally, the environmental anddemographic profile of a country, itsenvironmental problems and its stage ofeconomic, social and technological developmentshould be kept in mind when choosingappropriate (public) participation methods andtechniques.

The International Association of ImpactAssessment (IAIA) offers a concise backgroundstatement on various dimensions of publicparticipation in EIA (Andre, 2006), and the WorldBank (2007) and Canadian InternationalDevelopment Agency (CIDA, 2007) each offer acollection of resources pertinent to public

participation in EIA processes. IAP2 (2004)summarises key points and what can goright/wrong in a wide range of techniques; it sortsthem by the nature of participation and number ofparticipants. Rauschmayer and Risse (2005)undertook an analysis of certain techniques, andthe OECD DAC (2006), CIDA (2007) and theWorld Bank (2007) discuss participationtechniques in a development cooperationcontext. Useful sources of guidance for designingand undertaking a participation process in thecontext of EIA and public environmental decision-making have been developed by Petts and Leach(2000), Beierle and Cayford (2002), and the WorldBank (1999).

Several authors have made suggestions on howto select the appropriate level of public

Provide Cater for special Two way Impact oninformation interests communication decision-making

Explanatory meeting, slide/film presentation u ½ ½ -

Presentation to small groups u u u ½

Public displays, exhibit, models u - - -

Press release / legal notice ½ - - -

Written comment - ½ ½ ½

Poll ½ - u u

Field office u u ½ -

Site visit u u - -

Advisory committee, task force, ½ ½ u u

Working groups of key actors u ½ u u

Citizen review board ½ ½ u u

Public enquiry u ½ ½ u/-

Litigation ½ - ½ u/-

Demonstration, protest, riots - - ½ u/-

u = yes ½ = partly - = noSource: adapted from Westman (1985)

Table 9.3: methods of public participation and their effectiveness



engagement in decision-making (Beierle andCayford, 2002; Petts and Leach, 2000). Beierleand Cayford (2002) suggested that before settingup anything at all with regards to publicparticipation, decision makers need to considerthe following two commitments that go hand inhand with seeking participation (2003, p. 64): 1. committing to some degree of flexibility and

open-mindedness regarding the nature of theprocess and its outcomes, as participantsmay want to redefine a problem or bring thefocus on to other issues; and

2. recognising the legitimacy of public valuesand understanding that those values maylead to priorities and conclusions thatagencies find undesirable or inconsistent withtheir perception of the public interest.

A third commitment might be to keep in mindthat creative options may be possible, such asthe famous case of siblings fighting over the lastlemon, and then finding out one wanted to makelemonade and one a lemon cake using the rind,so their needs could both be met. A fourthcommitment is to take the public contribution intoaccount in decision-making and mention inreports how public concerns and issues wereaddressed or reasons why certain issues couldnot be addressed.

9.7 Public participation in Pakistan Public participation or consultation in the form ofpublic hearing is mandatory in Pakistan undersection 12(3) of the Pakistan EnvironmentalProtection Act (PEPA) 1997 and section 10 ofIEE/EIA Regulations, 2000 during the EIA reviewprocess in Pakistan. A separate body ofguidelines for public consultation has beenprepared by the Pakistani EnvironmentalProtection Agency (Pak-EPA) in the light of theWorld Bank‘s Participation Sourcebook, 1995.The guidelines suggest that project proponentsshould hold comprehensive discussions with theaffected public and adequately incorporate their‘genuine’ concerns in the project design andmitigation measures to avoid adverse effects.

9.7.1 Guidelines for public consultationPublic consultation and participation during EIAreview is a legal requirement in Pakistan. Thissection provides an overview, including some ofthe propositions, considered important within thelocal context, of the guidelines for publicconsultation formulated by the Pak-EPA as a partof the Pakistan Environmental AssessmentPackage (GoP, 1997d).

Levels of public involvement:

Despite the title of guidelines as “publicconsultation”, the difference among various levelsof participation is highlighted for the sake ofclarification, as follows:

“Informing: one way flow of information from theproponent to the public;

Consulting: two way flow of information betweenthe proponent and the public, providingopportunities for the public to express views onthe proposal; and

Participating: proponent and the public involvedin shared analysis, agenda setting and decision-making, through reaching consensus on the mainelements” (GoP, 1997d p.2).

For effective participation, it is also emphasisedthat

“proponents should explain their proposals clearlyto affected communities, actively listen to thecommunities’ responses, and make prudentchanges to the proposal to avoid or mitigateadverse impacts. Where proponents are able togo beyond this to “participation”, they will achieveeven greater benefits for themselves and for thestakeholders.” (GoP, 1997d, p.3)

The Public or Stakeholders as suggested in theguidelines:

Composition of the public or stakeholders mayvary from project to project and from country to


country. There are some universal as well assome context specific types of stakeholders. Thefollowing categories of stakeholders have beenidentified in the Pakistani guidelines:

Local people: Individuals or groups in the localcommunity having indigenous knowledge;

Other affected communities: communities andminorities that may not be living near theproject site but that are likely to be affectedindirectly;

Proponents: proponents of the same and otherprojects situated around the project site andthose who are likely to be affected indirectly;

Government agencies and local councils:concerned officials of concerned governmentdepartments or agencies includinginfrastructure/utility service providers and localcouncils e.g. Tehsil Municipal Administrations;

Non-government organisations (NGOs):representatives of local and international NGOsmay or may not be working for environmentalprotection especially those who may not have aconflict of interest with the proponent oraffectees;

Influential people: large landholders, heads oftribes or clans, members of Parliament, mayorsand members of local councils; and

Others: anyone who can make a significantcontribution, e.g. independent experts of relevantprofessions, academia, consultants, etc.

In some situations, it is important to consult withrepresentatives of particular interest groups. Insuch situations, the concerned group should beallowed to choose their representatives. It mustalso be ensured that “fair and balancedrepresentation of views is sought and that theviews of the poor or minority groups are notoverwhelmed by those of the more articulate,influential or wealthy” (GoP, 1997d, p.5).

Principles of effective public involvement:Some basic principles have been suggestedwhich may help in achieving a positive outcomeand enhancing the efficacy of public involvementexercise (Box 9.2).

Levels and techniques of public involvement:The guidelines present a comparative view ofvarious communication levels, techniques ofpublic involvement and the objective of publicconsultation which every technique can possiblyachieve. This follows closely best practiceprinciples as described in the internationalprofessional literature (See: Table 9.3). It isobvious from the table that public hearing, asrequired and practiced during EIA review inPakistan, is a comparatively weak technique ofpublic consultation or participation. Other thanfulfilling the legal requirement, it is suggested thatthe proponents and EPA officials should try

Box 9.2 Principles of effective public involvement

l Provide sufficient and relevant information understandable to non-experts.

l Allow sufficient time for the stakeholders to comprehend the provided information and consider its possibleimplications.

l Allow sufficient time for stakeholders to raise their concerns.

l Respond to each and every issue raised by the stakeholders for the sake of building trust in theconsultation process.

l Select the timing and venue of consultation which are most suitable to the majority of the stakeholders andprovide them with an egalitarian environment to express their views.

Source: Adapted from GoP, 1997d



different techniques of communication and publicinvolvement which suit specific objectives of theproposed project and the local or cultural contextas well as the stakeholders’ level of literacy. It has been suggested to involve the stakeholdersduring the following stages of the EIA process: l Scoping;l Assessing impacts; l Mitigation and impact management; l Reviewing and decision-making; andl Monitoring and auditing.

The guidelines also advocate participation ofwomen and the poor by doing gender analysis,identifying and addressing cultural andeducational constraints and using locallanguage(s) as well as visual methods ofcommunication/consultation. In these respects,local and international good practice exampleshave also been cited. All of the above mentionedaspects of public consultation, as suggested inthe Pak-EPAs guidelines, are comparable withthose suggested in other developing as well asdeveloped countries. However, many deficienciescan be found in the actual practice of publicconsultation, which may possibly be overcome bytaking certain measures (See: Nadeem andFischer, 2011).

9.7.2 Practical experiencesWhile in more developed EIA systems, publicparticipation is obligatory during scoping (Wood,1999), in Pakistan the proponent does not legallyneed to involve the concerned public during EIApreparation. Some proponents, particularly offoreign-funded public sector projects, however,do consult affectees, even if it is mainly done forthe purpose of collecting socio-economicbaseline data and occasionally for obtaining theirviews on a project.

Stakeholders are given 30 days, following anotice published in two national dailynewspapers, for submitting written commentsbefore the public hearing. The venue for a publichearing is normally a high class hotel in the cityor office of the concerned EPA or public sector

proponent which are often inaccessible by thedirectly affected indigenous people who are livingin remote areas (Nadeem and Hameed, 2006c). Inaddition, stakeholders are not informed abouthow their concerns have been incorporated intothe EIA report and final decision.

Similar inadequacies pertaining to publicparticipation in EIA have also been reported forsome other developing countries, for instance,India, Bangladesh, Sri Lanka, Thailand, Indonesiaand Malaysia (Paliwal, 2006; Momtaz, 2002;Zubair, 2001; Boyle, 1998). In spite of all theodds, some instances of environmental activismdo exist in Pakistan. These include the casesdiscussed by Nadeem (2010), including theKarachi Elevated Expressway Project, LahoreCanal Bank Road Remodelling Project, and theLahore Ring Road Project. He states thatawareness about the environmental impacts ofmega projects is rising particularly among thoseliving in the urban areas of Pakistan.

This awareness is leading to active participationin the public hearings and follow-up of theoutcome of EIA related decisions. According to anews report, the alignment, as in the approvedEIA report, of the Karachi Elevated ExpresswayProject was withdrawn by the proponent,.CityDistrict Government, Karachi, due to legal andfinancial constraints in the land acquisition.Instead, the route alignment suggested by thestakeholders during public hearing was beingpursued (Daily Times, 2007). Similarly, some ofthe environmental NGOs and stakeholders of theLahore Canal Bank Road Remodelling Projectfiled a petition in the Lahore High Court againstthe proposed project and issuance ofenvironmental approval by the Punjab EPA. Lateron, an appeal was filed in the Supreme Court ofPakistan. The Court after various hearings andupon the recommendations of a mediationcommittee, (set up by the Court), directed thePunjab government and the EnvironmentProtection Agency (EPA) “to ensure that minimumdamage is caused to the greenbelt and every treecut is replaced by four trees of the height of 6/7


feet, and this replacement when commenced andcompleted should be notified through pressreleases for information of general public and thecopies of that should be sent to the Registrar ofthe apex court ” (Sigamony, 2011).

Likewise, as a result of protest by the affectees, asection of Lahore Ring Road Project, proposed totraverse through Gulshan-e-Ravi HousingScheme, had been withdrawn. The proponentdepartment, Communication and WorksDepartment of the Government of Punjab, hadasked its consultants to design the said sectionthrough new route alignment avoiding Gulshan-e-Ravi (The News, 2006). Keeping in view theabove scenario, it can be stated that although theactual practice of EIA has yet to be evolved intosubstantial public participation, still there are

some examples showing that public involvementin EIA is leading to project changes.

9.8 Practical element: Visit a public hearing or conduct a publicparticipation mock exercise with the students,

and / or:

Review World Bank Safeguard policies(environmental assessment and disputed areas):http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTLAWJUSTICE/0,,contentMDK:22226433~menuPK:6256357~pagePK:148956~piPK:216618~theSitePK:445634,00.html



This chapter is divided into three sections. First, what baseline data need tobe collected and reported on in EIA is explored. Secondly, the role ofalternatives in EIA is elaborated upon and finally, the importance of avoidance,mitigation, as well as compensation measures is discussed. The main sourcesthis chapter draws on include the Asian Development Bank (2003), EuropeanCommission (1999), Fischer et al. (2008; chapter 14 by Herberg: 143-150; andchapter 17 by Rajvanshi: 166-182), Department of Environmental Affairs andTourism (2004a) and UN University (2006h).

10.1 What baseline data need to be collected and reportedon in EIABaseline data need to allow for a description of a study area in terms of theexisting environmental resources and the likely future state. This is the basisfor assessing impacts of a planned development. In EIA, baseline data shouldnot just be presented, but the method applied to gather information should bedescribed, including what data sources are used and how. As much aspossible, the baseline information should be presented in e.g. tables, figuresand maps. According to the Asian Development Bank (2003), baselineenvironmental information in EIA should include the following:

(i) Physical Resources such as:.l atmosphere (e.g. air quality and climate);l topography and soils;l surface water;l groundwater; andl geology / seismology

(ii) Ecological Resources such as:l fisheries;l aquatic biology;l wildlife;l forests;l rare or endangered species;l protected areas; andl coastal resources;

10 EIA baseline data collection,consideration of alternatives and mitigation


(iii) Economic Development such as:l industries;l infrastructure facilities (e.g. water supply,

sewerage, flood control);l transportation (roads, harbours, airports, and

navigation);l land use (e.g. dedicated area uses);l power sources and transmission; andl agricultural development, mineral

development, and tourism facilities.

(iv) Social and Cultural Resources such as:l population and communities (e.g. numbers,

locations, composition, employment);l health facilities;l education facilitie;sl socio-economic conditions (e.g. community

structure, family structure, social well-being);l physical or cultural heritage; l current use of lands and resources for

traditional purposes by indigenous peoples;and

l structures / sites of historical, archaeological,paleontological, or architectural significance.

The scope and quantity of data collected willdepend on the specific EIA situation. The betterthe understanding of the potential significantimpacts, the more targeted the baseline datacollection exercise can be. With regards to thetype of data used, in EIA, existing data arenormally used alongside data that are specificallygenerated for assessment. Data may be neededin all of the above mentioned categories (i) to (iv).

It is important that different skills and expertiseare needed within an EIA team in order to be ableto (a) collect the right data that are meaningful ina specific situation, and (b) make sense of thewide range of data and information collected inan EIA. Teams often include ecologists andbiologists with different specialism, e.g.entomologists and botanists, geographers,landscape planners, as well as e.g. climatologists,toxicologists and engineers with specificknowledge, on e.g. noise, water or groundstability.

10.2 Role of alternatives in EIAAlternatives serve a key purpose in EIA. They areneeded in order to “find the most effective way ofmeeting the need and purpose of the proposal,either through enhancing the environmentalbenefits of the proposed activity, and throughreducing or avoiding potentially significantnegative impacts” (Department of EnvironmentalAffairs and Tourism, 2004a, p.4). Theconsideration of alternatives in EIA needs to startas early as possible, i.e. during screening andscoping. However, despite their importance,frequently they are inadequately handled. Thismeans that at times feasible alternatives are notbeing considered and unfeasible alternatives arebeing assessed in order to influence certainoutcomes.

The consideration of realistic alternatives isimportant in order to ensure that the EIA is notreduced to simply defending a particular projectproposal which a proponent may want. In thiscontext, it is important for EIA to include anunbiased, proactive consideration of options forbeing able to determine the best possible courseof action. The way in which alternatives areapproached during the early phases of an EIA willoften determine the subsequent unfolding of thewhole EIA process.

An inadequate consideration of alternatives is,therefore, often an indication of a biased processand the dissatisfaction with EIA processes isfrequently connected with this. As aconsequence, the likelihood of controversy in EIAincreases. On the other hand, the confidence ofstakeholders will grow when alternatives areconsidered in an open and transparent mannerand there is public acceptance of the assessedalternatives.

According to the Department of EnvironmentalAffairs and Tourism (2004a, p.4) obstacles to thefull consideration of alternatives include:l “Technological obstacles, where high costs of

a particular technology may prevent it frombeing considered as a viable option, or the



lack of technological development maypreclude certain options from consideration;

l Resource availability obstacles, which maylimit the range of alternatives in a particularcontext; and

l Political economy or intellectual obstacles, inwhich barriers may be imposed by groups orindividuals, usually holding positions ofeconomic or political power, who wish toadvance a particular agenda”.

Alternatives provide a framework for subsequentdecision-making (Glasson et al., 1999). Theirimportance therefore cannot be overestimated.Being clear about the impacts of relevantalternatives is the basis for sound decision-making. In this context, decision-makers andothers involved in EIA need to be given tailor-made and adequate information so that the bestpossible alternative can be chosen. In thiscontext, trade-offs between different factorsshould be made clear.

10.2.1 Types of alternatives that can beconsideredDifferent types of alternatives usually exist in anyproject situation. However, not all of them arenecessarily appropriate for consideration in aspecific EIA. For example, certain policy optionsmay not be available at the project level.Consideration therefore needs to be given tothose that are appropriate and suitable. In thiscontext, the Department of Environmental Affairsand Tourism (2004a) states that an importantstarting point is to consider the following aspects:l Who is the proponent? (private or public

sector);l Who are the intended beneficiaries? (general

public, select groups or individuals); and l Where is the proposal to occur? (zoned land

use, common property or private property).

There are discrete and incremental alternatives.The former are identified during screening andscoping, the early phases of an EIA. The lattercan arise during EIA as a reaction to potentialnegative impacts that have been identified. They

are developed to reduce adverse impacts and toenhance associated benefits. Frequently,incremental alternatives are discussed whendevising mitigation measures. They may also beincluded in the final project proposal.

According to the Department of EnvironmentalAffairs and Tourism (2004a), ten types orcategories of alternatives can be identified. Theseare summarised in Box 10.1 and are furtherdescribed below.

An activity alternative would be an alternative tothe proposed project, i.e. a different project. Thiscould be the extension of a tram, rather than anew road, or an incinerator, rather than a newlandfill site. In many instances, it may not bepossible to use activity alternatives in EIA at theproject level, due to e.g. specific legalrequirements. They are often supposed to beconsidered at higher tiers of decision-making, i.e.at the level of policies or plans.

Location alternatives are frequently considered inproject EIA. They may include an entirely differentlocation for e.g. a new power plant or the locationof a road bypass on the Eastern rather than theWestern side of a town. There may be certainrestrictions with regards to location alternatives,for example, if a certain patch of land is to bedeveloped.

Box 10.1: Different types of alternatives thatmay be considered in EIA

1. Activity alternatives;2. Location alternatives;3. Process alternatives;4. Demand alternatives;5. Scheduling alternatives;6. Input alternatives;7. Routing alternatives;8. Site layout alternatives;9. Scale alternatives; and10. Design alternatives.

Source: Following Department of Environmental Affairs andTourism (2004a)


Process alternatives are those considered toachieve the same outcome or output. Forexample, a certain output of electricity may beachieved by different renewable or non-renewablemeans. The scope for considering specificprocess alternatives will depend on a particularsituation. Similarly to activity alternatives, theymay be considered at higher tiers, e.g. in anelectricity policy.

In the same way, demand alternatives are often tobe considered above the project level ofdecision-making. Taking the electricity examplefrom above, a question arising would be ifadditional electricity is needed after all or if thereare other ways for reducing the need forelectricity. With regards to housing, this mayinclude the consideration of low energy homes.Also, the need for waste treatment facilities canbe reduced if less waste is being produced.

Scheduling alternatives are also known assequencing or phasing alternatives. For example,activities that generate noise may be scheduledto only happen at certain times of the day. Withregards to many airports, night time restrictionsare often in place in order to protect localresidents from noise.

Input alternatives are often particularly relevantfor industrial development projects. For example,different combustion materials may beconsidered in the production of a product.Furthermore, different materials may be possiblein a product, e.g. card board or plastic.

Routing alternatives can be said to overlap tosome extent with locational alternatives. Routingalternatives are frequently considered for e.g.electricity transmission lines or new roads. Theyare often considered in connection with e.g.infrastructure corridors.

Site layout alternatives are design alternativesthat can help to reduce negative impacts bychanging the layout of e.g. a high rise building(local wind or shadow) or a factory so that e.g.

noisy activities do not happen next to aresidential area, but on the opposite locationalside of a proposed development.

Scale alternatives are about the size of aparticular development. They may include theconsideration of e.g. 50 rather than 100 housingor other units.

Finally, design alternatives can reduce negativevisual or landscape impacts. Incinerators, forexample, can be ‘hidden’ behind an interestingarchitectural design. A well-known example is anincinerator designed by the well-known architectHundertwasser in the city of Vienne.

The ‘zero’ or ‘no action’ alternativeThe ‘zero-alternative’ is also known as the ‘no-action’ alternative. This is an alternative whichassumes that the activity does not go ahead;therefore implying a continuation of the statusquo, i.e. no new development is happening. Thisis important in order to be able to judge howmuch better or how much worse theenvironmental situation would be in the absenceof any development. There are cases in which thezero alternatives can be considered the onlyviable major alternative to a proposeddevelopment. However, this does not mean it isnecessarily the best alternative from anenvironmental perspective. An example would beupgrades of existing industries where outdatedand polluting technologies may be replaced,resulting in fewer harmful emissions into e.g.soils, water and air.

Many EIA experts believe the zero alternativeshould be considered in every EIA. The WorldBank suggests that when evaluating the zeroalternative, it is important to take into account theimplications of foregoing the benefits of aproposed project (World Bank, 1996). Assessingthe zero alternative means describing andevaluating the baseline and establishing the likelyfuture state of the environment if no developmentis taking place.



10.2.2 Identification of suitable alternativesfor use in EIAThere are different types of alternatives that maybe considered in EIA. These have been describedabove. However, as already mentioned, not allalternatives are appropriate for assessment of aparticular project. Possible alternatives shouldtherefore be identified as early as possible in thepreparation of a project (e.g. during the pre-feasibility stage). While some may already beidentified during screening, the choice of themain alternatives should be achieved duringscoping. In this context, the process of choosingalternatives should be well documented. It shouldbe transparent how alternatives were identifiedand they should represent as wide a choice ofoptions as possible. As discussed in chapternine, stakeholders and potentially the generalpublic should play an important role whenidentifying alternatives.

There are a number of key questions that shouldbe asked when considering alternatives in EIA,including whether a certain alternative is“practicable”, whether it is “feasible”, “relevant”,“reasonable” and “viable” (Department ofEnvironmental Affairs and Tourism, 2004a). Inorder to be able to conduct a meaningfulassessment, it may be necessary to focus on afew alternatives only, i.e. eliminating others. Thewhole process involved in developing andassessing alternatives should be well-documentedand substantiated and explanations should beprovided as to why certain alternatives are beingconsidered and others not. Those alternativesincluded in EIA should be assessed thoroughlywith regards to their significant environmentalimpacts. In this context, technical and financialaspects should also be taken into account.

A generic process for identifying and analysingalternatives in EIA was introduced by theDepartment of Environmental Affairs and Tourism(2004a). It starts with an establishment of projectobjectives. This is followed by an identification ofalternative technologies. Having defined a rangeof possible technologies, resource requirements

should be determined for each of them (WorldBank, 1996). Alternatives should then bescreened in the light of environmental objectivesfor a particular area. In this context, efforts andcosts associated with potential data collectionand assessment should be taken into account.Location suitability and social acceptability needsto be carefully considered at this point.

Having established a shortlist of alternativetechnologies, the next step is to find a range ofpossible alternative locations, whichsubsequently should also be screened, using thesame criteria as above. Each chosen alternativethen needs to be evaluated and assessed, takinga comparative perspective. Alternatives must beassessed and evaluated at a scale and level thatallows for a comparison with the proposedproject. The assessment should focus on thepotential direct, indirect and cumulative impacts.When selecting a specific alternative, the criteriaused to do so need to be explained. Rejectedalternatives should also be described and thereasons for the rejection alternatives be given.Methods for comparing alternatives range fromvery simple descriptive and non-quantitativemethods, through methods based on varyinglevels of quantification to a full quantitativecomparison, in which all impacts are expressed inmonetary terms (See: chapter 8).

10.3 The importance of avoidance,mitigation, as well as compensationmeasuresIt is frequently difficult to reconcile newdevelopments with environmental protection andnature conservation if conflicts have beendetected, but the economic case is strong.Mitigation and compensation measures in EIAaim at preventing any significant negativeimpacts from happening. Overall, mitigation andcompensation in EIA is supposed to (Rajvanshi,2008):l Support the development of measures to

avoid, reduce, remedy or compensatesignificant adverse impacts of developmentproposals on environment and society;


l Enhance beneficial effects and lower costsfor environmental protection and conservationof natural resources as an outcome ofdevelopment where possible; and

l Foster better opportunities for businessthrough positive outcomes for environmentalconservation, sustainable livelihoods andhuman well-being.

Mitigation and compensation thus potentiallyenable better protection of environmental assets;encourage prudent use of natural resources andecosystems, and so avoiding costlyenvironmental damage. They are important andintegral parts of EIA.

Rundcrantz and Skärbäck (2003) definedmitigation as something that ‘limits or reduces thedegree, extent, magnitude or duration of adverseimpacts’. Furthermore, in the EuropeanCommission’s guidance note on Article six of theHabitats Directive (European Commission, 2000),mitigation is defined as ‘measures at minimisingor even negating the negative impact of a plan orproject, during or after its completion’.

Compensation is about implementing measuresto replace lost or adversely impactedenvironmental values. Compensation measuresshould have functions similar to existing

environmental values. In this context, Kuiper(1997) talked about compensation in terms of ‘thecreation of new values, which are equal to thelost values’. If the lost values are irreplaceable,compensation concerns the creation of valueswhich are as similar as possible. Currently, theonly country globally with area-wide formalrequirements for environmental compensation inplace that go beyond protected areas and zonesis Germany, based on the Federal EnvironmentalImpacts’ Compensation Rule (Eingriffsregelung).Other countries with environmental compensationrequirements for protected areas include the USA(no net loss of wetlands, see above), Canada,Austria and Switzerland (Peters et al., 2003).Compensation in EIA usually refers to biologicalfunctions. In case no adequate functionalcompensation can be found, many systems havecompensation rules in place that allow formonetary compensation.

10.3.1 Mitigation and compensation hierarchyMitigation and compensation should beconsidered in a hierarchy, consisting ofavoidance, minimisation, rectification,compensation and enhancement measures. Thisis shown in Figure 10.2.

Priority should be given to avoiding impacts atsource, e.g. through the re-design of a project

Figure 10.2: Hierarchy of mitigation measures

Source: Rajvanshi (2008), modified from UNEP (2002)

Highest

Prio

rity

Lowest

Avoid the potential impact

Decrease the spatial/temporal scale of the impact

during design, construction, etc.

Apply rehabilitation techniques after the impact has occurred

Offset the residual impact and compensate, as appropriate

Avoid

Minimize

Rectify

Compensate

Enhance Apply measures to create new benefits



proposal or by changing the timing and locationof activities. In this context, the precautionaryprinciple should be applied, in particular insituations where the level of uncertainty of aproject is high. If avoiding significant negativeimpacts is not possible, they should be reduced.If significant negative environmental impacts stillremain, compensation may be necessary.However, this should only be applied if all othermeasures from Figure 10.2 have beenconsidered. Figure 10.3 explains the differentmitigation measures introduced in Figure 10.2further, referring to ‘approaches for mitigation ofimpacts’ (following Rajvanshi, 2008).Subsequently, measures to avoid and minimizeimpacts are discussed further before remedialaction is considered.10.3.2 Avoiding environmental impactsThere are various possibilities to avoidenvironmental impacts. These include the

consideration of alternatives, sensitive design,environmentally sustainable technology,development restrictions in sensitive areas,avoidance of certain key areas, adopting the‘precautionary approach’, and finally, refrainingfrom certain action altogether.

Identification of alternatives:The identification of least impacting alternatives isat the heart of any EIA. A range of possibleimpacts were introduced above. A specificalternative can lead to avoiding impacts onsensitive environments, such as humansettlements, biodiversity rich areas, habitats ofendangered species, archaeological and culturalsites of proposed projects.

Sensitive design:Adopting environmentally sensitive design ofdevelopment projects can help to avoid many

Figure 10.3: Approaches for mitigation of impacts

Source: Rajvanshi (2008, p.168)

Mitigation by avoidanceMeasures considering siting, design,process, technology, routealternatives and ‘no go’ options toavoid impacts.

Represents cheapest and mosteffective form of impact mitigation.

This approach offers the greatestbenefit of avoiding impacts early inthe planning cycle.

CompensationRepresents measures to achieve nonet loss.

Represents on-site or off sitemeasures considered early in theplanning process and also alongsidethe development to offset residualimpacts.

This approach opens a window ofopportunity for negotiations betweendevelopers and decision-makers.

EnhancementRepresents measures to achieve netpositive gain.

Applied in parallel with othercompensation measures toencourage opportunities to limit thescope and scale of impacts and onimproving environmental features.

This approach may result in a win-win situation and improve prospectsfor project acceptability.

Mitigation by reductionMeasures attempting to reduceimpact or to limit the exposure ofreceptors to impacts.

Applicable only in the progressivephase of the development project.

This approach aims at limiting theseverity of impacts and not avoidingthem altogether.

Mitigation by remedyMeasures undertaken to restore theenvironment to its previous conditionor to a new equilibrium.

Applicable only towards the endphase of project implementation.

This ‘end of pipe’ restorativeapproach helps improve adverseconditions created by the proposeddevelopment.

Residual impacts


impacts. ‘Nature engineering’ concepts havebeen discussed by a range of authors (Canters etal., 1995; Spellerberg, 1998; Forman andSperling, 2003) and are being implemented inpractice in many countries. This can include e.g.road underpasses and bridges for animals or fishladders on dams. Artificial nests also fall into thiscategory.

Environmentally sustainable construction andtechnology:Environmentally sustainable construction andtechnology for controlling impacts and makinggood environmental choices are also important.Environmentally sustainable technology can beapplied during construction, post constructionand in progressive phases of a project.

Development restrictions in sensitive areas: In many countries, there are restrictions onlocating projects in specific areas. In the UK, the‘Green Belt’ has protected open space aroundmajor conurbations, keeping development andsprawl in around metropolitan areas to aminimum. The same applies to the Dutch ‘GreenHeart’, an area with development restrictionsbetween Amsterdam, the Hague, Rotterdam and

Utrecht. In Germany, the landscape planningsystem identifies, in an area wide manner, sitessuitable for defined developments and sites withdevelopment restrictions (Hanusch and Fischer,2008). Development controls are beingincreasingly enforced in other countries.

Avoiding development in certain areas altogether:An effective way for avoiding negativeenvironmental impacts is to avoid development incertain areas altogether. This may include, forexample, estuaries, salt marshes, wetlands, shorelines and specific sensitive habitats such asbreeding grounds, rearing areas, over winteringsites and migration routes. There is an emergingconsensus on ‘no development’ zones (Box 10.2),based on guidelines of various internationalbodies (WWF, 2002; EBI, 2004; IFC, 2004). Someinstitutions have adopted a no developmentzones approach. These include e.g. the USOverseas Private Investment Corporation, abilateral finance agency, which categoricallyprohibits projects in or impacting IUCN I-IVprotected areas, World Heritage Sites, andprojects that involve conversion or degradation ofcritical forest areas or related critical naturalhabitats. Also, the Bank of America will not

Box 10.2: Criteria for recognising high conservation value sites as ‘No-Development’ zones

l Protected areas, core areas of biosphere reserves and Ramsar sites not included under IUCN category I-IVof Protected Areas.

l Proposed protected areas in priority conservation areas.l Sites that maintain conditions vital for the viability of protected areas that support 'jewels'.l Centres of plant diversity.

l Areas officially proposed for protection based on local and national priorities.

l Area of known high conservation value, these may include sites of degree of endemism, rarity, vulnerability,representativeness and ecological integrity.

l Areas where there is a lack of knowledge of biodiversity.

l Areas where operations will reduce populations of any recognised critically endangered or endangeredspecies, or significantly reduce the ecological services provided by an ecosystem.

l Areas recognised as protected by traditional local communities.

l Critical fish breeding grounds.

l Areas where there is a serious risk of soil, watershed, pollution, and knock-on effects such as landinvasion.

Source: Rajvanshi (2008, p.171)



finance projects that include resource extractionfrom high conservation value forests, primarytropical moist forests, and primary forests intemperate or boreal forest regions (IUCN, 2005).

Timing of activities:Many countries have regulations in place withregards to scheduling certain activities as to takeplace in defined times only. This is done in orderto avoid overlaps with e.g. flowering and seeding,nesting or breeding seasons.

Adopting the ‘precautionary approach’: The precautionary approach means preventivedecisions are to be made in the face ofuncertainty in order to protect the environment.Probably the best known document puttingforward the Precautionary Principle internationallyis the Rio Declaration from the 1992 UnitedNations Conference on Environment andDevelopment (Agenda 21). It promotes action toavert risks of serious or irreversible harm to theenvironment (Cooney and Dickson, 2006). ThePrecautionary Principle has been integrated intonumerous international conventions andagreements. One of the first countries to haveincluded the precautionary principle intoenvironmental legislation is Germany, where theidea can be traced back to the first draft of theclean air legislation in 1970 (Wurzel, 2006).

Refraining from certain developments:Refraining from certain developments altogethermeans avoiding particular impact-causingactions. An important question to ask is thuswhether a particular development is needed at all,even though in practice this may often bedifficult.

10.3.3 Minimising environmental impactsMinimising impacts of development is the nextstage on the EA mitigation hierarchy ladder. Thereare a number of measures aimed at limiting thedegree, extent, magnitude, and duration ofadverse impacts, including control measures forpreventing pollution, minimisation of physicaldisturbances, ‘good housekeeping’, the

installation of physical barriers, creative landmanagement, technological fixes, promotion ofcompatibility, and if possible, translocation ofaffected species.

Control measures for preventing pollution:Numerous control measures can be used forpreventing air, water and other environmentalpollution. Innovative design and technologicalmeasures can also reduce the magnitude andseverity of project related impacts. Examplesinclude the installation of well-designed chimneysfor regulating emissions and sound-proofing inorder to reduce noise coming in. Furthermore,effluents can be filtered before discharge intowater bodies.

Minimisation of physical disturbances:Responsible construction practices cansignificantly reduce environmental impacts. Thisapplies to other activities, as well, e.g. dredgingand mineral extraction. Exploration activitiesshould always use non-intrusive techniques,including remote sensing and global positioningsystems. The use of existing infrastructuresshould normally be given preference and the useof e.g. helicopters to transport equipment intosensitive areas is also a way to minimizeenvironmental impacts (White et al., 1996).

Good housekeeping:Good housekeeping, use of energy-savingappliances and cleaner production technologiesare being universally promoted. These can reduceenvironmental pollution and emission of e.g.greenhouse gases.

Installation of physical barriers:Installing physical barriers and developinglandscape buffers to reduce visual impacts ofinfrastructures and buildings are now undertakenin many countries. They can be very effective inreducing visual and noise impacts.

Creative land management:Creative land management, landscaping anddevelopment of land-use alternatives can reduce


physical impacts, both during construction andoperation. It can also improve post projectaesthetics.

Technological measures:Technological measures can be very effective inminimizing impacts. Examples include bio-filtration, energy conservation through moreefficient engines and electric vehicles. They alsoinclude renewable energy technologies, such assolar panels and wind turbines.

Promotion of compatibilities:Promoting compatibilities between different usescan minimise impacts. Measures can range fromkeeping high density residential developmentsseparate from major motorways to promotingeco-parks. These are industrial zones wherebusinesses co-operate with each other. This maymean one company using the waste produced byanother to produce energy for the entire park.

Translocation of certain species: Translocation of plants and animals and possiblyhabitats from sites of proposed development canbe an effective way to minimize impacts.Relocation of animals in certain developmentsituations is a legal requirement in manycountries. This may help reducing the decline ofnative species. Policies in the UK (JNCC, 2003aand b) propose translocation of habitats as ameans to reducing the impacts of damagingdevelopments. They suggest moving affectedwildlife habitats to new “safe” locations.Translocation and relocation measures should,however, normally be applied only as the lastresort for mitigating impacts of a development.

10.3.4 Remedial action – restoration andcompensationRemedial measures include the repair,reinstatement, restoration or rehabilitation of anaffected environment. The goal is to eithermaintain or recreate pre-developmentenvironmental characteristics of a site.Furthermore, as a last resort for residualunavoidable harm, compensating for a lost

environmental quality may also be considered.Compensation should aim at restoring anenvironmental value either on-site or next to thesite. If that’s not possible, compensation actionfurther away may also be a possibility. Off-sitecompensation may mean e.g. creating a newhabitat elsewhere by e.g. strengtheningconservation of species threatened by aproposed development. Finally, ‘in-kind’compensation may be necessary when both, on-site and off-site compensation are not possible.In-kind compensation involves use of e.g. tradinginstruments to offset impacts and to support theenvironmental sustainability of developmentproposals. Carbon trading and wetland andconservation banking schemes (see the USEndangered Species Act and the Clean WaterAct) are perhaps the best examples of tradinginstruments. The state of California pioneered themitigation banking approach in 1990. Since then,similar trading schemes in the US have created72,000 ha of wetland and endangered specieshabitat in over 250 approved ‘banks’. Habitat‘credits’ are sold in more than 45 states in theUSA (Wilkinson and Kennedy, 2002; Fox andNino-Murcia, 2005). The bio-banking scheme ofAustralia (NSW) and the area pools (Flächenpools)in Germany (in the context of the FederalEnvironmental Impacts Intervention Rule) arefounded on similar principles. While there is alsothe possibility of out-of-kind monetarycompensation, as a general rule, this should notnormally be considered, as this does not directlybenefit the environment.

In practice, restoration may mean, for example,reforestation, not just planting saplings, but alsomanaging growth, restocking reservoirs with fishor reclaiming or stabilizing abandoned sites. Thefollowing are some of the best recognised andmost frequently employed remedial measures. Itis important that any remedial or compensationaction also takes possible impacts into account,carefully considering trade-offs and long-termeffectiveness. Compensation measures shouldaim at enhancing environmental quality and atachieving no net-loss of environmental services.



Figure 10.4 indicates what compensation shouldaim to achieve with regards to counterbalancing asignificant negative impact.

10.3.5 Criteria for successful implementationof mitigation and ingredients for good practiceapproachesGood mitigation practice has been described ascontributing to the resolution of environmentaland social problems and optimising the benefitsfrom a particular development. While mitigationhas been criticised as ultimately enablingdevelopment without securing safeguards, thereis evidence that at least some good practice isemerging (EBI, 2007; Patricia and Ernst, 2007).

Several factors determine the reliability,practicality and successful implementation of

mitigation measures. Tomlinson (1997) warnedthat mitigation ‘promises’ made in EIAs may notbe delivered unless they are built into the consentprocedures. Effective implementation ofmitigation measures may involve the preparationof a written plan including a schedule of agreedactions. With regards to EIA, this plan is oftenreferred to as an ‘Environmental ManagementPlan (EMP)’. Preparation of EMPs is required bye.g. the World Bank (World Bank, 1999) andWestern Australia (Wood, 2003), and in the EIAsystems of many developing countries.

Good EMPs should focus on the mitigationmeasures put forward in EIA. .In this context,technical details, financial allocations, and timeschedules should be clarified. Table 10.1 showswhat an EMP for an EIA may entail.

Figure 10.4: Compensation measures for achieving no net less or positive enhancement

Source: Rajvanshi, 2008, p176

Impact offset

( Modified from ICMM, 2005)

Zero impact level

No net loss

+

-

Anticipated impacts

Residual impacts

Mitigated impacts

Mitigated impacts

Avoided impacts

Avoided impacts

Avoided impacts

Positive contributions or enhancement

Size of offset

Residual impacts

Application of compensation measures to offset impacts

Net positive environm

ental benefit


10.4 Practical elementStudents should develop suitable alternatives forEIA in different sectors e.g. transport, energy,resource extraction and waste, and considersuitable methods or techniques for assessingthem.

Projectactivities

Typeof impact

Potentialimpacts

Where theimpact islikely tohappen

When theimpact islikely tooccur

Magnitude of impacts

Mitigationmeasures

Anticipatedcosts

Institutional responsibility

Implementation Supervision


Table 10.1: Format for summarising mitigation outcome for developing EMP



This chapter is divided into five sections. First, what an EIA report is, isexplained. Secondly, the content and focus of an EIA report is explored. Thisis followed by a section describing the importance of EIA report qualityreview. The role of EIA report quality review packages is then explained andan example package is introduced. Finally, EIA report quality review inPakistan is explored. The main sources this chapter draws on include:European Commission (2001), Fischer et al (2008), Nadeem and Hameed(2008), and UN University (2006g).

11.1 The EIA ReportReport preparation is a key technical stage of the EA process. The EA reportrepresents an important basis for discussing the acceptability of proposedprojects. Furthermore, it helps to identify possible amendments and mitigationmeasures.

The EIA report is the main document produced in the EIA process. Differentsystems refer to it with different terms, for example, Environmental ImpactStatement (EIS). It can be one document of a few pages only or it can consistof several volumes. Its objective is to provide some detailed information onthe assessed activity for a range of individuals and institutions, includingdecision- makers, stakeholders and the general public. Its main purpose is todescribe the current state of the environment as well as to present anevaluation of the likely or significant impacts. It should also includesuggestions for mitigation and monitoring. The EIA report should comprise theidentification of significant environmental impacts and how to avoid, mitigateor compensate for them. The EIA report is also the basis for a transparentpublic participation process. In this context, the report should be subjected topublic review, possibly resulting in suggestions on how to amend theproposed project or the EIA itself.

The EIA report is normally highly demanding for those preparing and thosereading it. Therefore, in many systems there are certain rules in place withregards to e.g. project proponents commissioning listed professionals orconsultancies. Generally speaking, an EIA report greatly benefits from theinvolvement of local experts. In order to be a document that also lay peoplecan understand, the report should be written in a clear and simple manner. In

11 EIA reporting and EIA report qualityreview


this context, ideally, the EA report should containeasy-to-understand pictures and visualisations.Normally, it is also expected to include a non-technical summary. Furthermore, it frequentlycontains specific studies on important issues thatare looked at by experts, e.g. ecologists orhydrologists. Those preparing an EIA report needto closely cooperate with responsible authoritiesand the affected public. Guiding principles ofreport preparation are illustrated in Box 11.1.

11.2 Focus of an EIA report In an EIA, it is important to understand, andwherever possible, to quantify the environmentalimpacts of investment activities. Key questions tobe addressed during impact prediction include:l What impacts are likely to be caused by a

development proposal?l What objectives are the basis for evaluating

the significance of environmental impacts?l What indicators should be used in order to be

able to describe and understandenvironmental impacts and how can these bequantified?

l What is the significance of environmentalimpacts of the proposed development and itsalternatives and how can they be avoided,mitigated or compensated?

An EIA report consists of several distinctsections. These can be summarised in terms offive main tasks it is supposed to fulfil, including:l Description of a project and its alternatives;l Description of the baseline environment;l Prediction of positive and negative

environmental impacts;l Assessment of cumulative effects;l Evaluation of impact significance; andl Identification of mitigation measures.

These sections are subsequently described infurther detail.

11.2.1 Description of a project and itsalternativesThe proposed project should be described withan explanation as to what it means in practice,while focusing on the information that isimportant for EIA. This description should clearlystate the underlying objectives. Alternatives needto be meaningful and realistic. Furthermore, anenvironmentally friendly option and the ‘donothing option’ should be included.

11.2.2 Description of the baselineenvironmentIn an EIA report, the baseline environment needsto be described, including e.g. human health,fauna, flora, soil, water, air, climatic factors,material assets, cultural heritage, as well aslandscape. Other aspects may need to beincluded, depending on specific legalrequirements. Characteristics need to beevaluated, establishing their environmentalsensitivity. Existing environmental data fromprevious surveys, monitoring, environmentalaudits, environmental databases, land registers,GIS and other environmental management andplanning instruments are often useful in thiscontext. Other sources of information include e.g.spatial and other development plans, habitat andsoil maps, climate, noise and emission registers.These need to be sufficiently detailed and up-to-date. Normally, other data are specificallygenerated for EIA. The description of the baselineenvironment should put special emphasis onexisting environmental problems and constraints,as well as on ecologically important and sensitiveareas.

Box 11.1: Guiding principles for EIA report preparation

l the content of the report should reflect the outcomes of the scoping stage;

l the focus should be on information relevant for EIA;

l the quality and relevance of information is more important than its quantity; and

l the forecasts need to be reliable, based on scientific principles that others can understand.

Source: Belcakova, 2008; von Seht, 1999; Sadler, 1996



11.2.3 Prediction of positive and negativeenvironmental impacts Positive as well as negative environmentalimpacts need to be predicted. These shouldinclude direct, indirect, synergistic, cumulative,ancillary, long-term, delayed, regional and globalimpacts (Belcakova and Finka, 2000). Generallyspeaking, predictions should be linked to keyissues of the baseline environment.

Impacts can be determined qualitatively – andwherever and whenever possible – quantitatively.Certain impacts may be calculated, others bemodelled or otherwise be predicted. Manyimpacts will not be recordable as quantitativedata, but will only be described qualitatively.Appropriate methods will need to be identified atthe scoping stage and might have to bereassessed later on in the EIA process.Environmental impacts may affect various mediadue to the complexity of causal chains andmonocausal relationships will rather be theexception than the rule. Feedback mechanismsand synergisms will make the assessment morecomplex. In this context, it is important thatenvironmental impacts depend on thecharacteristics of the receiving environment aswell as the type of action giving rise to impacts.

11.2.4 Assessment of cumulative effectsThe assessment of cumulative effects is anaspect of EIA that requires particular attention. Arange of methods is available for this, from themore analytical matrices to planning orientedmulti-criteria analysis. Sadler and Verheem (1996)put forward the following framework for analysingcumulative effects in EIA:l Sources: The pattern and timing of activities

that can cause or will potentially initiateenvironmental change;

l Effects: The syndrome of impacts and longterm changes that occur in response tostress; and

l Processes: The ecological pathways,mechanisms and triggers that structureaccumulation of effects.

11.2.5 Evaluation of impact significance Evaluation of impact significance needs to bebased on objectives, including e.g. environmentaland sustainability objectives. These can be basedon regulations, guidelines or on e.g. expert orpublic opinion. In order to evaluate impactsignificance, an appropriate method needs to bechosen. In this context, applying a pre-definedmethod makes EIA more transparent,reproducible and comparable.

Knowledge of the significance of impacts isessential for being able to make decisions onalternatives and mitigation measures. Mostexperts agree that when using evaluationmethods and techniques, it should be avoided:l to pretend a non-existing accuracy of the

results; and l to aggregate the evaluation results of various

media or impacts into one single variable; thismeans information for the decision-maker willbe lost in the process without pre-agreedmethods on weighing and scaling.

11.2.6 Identification of mitigation measuresModifications of the original proposal andmitigation measures that will improve theenvironmental friendliness of the proposedproject, policy, plan or programme should beconsidered. This is a key function regardingenvironmental protection.

11.3 Pakistani guidelines forpreparing environmental reports ofspecific sectorsThese include guidelines for preparingenvironmental assessment reports of the projectspertaining to the following eight sectors(http://www.environment.gov.pk/info.htm): - Housing estates and new towns

development;- Oil and gas exploration and production;- Major chemical and manufacturing plants;- Major thermal power stations;- Major sewerage schemes;- Major roads;- Industrial estates; and- Wind power projects.


Each of these guidelines highlights thesignificance of the sector and specific issuesincluding site selection parameters, potentialenvironmental and socio-economic impacts,possible magnitude of impacts, emissions ordischarge requirements, and checklists ofenvironmental parameters, various mitigationmeasures, monitoring, management and trainingaspects. These guidelines have been prepared onthe basis of reviewing local laws, environmentaland planning standards and the EIA/EISguidelines of the Pakistan Government, IUCN,World Bank and Asian Development bank. TheUNEP Training Resource Manual and sector

specific guidelines of developed countries (e.g.New South Wales EIS Guidelines, 1997) have alsobeen consulted or referred to. The guidelinesappear to be equally useful for prospectiveproponents, EIA consultants, EPA officials andthe academics. These are “quite comprehensiveand as comprehensive in nature as comparedwith such guidelines and regulations in othercountries like Sri Lanka, India, Bangladesh andEgypt” (Nadeem and Hameed, 2008, p.564 ). Asample checklist of environmental parameters ofindustrial estates as appended in the relevantguidelines is presented in Table 11.2.

Table 11.1: Checklist of environmental parameters for industrial estates

Actions Affecting EnvironmentalResources and Values

A. Problems Related to SiteSelection

1. Displacement of existing landuse e.g. agricultural land

2. Destruction of sensitive areas3. Natural adverse site conditions4. Adjoining land owners

5. Displacement of existingpopulation

6. Impairment ofhistorical/cultural resources

7. Availability of existinginfrastructure and services

B. Problems Related to DesignPhase

1. Hazardous materials

2. Liquid waste emissions

3. Gaseous waste emissions

4. Solid waste emissions

5. Noise

Damages to Environment

A. Depends on Nature ofProblem

1. Loss of economic resource

2. Loss of natural habitat3. Impact on human welfare4. Impact on human

health/welfare5. Social inequities

6. Loss or impairment of thesevalues

7. Overloading of existinginfrastructure

B. Depends on Nature ofProblem

1. Hazards to workers andadjoining population

2. Impairment of down-streamwater quality and use

3. Impairment of community andregional air quality

4. Impacts on human health

5. Damage to workers andneighbours

Recommended FeasibleMeasures

A. Depends on Nature ofProblem - Reject site ifinappropriate

1. Proper quantification ofimpacts.

2. Proper valuation of impacts. 3. Design accordingly. 4. Design accordingly.

5. Adequate resettlementplanning and budgeting

6. Careful planning/ design, plusoffsetting measures

7. Expanding infrastructurewhere possible

B. Depends on Nature ofProblem

1. Careful planning andemergency procedure

2. Careful planning/ design andO and M, plusoperating/monitoring

3. Careful planning/ design andO and M, plusoperating/monitoring

4. Careful planning, O and M andmonitoring

5. Careful planning and O and M



11.4 The importance of EIA qualityreview The review of the quality of an EIA report isimportant in order to check its adequacy.Conducting a quality review allows a responsibleauthority and stakeholders to check whether alllegal requirements have been met and to whatextent the report meets good practice criteria.Quality review is normally done on the basis ofreview matrices or packages. These are normallybased on review criteria that are evaluated withregards to whether the report can be considered

to be of e.g. excellent, good, average, poor orvery poor quality. The latter two evaluation resultswould normally indicate that the report does notmeet acceptable standards.

There are a number of good practice principleswith regards to the review of EIA reports. TheUnited Nations University (2002g) explains that aframework for the EIA review needs to beestablished first, including the following steps: l “set the scale/depth of the review; l select reviewer(s);

Actions Affecting EnvironmentalResources and Values

6. Transport and traffic issues

7. Aesthetics

8. Loss or impairment of floraand fauna

C. Problems During ConstructionStage

1. Silt runoff from constructionoperations

2. Dangers to workers fromaccident, disease quarrying,and emissions

3. Local flooding from wateringexcavations, flushing of pipes

4. Loss/degradation ofvegetation from mechanicaldamage

5. Traffic congestion andblocking of access

D. Problem During OperationStage

1. Pollution, health hazards andnuisance

2. Occupational healthinadequacies

3. Inadequate O and Mperformance

Damages to Environment

6. Air pollution and noise effecthuman health

7. Visual intrusion

8. Loss of environmentalresource

C. Unnecessary EnvironmentalDamages

1. Soil erosion with damage toproperty and aesthetic values

2. Injuries to workers and nearbyresidents

3. Local flooding damages

4. Loss of vegetation, forest andhabitat in general

5. Loss of time and fuel andaccidents

D. Depends on Nature ofProblem

1. Damage to workers andadjoining residents

2. Damage to worker safety andhealth

3. Damage to worker safety

Recommended FeasibleMeasures

6. Careful traffic and circulationplanning

7. Careful planning/design/landscaping

8. Careful layout and design

C. Careful Construction Planningand Monitoring

1. Erosion control planning andcareful monitoring

2. Careful construction planningand monitoring



5. Careful constructionplanning/monitoring

D. Careful O and M, plusOperation Stage Monitoring

1. Competent O and M

2. Occupational health plan plusmonitoring

3. Occupational health plan plusmonitoring

Source: GoP (1997f, pp.16-17)


l use input from public involvement; and l identify review criteria and aspects to be

considered”.

Conducting the actual review means to evaluatethe EIA report on the basis of the framework. Inthis context, potential problems and deficienciesneed to be identified and suggestions be madeon how these may be addressed. Findings thenneed to be reported and shared with projectproponents, assessors, responsible authoritiesand possibly others.

Before starting a review, the person conducting itshould have a clear idea about the time andresources available. Depending on the project,the review may be done either quickly or in-depth. It is probably not a good idea to runquickly through an EIA report review for acontroversial project or a project with manyenvironmentally significant effects.

Any review should be done by at least two ormore reviewers. To start with, individuals shouldconduct their reviews independently. They shouldthen get together and compare their results,attempting to reach consensus on the quality ofthe EIA report. The review team may consist ofpeople with different expertise and experiences,depending on the specific proposal for which thereview is conducted.

EIA review does not only consist of an expertapplying a framework to evaluate the quality ofthe EIA report. In most EIA systems, the EIAreport is an important basis for obtainingfeedback from stakeholders and the generalpublic. This is particularly useful in order toestablish whether all potential impacts have beendetected and whether there are any otheromissions (e.g. with regards to baseline data).There is a range of different ways in which thestakeholders and the general public may getinvolved at this stage. This may involve publichearings or written comments. It is good practicethat replies are provided to comments either bythe assessor or a responsible authority and that

both, comments and replies are made accessible,e.g. on the internet. Public participation methodsand techniques were introduced in chapter 9.

Identifying the review criteria The United Nations University (2002g) introducesa number of questions to be used in order toidentify review criteria. These include thefollowing (UN University, 2002g):

l Are terms of reference or other guidelinesavailable for the review?

If this is not the case, the first task of a reviewwould be to identify the main issues and impactsthat should be addressed in the EIA report. In thiscontext, those methods used for scoping can behelpful (See: chapter 7).

l Are any reviews of EIA reports of similarproposals and settings available?

Both, EIA reports and their reviews of similarproposals and settings can be useful referencepoints. They may help proponents, assessors,authorities and other reviewers to develop abetter understanding of the EIA report they arelooking at. Depending on the specific EIA systemand the particular situation of application otherEIA reports may either be from the same systemor from elsewhere.

l Which generic review criteria may be useful?

According to the United Nations University(2002g), generic criteria that support an effectiveEIA review include: - “legal EIA requirements (if any); - relevant environmental standards, guidelines

or criteria; - principles of EIA good practice; and - knowledge of the project and its typical

impacts and their mitigation”.

l When is a comprehensive reviewappropriate?



Table 11.2: Main categories and sub-categories of the Lee and Colley Review Package

Main Categories of Lee and Colley Review Package Review Review categoriesareas1 Description of the development, local environment and baseline conditions

1.1 Description of the development: The purposes of the development should be described as shouldthe physical characteristics, scale and design (5 questions).1.2 Site description: The on-site land requirements of the development should be described and theduration of each land use (5 questions).1.3 Wastes: The types and quantities of wastes which might be produced should be estimated, andthe proposed disposal routes to the environment described (3 questions).1.4 Environmental Description: The area and location of the environment likely to be affected by thedevelopment proposals should be described (2 questions).1.5 Baseline conditions: a description of the affected environment as it is currently and as it could beexpected to develop if the project were not to proceed, should be presented (3 questions).

2 Identification and evaluation of key impacts2.1 Definition of impacts: Potential impacts of the development on the environment should beinvestigated and described (5 questions).2.2 Identification of impacts: Methods should be used which are capable of identifying all significantimpacts (2 questions). 2.3 Scoping: Not all impacts should be studied in equal depth. Key impacts should be identified,taking into account the views of interested parties, and the main investigation centred on these (3questions). 2.4 Prediction of impact magnitude: The likely impacts of the development on the environment shouldbe described in exact terms wherever possible (3 questions). 2.5 Assessment of impact significance: The expected significance that the projected impacts will havefor society should be estimated (2 questions).

3 Alternatives and mitigation of impacts3.1 Alternatives: Feasible Alternatives to the proposed project should have been considered (3questions).3.2 Scope and effectiveness of mitigation measures: All significant adverse impacts should beconsidered for mitigation (3 questions).3.3 Commitment to mitigation: Developers should be committed to, and capable of carrying out themitigation measures and should present plans of how they propose to do so (2 questions).

4 Communication of results4.1 Layout: The layout of the statement should enable the reader to find and assimilate data easily andquickly. External data sources should be acknowledged (4 questions). 4.2 Presentation: Care should be taken in the presentation of information to make sure that it isaccessible to the non-specialist (3 questions). 4.3 Emphasis: Information should be presented without bias and receive the emphasis appropriate toits importance in the context of the ES (2 questions). 4.4 Non-technical summary: There should be a clearly written non-technical summary of the mainfindings of the study and how they were reached (2 questions).

Source: Lee and Colley (1992)


As was explained above, it is possible to conducteither short or more comprehensive qualityreviews. In case a more comprehensive review isdeemed necessary, this may also cover otheraspects of the EIA process than just the EIAreport. “Some or all of the elements and aspectsthat may require consideration include: - performance of scoping; - accuracy of impact prediction; - criteria used to evaluate significance; - comparison of alternatives; - effectiveness of proposed mitigation

measures; - requirements for monitoring and impact

management; and - modes of public and stakeholder

involvement” (UN University, 2002g).

Some attention should be given to the executivesummary, which is intended to explain the keyfindings concisely and in a non-technical manner.What is important is that on many occasions thenon-technical summary will be the onlydocument decision-makers and others are likelyto read.

11.5 EIA report quality reviewpackagesNumerous EIA report quality review packageshave been developed in many institutions andauthorities worldwide. There are packages that

are supposed to be applicable in differentsituations and there are packages that areproduced for use in one specific system or area.One of the first packages developed was that byLee and Colley (1992). This had been preparedprimarily to assist in assessing the quality ofenvironmental statements submitted in responseto UK planning regulations which requireenvironmental assessments to be undertaken inaccordance with European Directive 85/337/EEC.It is a package that is commonly used andaccepted. Published studies based on theapplication of the review package include e.g.Marr (1997) and Barker and Wood (1999). Morerecently, this review package has been adaptedfor reviewing strategic environmental assessment(SEA) documentation (see Bonde and Cherp,2000 and Fischer, 2010).

By utilising the package, reviewers are able toassess whether an EIA report fulfils a number ofimportant quality criteria with regards to itscontent, the prediction of impacts and thepresentation of information. The package helps toidentify additional information that may berequired for the ES from the developer, such asimpacts which have not been satisfactorilyaddressed and where further information may berequired. Quality review is performed using a setof hierarchically arranged review topics. Table11.2 presents the main categories and sub-

Figure 11.1: The assessment pyramid


Level 4

Level 3

Level 2

Level 1

Overall quality assessment of the EnvironmentalStatement

Assessment of the Review Areas

Assessment of the Review Categories

Assessment of the Review Sub-categories



categories used and also indicates how manyquestions contribute to a sub-category. In total52 questions are to be answered.

The review topics are arranged hierarchically. Anoverall EIA report quality mark is assigned on thebasis of the review areas, categories and sub-categories. Figure 11.1 shows the pyramidprinciple of the Lee and Colley review package.

Quality grades are assigned, ranging from A (bestpossible grade) to F (worst possible grade). Allgrades are presented in Table 11.3.

In order to conduct the review, a reviewer shouldfollow the following steps:l Read the statement;l Read the review category (e.g. 1.1) and the

component sub-categories (e.g. 1.1.1-1.1.5);l Assess the sub-categories;l Carefully choose an assessment symbol and

record it on collation sheet;l Use assessments of sub-categories to obtain

an overall review mark for the review;category (e.g. 1.1);

l Assess all other review categories;l Assign a final mark;l Compare your marks with that of your peer;

andl Write a report on strengths and weaknesses,

provide comments and recommendations.

11.6 The EIA report in PakistanVarious legal documents and guidelines that areof importance for the preparation of EIA(Environmental) reports in Pakistan are as follows:l Pakistan Environmental Protection Act

(PEPA), 1997;l Pakistan Environmental Protection Agency’s

Guidelines for the Preparation and Review ofEnvironmental Reports, Pak-EPA, 1997;

l Policy and Procedures for the Filing, Reviewand Approval of Environmental Assessments;

l Guidelines for the Preparation and Review ofEnvironmental Reports;

l Guidelines for Public Consultation;l Sectoral Guidelines for Preparation of

Environmental Reports; andl Pak-EPA (Review of IEE and EIA) Regulations,

2000.

What an environmental report should consist of isdescribed in the guidelines for the preparationand review of environmental reports. Box 11.2shows the contents of an environmental report,following the guidelines.

Guidelines for preparation and review ofenvironmental reportsThis set of guidelines encompasses basic stepsin preparation of the review of IEE and EIAreports. It is useful for prospective proponents,EIA consultants as well as for the EPA officialsinvolved in this process. Though a bit old, theguidelines can still be used as one of the sources

Table 11.3: Lee and Colley Review Package Granding System

Grade ExplanationA Relevant tasks well performed, no important tasks left incomplete.B Generally satisfactory and complete, only minor omissions and inadequacies.C Can be considered just satisfactory despite omissions and/or inadequacies.D Parts are well attempted but must, as a whole, be considered just unsatisfactory because of omissions

or inadequacies.E Not satisfactory, significant omissions or inadequacies.F Very unsatisfactory, important task(s) poorly done or not attempted.N/A Not applicable.

Source: Lee and Colley (1992)


of literature on the subject. The following aspectshave been discussed in detail:l Relationship between environmental

assessment and good design;l Inter-agency coordination;l Early consideration of strategic context;l Environmental impact assessment process

including impacts identification, assessmentand prediction methods;

l Mitigation and impact management as well asreport drafting style;

l Steps in reviewing environmental report; l Decision-making, approval process for public

and private projects; l Environmental monitoring and auditing; andl Project management, including role and

attributes of a good environmental manager,programming and budgeting, and capacitybuilding aspects.

While highlighting various issues involved in siteselection, project design and the need forcoordination among all stakeholders, theseguidelines suggest a systematic approach for the

preparation and review of the environmentalassessment report, follow up, monitoring andproject management (See: GoP, 1997c;http://www.environment.gov.pk/info.htm). Theseaspects are introduced and discussed in varioussections of this curriculum.

‘Quick’ checklist

Official criteria for evaluating EIA reports are alsoprovided in the same guidelines (Pak-EPA,1997b), presented in the format of a ‘quick’checklist. This is summarised in Box 11.3.

11.7 Practical elementl Students should conduct a quality review of

an EIA statement from Pakistan, based onBox 11.3, and discuss review experienceswith the teacher and other students.

l Lecturers should stress the importance ofwriting skills to students; if possible requestthe services of somebody from a socialscience department who is dealing with‘good writing’.

Box 11.2: Contents of en environmental report, following Pak-EPA guidelines

l Executive or non-technical summary;

l Description of the objectives of the proposal;

l Description of the proposal and its alternatives including do-nothing alternative;

l Discussion of the proposal and current land use and policies;

l Description of the existing and expected conditions;

l Evaluation of impacts for each alternative;

l Comparative evaluation of alternatives and identification of the preferred options;

l Environmental management plan, monitoring plan and proposed training; and

l Appendices containing:

q a glossary;

q management of study process including list of individuals and agencies consulted;

q sources of data and information;

q list of EA study team members with qualifications; and

q TOR of environmental reports and those given to individuals and specialists.

Source: Nadeem and Hameed, 2008; derived from Pak-EPA, 1997b



Box 11.3: Criteria for evaluating EIA reports in Pakistan

l Whether the executive summary presents significant impacts, cumulative effects of impacts, mitigationmeasures, requirements for monitoring and supervision;

l Whether the project description is complete and at least includes aspects which can affect theenvironment;

l Whether project alternatives are described;

l Whether baseline conditions have been described adequately in an easily understandable manner withcomments on quality of data;

l Whether significant impacts have been predicted and evaluated with indication of potential impacts thatwere expected at scoping stage but not found at this stage;

l Whether mitigation measures to control adverse impacts and enhance project benefits have beenproposed;

l Whether institutional arrangements for implementing mitigation measures have been defined in the form ofEnvironmental Management Plan (EMP);

l Whether costs of implementing all recommendations have been adequately budgeted in the costestimates;

l Whether monitoring programme is described and commitment made with reasons for and detail of costs ofcarrying out monitoring activities;

l Whether local people have been involved in the study process and an overview of the issues raised andtheir treatment is given; and

l Whether the EIA report is written with clarity, free of jargon and explains technical issues in terms that areintelligible to a nontechnical reader.

Source: Nadeem and Hameed, 2008; derived from Pak-EPA, 1997b

126EIA Course Curriculum for Higher Education Institutions in Pakistan126

This chapter is divided into eight sections. First, what EIA follow-up is and whyit is relevant is explained. Secondly, the rationale for EIA follow up isintroduced and who should be involved is discussed. Then, regulations forfollow-up and how to conduct it are established. The potential role of a follow-up programme, environmental and social management plan and possibleconnections with environmental management systems are explained andbarriers as well as enabling factors and challenges are portrayed. Lastly, EIAfollow-up, monitoring and auditing requirements in Pakistan are presented.The main sources this chapter draws on include Asian Development Bank(2003ii); Fischer et al. (2008; chapter 18 by Arts, J: pp.183-196); Nadeem andHameed (2010); GoP (2000) and GoP (2010).

12.1 What is EIA follow-up and why is it relevant?Follow-up is an important stage of EIA. It is important in order for EIA to‘become a true instrument for safeguarding sustainable development’ (Arts,2008). Follow-up can help in managing environmental risk and to learn frompast experiences. Without it, it is not possible to identify the environmentalperformance of a particular project. EIA follow-up can be defined as “Themonitoring and evaluation of the impacts of a project or plan (that has beensubject to EIA) for management of and communication about the performanceof that project or plan” (Morrison-Saunders and Arts, 2004). EIA follow-up hasbeen described as comprising four key components (Arts et al. 2001). Theseare summarised in Box 12.1.

According to Arts and Morrison-Saunders (2004b) there are different forms offollow-up. Furthermore, follow-up can be applied to different abstractionlevels. These range from micro- (a specific project EIA) to macro- (an EIAsystem) levels. The concept of EIA can also be said to be followed-up at themeta-level.

12.2 What is the rationale for EIA follow-up?The rationale for follow-up is closely connected with obtaining a betterunderstanding of uncertainty inherent in EIA. It is important that while EIAfocuses on the planning stages, i.e. the stages before development begins,follow-up is about looking at what is happening after a consent decision.

12 EIA follow-up, monitoring andauditing; the role of environmental andsocial management plans



Follow-up should be integrated into projectmanagement, in particular with regards to impactmonitoring. It is essential in identifying realoutcomes of projects and associated EIAs.Feedback from follow-up into the EIA systemenables learning from experience. It is anecessary element in any EIA system. Box 12.2summarises the objectives of doing EIA follow-up.

Follow-up links pre- and post-decision stages ofEIA, thereby bridging the implementation gap(Dunsire, 1978). This gap can arise in case of adifference in project planning and projectimplementation (Arts et al., 2001). As EIA ispredictive there may be differences between whatit says and what is actually happening in reality.

However, it is not the predicted impacts, but thereal effects that are relevant for protecting theenvironment (Arts, 2008). Follow-up does notonly inform about the consequences of an activity,but also gives proponents an opportunity toimplement measures to mitigate or preventnegative effects on the environment.

EIA follow-up has financial and staffing demands,and it is important to integrate it with othermonitoring and auditing activities (Arts andNooteboom, 1999). However, there is emergingevidence that the costs and effort put into EIAfollow-up are outweighed by the benefits arising(See: e.g. Marshall, 2005 and Sanchez andGallardo, 2005).

Box 12.1: The four key components of EIA follow-up• “Monitoring – the collection of activity and environmental data and comparison with standards, predictions or

expectations. Baseline monitoring refers to measuring the initial state of the environment before activityimplementation and provides the basis for prediction and evaluation in the EIS. In the post-decision stages,monitoring may relate to both, compliance and impact of the decision. Closely related to the continual activityof monitoring is auditing, which is the periodical objective examination of observations by comparing themwith pre-defined criteria (standards, predictions or expectations);

• Evaluation – the appraisal of the conformance with standards, predictions or expectations as well as theenvironmental performance of the activity. This may involve (policy-oriented) value-judgments. Ex-anteevaluation is forward looking and predictive in nature (an example is the preparation of an EIS). Ex-postevaluation has a backward looking nature, involving the appraisal of a policy, plan, program or project that hasbeen or is currently being implemented;

• Management – making decisions and taking appropriate action in response to issues arising from monitoringand evaluation activities. Ongoing management responses may be made by both, proponents (in response tounexpected impacts) and EIA regulators (e.g. reviewing consent conditions and management requirements).An environmental management system (EMS) is a (often voluntary) system of compliance that operationalisesthe implementation of environmental protection and management measures; and

• Communication – informing the stakeholders about the results of EIA follow-up in order to provide feedbackon project/plan implementation, as well as feedback on EIA processes. Both, proponents and EIA regulatorsmay engage in communication on follow-up and communication may extend beyond simple informing aboutresults and management responses but may also include direct stakeholder participation in the monitoring,evaluation and management”.

Box 12.2: Objectives of EIA follow-up• “Controlling, checking and adjusting the plan/project and their impacts for the purpose of controlling

(environmental) risk, maintaining decision-making flexibility and allowing adaptive management responses;• Learning by providing feedback on EIA processes, predictions and actual effects – i.e. learning for the

plan/project, for EIA in general or for enhancing scientific and technical knowledge; and• Communication about the environmental performance of the plan/project. This may include informing

stakeholders about mitigation measures and management of potential impacts on the environment, which isrelevant for improving e.g. public awareness and acceptance”.

Source: Arts, 2008 p.183, based on Arts et al., 2001

Source: Arts, 2008, p.184


12.3 Who should be involved in EIA follow-up?Three groups of stakeholders should be involvedin EIA follow-up, including the proponent of theproject, the (EIA) regulator and the affectedcommunity (Arts, 2008). A proponent is theprivate company or governmental organisationdeveloping a project. They are often expected toperform most follow-up activities (1st partyfollow-up). The way in which follow-up is donemay include self-regulatory or industry-ledinitiatives, including e.g. environmentalmanagement systems (EMS). The regulator, orcompetent authority, is normally a government orfunding agency, e.g. ADB or World Bank,responsible for administering and implementingEIA processes (2nd party follow-up). Theregulator’s role is to ensure proponents complywith EIA approval conditions. The affectedcommunity includes the public, ranging fromindividuals directly affected by a proposal or otherinterested persons (e.g. NGOs). Affectedcommunity participation may “range from directinvolvement in follow-up programmes to simply

being kept informed of follow-up activities andoutcomes” (Arts, 2008). Follow-up done by thecommunity (3rd party follow-up) ranges “fromformal committees or agencies established tooversee or sometimes conduct follow-upactivities through to independent action bycommunity members concerned aboutenvironmental effects in their neighbourhood”(Arts, 2008). EIA follow-up can take many forms,ranging from proponent driven self-regulation torequirements imposed by EIA regulators orinitiatives motivated by public pressure andcommunity involvement (Morrison-Saunders etal., 2001).

12.4 Regulations for EIA follow-upCurrently, post-decision follow-up is still a weakpoint of EIA practice in many jurisdictions.Legislative requirements for EIA follow-up exist ine.g. The Netherlands, the US, the UK, Hong Kong,Western Australia, California and Canada. TheEspoo Convention on ‘EIA in a trans-boundarycontext’ (UNECE, 1991) includes a discretionary

Figure 12.1: EIA follow-up as a link between planning / assessment and project implementation

Source: Arts, 2008, p185, based on Morrison-Saunders and Arts, 2004a

Strategic policies, plans, programmes

Development project plan(design)

Consent decision(approval, permit, etc)

Project implementation(construction, operation)

Environmental consequences (environmental pressures, state, impacts)

Strategic Environmental Assessment? (SEA)

Environmental Impact Assessment(EIA, baseline monitoring)

Environmental Impact Statement(EIS)

Compliance monitoring / auditing(evaluation of conformance)

Effects monitoring / auditing(evaluation of performance)

EIA follow -up

implementation gapuncertainties

implementation gapuncertainties

future EIAs

Project life - cycle Environmental Assessment

pre-decision

post-decision



requirement on follow-up. This states that partiesinvolved can decide that on request a countrymust undertake an ex post evaluation of a project.There are three basic regulatory settings to EIAfollow-up (Arts and Morrison-Saunders, 2004):l “command and control – requirements by

government regulators laid down in formalEIA regulations and focussing on compliancewith law, insight in environmental and EIAsystem performance. These might link upwith environmental permits, standards,surveillance, enforcement and prosecution oroffences for legal breaches;

l self-regulation – by proponents. This willoften be related to instruments likeenvironmental management systems (EMS),or environmental management plans.Examples of this are formal systems, such asISO 14001 and EMAS. The output usuallyfocuses on third party accreditation (e.g.contractors), compliance with industrystandards, management of the activity and agreen profile; and

l public pressure – created by communitystakeholders. This might be achieved via

public concern, interest of the media, studiesor lobbying by interest groups. The focusmight be transparency and accountability ofmanagement of the activity, information aboutthe project, enhancement of localenvironmental knowledge, public participation.Public pressure might be a very strong driverfor EIA follow-up” (Arts, 2008, p.186).

While prescriptive EIA follow-up arrangementsestablish the ‘rules’ for all stakeholders, there areother mechanisms in place, including e.g.proponents’ permit compliance monitoring andarea-wide monitoring by regulation authorities(Arts and Nooteboom 1999). This may meanpreparing management plans. Various EIAregulations include requirements for a periodicsystems evaluation of the EIA regulations andpractice (macro-level follow-up). Associatedrequirements are found in the EU, theNetherlands, Canada, Australia and Hong Kong(See: e.g. Wood 2003).

12.5 How to do EIA follow-up?Arts (2008) introduced a process for conductingEIA follow-up which looks similar to the EIAprocess itself. Box 12.3 shows what it entails.

Box 12.3: the EIA follow-up process• “Screening: This is about the determination of the need for follow-up. This will depend on e.g. regulatory

requirements and the degree of development certainty, which will be connected with the complexity and magnitudeof a proposed activity as well as the involvement of new or unproven technologies. Also, the sensitivity of thereceiving environment is important and the degree of risk of incorrect implementation. Additionally, political andpublic concern needs to be taken into account.

• Scoping: This is about defining the content of EIA follow-up. Potential residual effects need to be considered alongwith the expected most adverse effects, including e.g. cumulative effects. Gaps in knowledge along with publicsensitivities need to be taken into account.

• Designing a follow-up programme: This includes determining the roles and responsibilities of those involved in aproject and EIA and its follow up. Results of scoping need to be documented. This includes a description of themethods and tools used. Costs of follow-up and the requirements of other resources, e.g. time, need to bedetermined. It is important that at least a draft EIA follow-up programme is prepared prior to project approval andthat this is included into the terms and conditions of the consent decision.

• Implementation: This relates to specific activities, i.e. baseline, effects and compliance monitoring. Connectionsshould be made with other monitoring activities, e.g. environmental auditing or Environmental Management Systems(EMS) activities.

• Evaluation: This relates to the need to evaluate results and outcomes. Follow-up data need to be gathered and theconformance with standards and predictions be checked. The overall environmental performance of the activity alsoneeds to be critically looked at.

• Issue management: This is about taking action in response to follow-up outcomes and may range from doing nothingif e.g. follow-up results are positive to implementing additional mitigation measures or modifying construction andproject operation. Issue management can be conducted by proponents, e.g. in response to unexpected impacts,and EIA regulators e.g. with regard to reviewing consent conditions and management requirements.

• Communication: This is about reporting follow-up results. Communication may extend beyond providing simpleinformation and could include direct stakeholder participation in monitoring, evaluation and management”.

Source: Arts, 2008, p.187


12.6 The potential role of a follow-upprogramme / environmental and socialmanagement plan and possible connectionswith environmental management systemsThe Asian Development Bank (ADB) asks forenvironmental management plans (EMPs) to beprepared within EIAs and IEEs for the projectsthey finance. This includes setting out conditionsand targets to be met during projectimplementation. A borrower needs to include thisin their terms of references. It is stated that‘where appropriate, the key contents of EMPs areincorporated into the loan agreement, forimplementation and monitoring by the Borrower’(ADB, 2003).

In the planning stages of a project it is not alwayspossible to provide all the details required for aneffective EMP. In this case, the ADB would askthe Borrower to prepare a revised EMP later, i.e.at the beginning of the implementation stage.

In terms of institutional arrangements, the ADBasks for a project environmental managementoffice (EMO) to be set up within the executingagency. In this context, they recommend thatassociated staff be drawn from permanent full-time staff of the executing agency. It is theresponsibility of theEMO to ensure mitigation measures andmonitoring programmes are completed as agreed(in line with ADB requirements).

The EMP is of crucial importance, as it is thebasis for judging “whether the executing agencyis carrying out the project in conformity with theEMP, (ii) identify problems, and (iii) to developplans for corrective action” (ADB, 2003). The ADB(2003) defines the contents of an EMP which isincluded with an EIA or IEE as follows:

1. Summary of ImpactsThere is a need to summarise mitigation activitiesfor the predicted adverse environmental andsocial impacts.

2. Description of Proposed MitigationMeasuresTargets and quantitative indicators for monitoringneed to be clearly set out. Measures need to bedescribed, explaining the associated impact.Conditions with regards to ‘designs, developmentactivities, equipment descriptions, and operatingprocedures and implementation responsibilities’(ADB, 2003) need to be laid out.

3. Description of Monitoring Programmes andParametersRequirements for the specific monitoring to beconducted along with associated protocols,parameters, and frequencies of production needto be established. Environmental performanceindicators that can show the linkages betweenimpacts and mitigation measures should bedevised and the parameters to be measured andmethods used be clearly explained. In thiscontext, locations and frequency ofmeasurements need to be identified andthresholds be set that indicate the need forcorrective actions. Monitoring and supervisionarrangements need to be agreed. There is a needto show compliance with agreed action.

4. Public Consultation ActivitiesPublic consultation activities should be part of anEMP. This may happen during both, thefinalisation and implementation of an EMP. Theextent of consultation will depend on the specific project and local situation. According to the ADB(2003) it “will normally include (i) notification of local communities when project

activities are going to take place; (ii) disclosure of the results of monitoring

programs to local communities and otherstakeholders; and

(iii) provision for independent third partymonitoring, where necessary”.

Public and stakeholder consultation may also berequired during the design of mitigation measures,in particular when significant extensive effects areto be expected.



5. Description of Responsibilities for Mitigationand Monitoring RequirementsInstitutional arrangements for implementationshould be specified, taking local conditions intoaccount. Responsibilities need to be defined andarrangements put into place for the flow ofinformation and for the coordination of activitiesbetween different bodies responsible formitigation. The EMP needs to specify who will beresponsible for conducting the mitigating andmonitoring measures. In case of limited capacityof the responsible authority, a third party mayneed to be involved. In this context, the EMPmay pay out measures to strengthen institutionalcapacity.

6. Preliminary Cost EstimatesIt is important that mitigation and monitoring areadequately funded and that the EMP provide forpreliminary cost estimates. It is also importantthat once construction and operation has started,the EMP may need to be revised. In this context,additional information may be needed onresponsibilities, work and procurement plans,costs estimates and mechanisms for takingcorrective action (ADB, 2003).

7. Description of the Responsibilities forReporting and ReviewResponsibilities for reporting and review need tobe clearly defined. This includes theresponsibilities of e.g. developers, contractors,authorities, and e.g. development banks (ADB).Roles to be defined include preparation,submission, reception, review, and approval ofreports. A detailed implementation scheduleshould be prepared. “Structure, content andtiming of reporting should be specified to facilitatesupervision, review and approval, if necessary, byADB” (ADB, 2003).

8. Work PlanThe work plan should include information on EMOstaffing and on other work to be done. EMPrequirements should be included in all biddingand contract documents and responsibilities ofcontractors with regards to environmental

management should be made clear. Follow-upwork needs to be supervised and if requirementsare not met, there should be possibilities ofenforcement and potential disbursement (ADB,2003).

9. Procurement PlanThe procurement plan should list those items andequipment required to implement mitigation andmonitoring programmes and procedures toensure consistency of all project procurementshould be described.

10. Cost EstimatesDetailed costs of implementation need to bespecified for all expenses, both initial andrecurring. These need to be integrated into thetotal project costs. Operation, maintenance andadministrative costs need to be considered. Abudgeting plan should clearly state the costs andhow these are to be met (ADB, 2003).

11. Project Feedback and AdjustmentThis is about the procedures and mechanismsthat will be used to modify and reshape theproject in the light of monitoring results. Afeedback mechanism, with proposed timing andprocedures should be included in the EMP toprovide for modifications to the Project, and theinvolved bodies and agencies.

The ADB (2003ii) provides for specific matrices tobe included in an EMP that can be used for takingtrack of developing mitigation measures, themonitoring programme, institutional arrangementsand scheduling.

12.7 What are barriers and enabling factors forEIA follow-up and challengesWhile follow-up is an essential element of EIA, inpractice the extent to which it is applied is stilllimited. This is connected with the existence ofcertain key barriers to its implementation. Arts(2008, p.89) summarised those in terms of thefollowing five aspects:


l “Limitations of EISs or environmental impactstatements – EISs are often descriptive ratherthan predictive, containing vague andqualitative prediction statements that aredifficult to test. Other limitations includegaps in information and outdatedassumptions about future developments.

l Limitations of techniques for follow-up – themethods and techniques for follow-up areless developed than other components ofEIA. Most methods can be considered onlyminor variations on the standard researchdesign. In addition, knowledge about dose-effect is limited and cause-effect relationshipsbetween activities and environmental changeare difficult to establish. Also, baselineinformation is inadequate (Arts and Morrison-Saunders, 2004a).

l Limitations in organisation and resources –monitoring environmental changes and linkingthem to a source, a project or plan, mayrequire considerable time, money, staff,expertise and the involvement of severalparties. The division of tasks, responsibilitiesand costs may be unclear. During the longtime period the EIA follow-up may cover, theproject may be handed over to others, orthere may be changes in personnel. The taskof organising an EIA evaluation may becomplex while little guidance and trainingexist.

l Limited support for conducting EIA follow-up– in general, authorities and proponents alikeseem to give EIA follow-up a low priority. Inmany jurisdictions, EIA follow-up is part ofthe EIA framework. Reasons for this lack ofsupport relate to e.g. expected benefits ofEIA follow-up and its added value in relationto the costs; EIA follow-up may overlap withother evaluative instruments and activities;the extent to which EIA follow-up canperform all of the potential functions may beless than expected; it may be consideredthreatening and a burden on both, theproponent of the activity and the authoritythat had originally given consent; andexternal pressure may also be lacking.

l Uncertainties about benefits and cost-effectiveness – there seems to be animbalance between the various 'stick andcarrot' factors, enforcement versusincentives. As a consequence, in practicethere seems to be an attitude of 'wait andsee'. The ‘stick’ is usually perceptible topractitioners, unlike the ‘carrot’, which maybe less obvious” (Arts, 2008, p.189).

The same author introduces important contextualfactors supporting effective follow-up. Heportrays effective follow-up as a function of theinterplay of the following four factors:

l “Regulations and institutional arrangementsthat have been put in place. In order for EIAfollow-up to be successful, the followingissues are important; having a formalrequirement for follow-up in the EIA system isan important prerequisite; strong commitmentby EIA regulators for follow-up; industry self-regulation tools may fill in gaps; publicpressure is an effective driver; quality controlin EIA follow-up may be improved throughexternal, independent, bodies.

l Approaches and techniques – This relates tosuch issues as: careful screening andscoping to ensure that follow-up is effectiveand efficient; making use of existing data andmonitoring activities where available; rigorousapproaches may be needed, but simplestraightforward techniques may be sufficient;flexibility and a mix in approaches tomonitoring; approaches need to be inaccordance with the local 'culture' for EIApractice.

l Resources and capacity – EIA follow-up caneasily comprise long periods of time, becomecomplex and require much effort in money,time and staff resources. However, follow-updoes not need to be complex and expensive.Important factors for success include: EIAregulators must reserve capacity andbudgets; proponents need to be committedto carrying out follow-up; here, contractoragreements may be a relevant instrument;



public involvement can be a resource in itsown right; local, communal knowledge andfeedback on project implementation; localcommunity and stakeholders will welcomebecoming involved, provided that they aregenuinely consulted; sufficient resources tocommunicate EIA follow-up findings isessential; education, training and capacity tosupport follow-up procedures; staff continuityin both, proponent and regulatororganisations improves effectiveness.

l Project type – the characteristics of theproject/plan that has been subject to EIA areimportant for determining on how to conductEIA follow-up in a relevant manner. Thedesign of the follow-up needs to consider theproject type, relating to issues such as: largeor small capital investment; long-term or

short-term; private or governmentaldevelopment; spatial extent; and strategic oroperational nature. In addition to controllingfunctions, informing and learning may beuseful for more complex projects. SEAfollow-up will be different from project-relatedEIA follow-up e.g. focus on subsequent tiersof decision-making and less directly ontracking detailed environmental changes”(Arts, 2008, p.190).

In order to support good follow-up practice, theInternational Association for Impact Assessment(IAIA) has issued ‘International best practiceprinciples for EIA follow-up’ (Morrison-Saunderset al., 2007). These relate to the success factorsdiscussed above. They are summarised in Box12.4.

Box 12.4: Best practice principles for EIA follow-upGuiding Principles, relating to core values (why?):• Follow-up is essential to determine EIA (or SEA) outcomes;• Transparency and openness in EIA follow-up is important; and • EIA should include a commitment to follow-up.

Guiding principles, relating to the nature of EIA follow-up (what?):• Follow-up should be appropriate for the EIA culture and societal context;• EIA follow-up should consider cumulative effects and sustainability; and• EIA follow-up should be timely, adaptive and action oriented.

Operating principles, relating to roles and responsibilities (who?):• The proponent of change must accept accountability for implementing EIA follow-up;• Regulators should ensure that EIA is followed up;• The community should be involved in EIA follow-up; and• All parties should seek to co-operate openly and without prejudice in EIA follow-up.

Operating principles, relating to roles and responsibilities (how?):• EIA follow-up should promote continuous learning from experience to improve future practice;• EIA follow-up should have a clear division of roles, tasks and responsibilities;• EIA follow-up should be objective-led and goal oriented;• EIA follow-up should be ‘fit-for-purpose’;• EIA follow-up should include the setting of clear performance criteria;• EIA follow-up should be sustained over the entire life of the activity; and• Adequate resources should be provided for EIA follow-up.

Source: Arts, 2008, p.191; based on Morrison-Saunders et al., 2007


12.8 EIA follow-up, monitoring and auditingrequirements in PakistanEIA follow-up, monitoring and auditing aremandatory requirements in Pakistan under varioussections of the Pak-EPA (Review of IEE and EIA)Regulations 2000 (see also Chapter 5). Afterobtaining EIA approval, every proponent is boundto submit an Environmental Management Plan(EMP) along with a confirmation of compliance ofthe conditions of approval. A proponent is alsobound to submit an annual monitoring report. Butin practice, EMP is made part of an EIA reportwhich stands approved along with the EIA(Nadeem and Hameed, 2008). The EIA follow-up,monitoring and auditing process in Pakistanbased on the legal requirements and relevantguidelines, is presented in Figure 12.2.

Legally, concerned EPAs are obliged to inspectthe project at any stage for confirmation ofcompliance and monitor or audit the gaseousemissions, noise pollution levels and contents ordisposal of liquid effluents (GoP, 2000). Accordingto Pak-EPA’s guidelines for the preparation andreview of environmental reports 1997, differentstakeholders should be involved in variousaspects of the monitoring and follow up activities.These include: l “Responsible Authorities [that] make

decisions on, and inspect or checkimplementation of, the conditions of approval;

l Proponents or their agents [that] areresponsible for implementing the projects,including monitoring the actual effects,

Figure 12.2: EIA follow up, monitoring and auditing process in Pakistan

Source: Nadeem and Hameed, 2010, p.118

Decision on EIA & EMP by EPA(Approval with conditions)

Confirmation ofcompliancewith EIAapprovalconditions

Ongoingauditing andpost projectanalysis

Submission ofannual

monitoringreport to EPA

Informingcompany’s

environmentalmanagement

system

Construction of developmentworks and commissioning of

plant machinery etc.

Monitoring of impacts(predicted and un-expected)

arising during operation of project

Managing impacts/Implementingmitigation measures

Review of EMP/EIA follow-upDesign



implementing remedial measures, andverifying the accuracy of predictions;

l Environmental Protection Agencies andDepartments as regulatory authorities [that]check compliance with NEQS, and verify theeffectiveness of mitigation measures; and

l The public [that] can be formally or informallyinvolved in monitoring activities and mayhighlight inadequacies in monitoringprogrammes. They may also have practicalsuggestions to help solve problems as theyarise” (GoP, 1997c, p.37).

An EMP generally includes procedures ofimplementing mitigation measures and assignresponsibility and frequency of monitoring theeffectiveness of mitigation measures for the lifecycle of the proposed project (Nadeem andHameed, 2010; GoP, 1997c). Part of an EMP ofan industrial estate development project ispresented in the Table 12.1 as a sample.However, EMPs also include environmentalmanagement measures for flora, fauna, soilconditions, health and safety of workers andresettlement action plan, if needed, indicatingtargets and mitigation measures.

Table 12.1: Part of an EMP of an Industrial Estate in Pakistan

Source: Nadeem and Hameed (2010, p.121).

Concern/ImpactComponent

Groundwater

Wastewater

Air Emissions

Noise Levels

Solid Waste

Considerations/parameters

pH, turbidity, colour,TDS, hardness,sulphate, fluoride,iron, faecalcoliforms etc.

Effluent flow, pH,BOD, COD, TSS,Chromium, Copperand Zinc, etc.

CO, NOx, SOx,PM10

Noise levels ondB(A) scale

Source, type,generation, used oil,discardedmechanical partsetc.

Location

Construction site,effluent treatmentplant and landfill site.

Offices, Effluenttreatment plant andlandfill site.

3 points near the mainentrance, treatmentplant site and landfillsite in downwinddirection.

7.5 metre from thevehicles at 6 pointsnear construction site,generator room,treatment plant site.

Construction site,administrativebuildings, industrialsites.

MonitoringFrequency

Quarterly

Monthly

Quarterly

Quarterly

Daily

Duration

-

-

8 hours

15 minutesat eachpoint

-

Responsibility

EnvironmentManager/ ResidentEngineer

Manger TreatmentPlant



Chief SanitarySupervisor/

Incharge

Landfill Site

AppliedStandards

NEQS

NEQS

NEQS

NEQS

-


Properties/parameters

Bacterial

All water intended fordrinking (e.Coli orThermotolerant Coliformbacteria)

Treated water entering thedistribution system (E.Coli orThermo tolerant Coliform andtotal Coliform bacteria)

Treated water entering thedistribution system (E.Coli orThermo tolerant Coliform andtotal Coliform bacteria)

Physical

Colour

Taste

Odour

Turbidity

Total hardness as CaCO3

TDS

pH

Chemical

Essential Inorganic

Aluminium (Al) mg/l

Antimony (Sb)

Arsenic (As)

Barium (Ba)

Boron (B)

Cadmium (Cd)

Chloride (Cl)

Chromium (Cr)

Copper (Cu)

Standard Values for Pakistan

Must not be detectable in any100 ml sample

Must not be detectable in any100 ml sample

Must not be detectable in any100ml sample

In case of large supplies,where sufficient samples areexamined, must not bepresent in 95% of thesamples taken throughoutany 12 month period.

≤ 15 TCU

Non objectionable/Acceptable


< 5 NTU

<500 mg/l

< 1000

6.5 – 8.5

mg/Litre

≤ 0.2

≤ 0.005 (P)

≤ 0.05 (P)

0.7

0.3

0.01

<250

≤ 0.05

2

WHO Standards

Must not be detectable inany 100 ml sample



In case of large supplies,where sufficient samples areexamined, must not bepresent in 95% of thesamples taken throughoutany 12 month period.

≤ 15 TCU



< 5 NTU

--

< 1000

6.5 – 8.5

mg/Litre

0.2

0.02

0.01

0.7

0.3

0.003

250

0.05

2

Remarks

Most Asian countriesalso follow WHOstandards



Standard for Pakistansimilar to most Asiandeveloping countries

Pakistan similar to Asia1

Furthermore, Table 12.2 presents national standards for drinking water quality

Table 12.2: National Standards for Drinking Water Quality



Properties/parameters

Toxic Inorganic

Cyanide (CN)

Flouride (F)*

Lead (Pb)

Manganese (Mn)

Mercury (Hg)

Nickel (Ni)

Nitrate (NO3)*

Nitrite (NO2)*

Selenium (Se)

Residual chlorine

Zinc (Zn)

Organic

Pesticides mg/L

Phenolic compounds (asPhenols) mg/L

Polynuclear aromaticHydrocarbons(as PAH) g/L

Radioactive

Alpha emitters bq/L or pCi

Beta emitters

Standard Values for Pakistan

mg/Litre

≤ 0.05

≤ 1.5

≤ 0.05

≤ 0.5

≤ 0.001

≤ 0.02

≤ 50

≤ 3 (P)

0.01 (P)

0.2-0.5 at consumer end0.5-1.5 at source

5.0

0.1

1

WHO Standards

mg/Litre

0.07

1.5

0.01

0.5

0.001

0.02

50

3

0.01

--

3

PSQCA No. 4639-2004.Page No.4 Table No.3 SerialNo. 20-58 may beconsulted. ***

≤ 0.002

0.01(By GC/MS method)

0.1

1

Remarks




1. Standard for Pakistan similar to most Asian developing countries * Indicates priority health related inorganic constitutes which need regular monitoring. *** PSQCA: Pakistan Standards and Quality Control Authority. Source: GoP, 2010b (S. R. O. 1063(I)/2010)

Proviso:The existing water treatment infrastructure is not adequate to comply with WHO guidelines. The Arsenic concentrations in South Punjab and insome parts of Sindh have been found higher than revised WHO guidelines. It will take some time to control arsenic through treatment process.Lead concentration in the proposed standards is higher than WHO guidelines. As the piping system for supply of drinking water in urban centres isgenerally old and will take significant resources and time to get them replaced. In the recent past, Lead was completely phased out from petroleumproducts to cut down Lead entering into the environment. These steps will enable to achieve WHO guidelines for Arsenic, Lead, Cadmium and Zinc.However, for bottled water, WHO limits for Arsenic, Lead, Cadmium and Zinc will be applicable and PSQCA standards for all the remainingparameters (GoP, 2010 (S. R. O. 1063(I)/2010).


12.8.1 Monitoring the environmentalperformance of industrial unitsMonitoring the environmental quality orperformance of industrial units in the countryagainst a large number of parameters or types ofpollutants require huge financial, technical andhuman resources. Secondly, the proponents donot like the frequent entry of EPAs’ inspectors andgenerally consider it a hindrance. To overcomethe deficiency of resources and win theconfidence of industrialists in the country, thePakistan Environmental Protection Councilintroduced a ‘Self-Monitoring and ReportingSystem for Industry’. This aims at “making thecountry’s industry owners and operatorsresponsible for systematic monitoring andreporting of their environmental performance”.The underlying objectives are to “transfer theresponsibility for examining and evaluatingindustry’s environmental performance toindividual industrial facilities” and “saving EPAsconsiderable expense, time and effort. Thismeasure will enable industry to make long-termprovisions for eco-friendly production. Thereported data will also enable governmentagencies to assist industrial units in controllingtheir pollution levels” (Pak-EPA, n.d.).

For implementing the self-monitoring andreporting system, industries have been classifiedinto three categories A, B and C, for reportingcompliances with gaseous emissions and liquideffluents separately, corresponding to a specifiedreporting frequency. For liquid effluents, CategoryA industries include 23 different types ofindustries like fertilisers, steel, pulp and paper,etc. Category B industries include fourteendifferent types of industries like sugar, glassmanufacturing and dairy industry, etc. Category Cindustries include 4 different types of industrieslike cement, pharmaceutical and marble, etc.(See: Table 12.3). Similarly, industries have beendivided into two categories for reporting gaseousemissions (See: Table 12.4). A Category ‘A’industry is required to submit the report of itsemission levels after every month, Category ‘B’industry quarterly and Category ‘C’ industry

biannually. Industrial units are required to get theireffluent tested from a certified laboratory andenter the results in software named as SMART –Self-Monitoring and Reporting Tool. The datacould be sent to respective EnvironmentalProtection Agency via email or through compactdisc.

Another important step in this regard is theformulation of National Environmental QualityStandards (Self-Monitoring and Reporting byIndustry) Rules (GoP, 2001). These rules specifypriority parameters for monitoring of liquideffluents and gaseous emissions separately for allthe three categories of industries. The said rulesare available at the Pak-EPA’s websitehttp://www.environment.gov.pk/info.htm. TheMinistry of Climate Change, Federal andProvincial Environment Departments and all theEPAs of Pakistan are making diligent efforts toimplement the NEQS and SMART Rules despitetheir limited resources and capacity. If theresponsible agencies succeed in effectivelyimplementing these standards, it is expected thatthe EIA follow-up, as well as overall monitoringand auditing of the environmental quality inPakistan would result in a safe and healthyenvironment.



Table 12.3: Categories of industrial units for monitoring of liquid effluents under the Self-Monitoring and Reporting System

Category-A(1) Chlor-Alkali (Mercury Cell).(2) Chlor-Alkali (Diaphram Cell).(3) Metal finishing and electroplating.(4) Nitrogenous fertiliser.(5) Phosphate fertiliser.(6) Pulp and paper.(7) Pesticides formulation.(8) Petroleum refining.(9) Steel industry.(10) Synthetic fibre.(11) Tanning and leather finishing.(12) Textile processing.(13) Pigments and dyes.(14) Thermal Power Plants (Oil and

Coal Fired).(15) Rubber products.(16) Paints, Varnishes and Lacquers.(17) Pesticides.(18) Printing.(19) Industrial chemicals.(20) Oil and Gas production.(21 Petrochemicals.(22) Combined effluent treatment.(23) Any other industry to be

specified by Federal orProvincial Agency

Category-B(1) Dairy industry.(2) Fruit and vegetable processing.(3) Glass manufacturing.(4) Sugar.(5) Detergent.(6) Photographic.(7) Glue manufacture.(8) Oil and Gas exploration.(9) Thermal Power Plants (Gas Fired)(10) Vegetable oil and ghee mills.(11) Woollen mills.(12) Plastic materials and products.(13) Wood and cork products.(14) Any other industry to be

specified by federal or ProvincialAgency.

Category-C(1) Pharmaceutical (Formulation)

Industry.(2) Marble Crushing.(3) Cement.(4) Any other industry to be specified

by Federal or Provincial Agency

Source: Pak-EPA, n.d.

Table 12.4: Categories of industrial units for monitoring of gaseous emissions under theSelf-Monitoring and Reporting System

Category-A(1) Cement.(2) Glass manufacturing.(3) Iron and steel.(4) Nitrogenous fertiliser.(5) Phosphate fertiliser.(6) Oil and Gas production.(7) Petroleum refining.(8) Pulp and paper.(9) Thermal Power Plants (coal and oil based)(10) Boilers, ovens, furnaces and kilns (coal and oil fired)(11) Brick-Kilns (firewood and bagasse based)(12) Any other industry to be specified by Federal or Provincial Agency.

Category-B(1) Sugar.(2) Textile.(3) Choloralkali plants.(4) Dairy industry.(5) Fruits and vegetables.(6) Metal finishing and electroplating.(7) Boilers, ovens, furnaces and kilns (gas-

fired)(8) Any other industry to be specified by

Federal or Provincial Agency.

Source: Pak-EPA, n.d.


Table 12.5: National Environmental Quality Standards for Ambient AirPollutants

Sulphur Dioxide (SO2)

Oxides of Nitrogen as(NO)

Oxides of Nitrogen as(NO2)

O3

SuspendedParticulate Matter(SPM)

Respirable ParticulateMatter (PM10)

Respirable

Particulate Matter(PM2.5)

Lead (Pb)

CarbonMonoxide(CO)

Time-weightedaverage

Annual Average*24 hours**



1 hour


Annual Average*

24 hours**

Annual Average*

24 hours**1hour


8 hours**1 hour

Effective from1st July 2010

80 µg/m3

120 µg/m3

40 µg/m3

40 µg/m3

40 µg/m3

80 µg/m3

180 µg/m3

400 µg/m3

550 µg/m3

200 µg/m3

250 µg/m3

25 µg/m3

40 µg/m3

25 µg/m3

1.5 µg/m3

2 µg/m3

5 mg/m3

10mg/m3

Effective from1st January 2013

80 µg/m3

120 µg/m3

40 µg/m3

40 µg/m3

40 µg/m3

40 µg/m3

130 µg/m3

360 µg/m3

500 µg/m3

120 µg/m3

150 µg/m3

15 µg/m3

35 µg/m3

15 µg/m3

1 µg/m3

1.5 µg/m3

5 mg/m3

10mg/m3

Concentration in Ambient Air Method ofmeasurement

UltravioletFluorescence method

Gas PhaseChemiluminescence

Gas PhaseChemiluminescence

Non dispersive UVAbsorption method

High Volume

Sampling (Averageflow rate not less than1.1 m3/min).

β Ray absorptionmethod

β Ray absorptionmethod

ASS method aftersampling using EPM2000 or equivalentfilter paper

Non DispersiveInfra-Red (NDIR)method

Source: GoP, 2010*Annual arithmetic mean of min. 104 measurements a year taken twice a week for 24 hours at uniform interval. **24 hourly/8hourly values should be met 98% of the time in a year; 2% of the time it may exceed but not on two consecutive days.



Sr. Parameter Existing RevisedNo. Standards Standards

Into Into IntoInland Sewage SeaWaters Treatment (5)

1 2 3 4 5 61 Temperature or Temperature Increase* 40oC ≤3oC ≤3oC ≤3oC2 pH value (H+) 6-10 6-9 6-9 6-93 Biochemical Oxygen Demand (BOD) at 20oC(1) 80 80 250 80**4 Chemical Oxygen Demand (COD) (1) 150 150 400 4005 Total Suspended Solids (TSS) 150 200 400 2006 Total Dissolved Solids (TDS) 3500 3500 3500 35007 Oil and Grease 10 10 10 108 Phenolic compounds (as phenol) 0.1 0.1 0.3 0.39 Chloride (as Cl- ) 1000 1000 1000 SC***10 Fluoride (as F- ) 20 10 10 1011 Cyanide (as CN- ) total 2 1.0 1.0 1.012 Anti-ionic detergents (as MBAS) (2) 20 20 20 2013 Sulphate (SO4 2-) 600 600 1000 SC***14 Sulphide (S2-) 1.0 1.0 1.0 1.015 Ammonia (NH3) 40 40 40 4016 Pesticides (3) 0.15 0.15 0.15 0.1517 Cadmium (4) 0.1 0.1 0.1 0.118 Chromium (Trivalent and hexavalent) (4) 1.0 1.0 1.0 1.019 Cooper (4) 1.0 1.0 1.0 1.020 Lead (4) 0.5 0.5 0.5 0.521 Mercury (4) 0.01 0.01 0.01 0.0122 Selenium (4) 0.5 0.5 0.5 0.523 Nickel (4) 1.0 1.0 1.0 1.024 Silver (4) 1.0 1.0 1.0 1.025 Total Toxic metals 2.0 2.0 2.0 2.026 Zinc 5.0 5.0 5.0 5.027 Arsenic (4) 1.0 1.0 1.0 1.028 Barium (4) 1.5 1.5 1.5 1.529 Iron 2.0 8.0 8.0 8.030 Manganese 1.5 1.5 1.5 1.531 Boron (4) 6.0 6.0 6.0 6.032 Chlorine 1.0 1.0 1.0 1.0

Source: GoP, 2000Explanations:1. Assuming minimum dilution 1:10 on discharge, lower ratio would attract progressively stringent standards to be determined by the Fed. Env.

Prot. Agency. 1:10 dilution means that for each 1 m3 of treated effluent, the recipient water body should have 10 m3 of water for dilution of thiseffluent.

2. Methylene Blue Active Substances; assuming surfactant as biodegradable.3. Pesticides include herbicides, fungicides, and insecticides.4. Subject to total toxic metal discharge should not exceed level given at S.No. 25.5. Applicable only when and where sewage treatment is operational and BOD5 = 80mg/l is achieved by the sewage treatment system. 6. Provided discharge is not on the shoreline and not within ten miles of mangrove and other important estuaries.* The effluent should not result in temperature increase of more than 3oC at the edge of the zone where initial mixing and dilution take place in the

receiving body. In case zone is not defined, use 100 metres from the point of discharge. ** The value for the industry is 200mg/l.***Discharge concentration at or below sea concentration (SC).Note: Dilution of liquid effluents to bring them to the NEQS limiting values is not permissible through fresh water mixing with the effluent before

discharging into the environment. The concentration of pollutants in water being used will be subtracted from the effluent for calculating theNEQS limits.

Table 12.6: National Environmental Quality Standards for Municipal and Liquid Industrial Effluents (mg/l, unless otherwise defined)


Sr. No.

1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

Parameter

2

Smoke

Particulate Matter

(1)

Hydrogen Chloride

Chlorine

Hydrogen Fluoride

Hydrogen Sulphide

Sulpher Oxides (2) (3)

Carbon Monoxide

Lead

Mercury

Cadmium

Arsenic

Copper

Antimony

Zinc

Oxides of Nitrogen

(3)

Source of Emission

3

Smoke capacity not to exceed

(a) Boilers and Furnaces

(i) Oil Fired

(ii) Coal Fired

(iii) Cement Kilns

(b) Grinding, crushing, Clinker coolers andrelated processes, Metallurgicalprocesses, converter, blast furnaces andcupolas.

Any

Any

Any

Any

Sulfuric acid/Sulphonic acid plants

Other plants except power plants operatingon oil and coal

Any

Any

Any

Any

Any

Any

Any

Any

Nitric acid manufacturing unit

Other plants except power plants operatingon oil or coal

Gas fired

Oil fired

Coal fired

Existing Standards

4

40% or 2Ringleman Scale

300

500

200

500

400

150

150

10

400

800

50

10

20

20

50

20

200

400

400

-

-

Revised Standards

5

40% or 2Ringleman Scale

or equivalentsmoke number

300

500

300

500

400

150

150

10

1700

800

50

10

20

20

50

20

200

3000

400

600

1200

Table 12.7: National Environmental Quality Standards for Industrial Gaseous Emission(mg/Nm3, unless otherwise defined)

Source: GoP, 2000

Explanations:1. Based on assumption that the size of the particulate is 10 micron or more.2. Based on 1 percent Sulphur content in fuel oil. Higher content of Sulphur will cause standards to be pro-rated.



Background AirQuality(SO2 Basis)

Unpolluted

Moderately Polluted*

Low

High

Very Polluted**

AnnualAverage

<50

50

100

>100

Max.24-hoursinterval

<200

200

400

>400

Criterion IMax. SO2 Emission

(Tons per day per plant)

500

500

100

100

Criterion IIMax. Allowable ground level

increment to ambient air (µg/m3)One year Average

50

50

10

10

Sulphur Dioxide Background levels micro-gram per cubic metre (µg/m3) Standards

In respect of emissions of Sulphur Dioxide andNitrogen oxide, the power plants operating on oiland coal as fuel shall on addition to National

Environmental Quality Standards (NEQS)specified above, comply with the followingstandards:

B. Nitrogen OxideAmbient air concentrations of Nitrogen oxides, expressed as NOx should not exceed the following:

Annual Arithmetic Mean 100 µg/m3(0.05 ppm)

Emission level for stationery source discharge before mixing with the atmosphere should bemaintained as follows:

For fuel fired steam generators as Nanogram (10o-gram) per joule of heat input:

Liquid fossil fuel .. .. .. 130Solid fossil fuel .. .. .. 300Lignite fossil fuel .. .. .. 260

Note: Dilution of gaseous emissions to bring them to the NEQS limiting value is not permissiblethrough excess air mixing blowing before emitting into the environment.

A. Sulphur Dioxide

* For intermediate values between 50 and 100 µg/m3 linear interpretations should be used. ** No project with Sulphur Dioxide emissions will be recommended.

Source: GoP, 2000


Sr. No. Category of Area/Zone Effective from Effective from1st July 2010 1st July 2012

Limit in dB(A) Leq

Day Time Night Time Day Time Night Time

1 Residential Area (A) 65 50 55 45

2 Commercial Area (B) 70 60 65 55

3 Industrial Area (C) 80 75 75 65

4 Silence Zone (D) 55 45 50 45Source: GoP, 2010

Note: 1. Day time hours: 6.00 a.m. to 10.00 p.m.2. Night time hours: 10.00 p.m. to 6.00 a.m.3. Silence Zone: Zones which are declared as such by the competent authority. An area comprising not less than 100 metres around hospitals,

educational institutions and courts. 4. Mixed categories of areas may be declared as one of the four above mentioned categories by the competent authority.

*dB(A) Leq: Time weighted average of the level of sound in decibels in scale A which is relatable to human hearing.

Table 12.8: National Environmental Quality Standards for Noise

12.9 Practical element A student field visit should be organised of aproject, possibly one which has previously beencovered in e.g. within the EIA report quality reviewtheme, and an evaluation of the situation after

construction should be attempted. In thiscontext, whether monitoring is actually in placeshould be explored. Furthermore, studentsshould critically evaluate whether predictedimpacts or unpredicted impacts have occurred.



This chapter is divided into six sub-sections. First, terminology and theconceptual framework for EIA effectiveness are clarified. Then effectivenessframeworks are introduced. This is followed by a section introducingeffectiveness criteria. Subsequently, the empirical evidence for EIAeffectiveness is introduced and discussed. Recommendations are providedon how to support effective EIA. The main sources this chapter draws oninclude Fischer (2009) and Fischer et al. (2008; chapter 12 by Retief: pp.122-135).

13.1 Exploring effectiveness – terminology and conceptual frameworkEver since it was first used, EIA has been under pressure to prove its addedvalue. On the one hand, this pressure has come from developers, politiciansand decision makers. On the other hand, traditional disciplinary boundarieshave meant that this inherently inter-disciplinary decision support instrumenthas also, at times, been under fierce criticism from the research and academiccommunities. In this context, empirical evidence and proof of how effectiveEIA is in achieving its objectives is of particular importance. EIA effectivenessdebates have revolved around questions such as (Retief, 2008, p.122): l “is EIA a good idea and why?

l how do we know it adds value?

l can we prove that EIA is not a waste of time?

l is EIA as a decision support tool succeeding?”

To evaluate performance or effectiveness of EIA is a key component of any EIAsystem (Sadler, 1996; Wood, 2003). A particular challenge in this context isthat effectiveness evaluation is a cross cutting issue, which is integrated withother EIA debates. Reflecting on the EIA literature, Retief (2008) suggestedthat EIA key debates revolve around three interrelated themes: EIA identity,application and performance evaluation. This is illustrated in Figure 13.1.

13 EIA effectiveness – what do weneed to consider in order to enhancepositive and avoid negative effects


The first key debate revolves around the identityof EIA, asking ‘What is EIA?’ Other associateddebates deal with the need for EIA, what it aimsto achieve and how it can be defined. Thedifferent aspects of this debate help to develop abasic understanding of what EIA effectivenesscomprises and what it is about. What is ofparticular importance in this context is that theevolution of EIA thinking has not been driven bytheory, but rather by practice. EIA theory hasdeveloped later, mainly over the past twentyyears. Important EIA theory works include e.g.Bartlet and Kurian (1999), Lawrence (2000),Leknes (2001), Nilsson and Dalkmann (2001),Fischer (2003), Weston (2004), Richardson (2005),Fischer, (2007), and Elling (2008).

The second debate focuses on how EIA can beapplied, dealing with EIA systems as well asprocedural and methodological issues. Thesecond debate has clearly received mostattention in the professional literature to date.

Finally, the third debate is dealing with theevaluation of EIA performance or effectiveness,

exploring how well EIA is being conducted andwhat it is achieving. Achieving a betterunderstanding in theme 3 also means themes 1and 2 are enhanced.

13.2 Effectiveness frameworkDifferent people often have different things inmind when talking about effectiveness. Somethink of impact, others of success, and still othersof performance when using the term. Based on areview of the professional literature, Retief (2008)summarises the use of different terminology andexplains differences as follows:l effectiveness as compared with success:

While most authors use the term‘effectiveness’, some have also talked about‘success’, including e.g. Sadler (2004) andRunhaar and Driessen (2007). In practice thetwo terms are interchangeable.

l effectiveness as compared with impact: Theterm ‘impact’ is normally used when makingreference to the contribution of EIA ondecision-making. Retief (2008) thereforesuggests that ‘influence’ would be a better

Figure 13.1: Key EIA debates

Debate 3: Performance evaluation:

How well is EIA being done?

Debate 2: Application of EIA:

How can EIA be applied?

Debate 1: Identity of EIA : What is EIA?

Need

Purpose

Definition

Methodology Process

System

Effectiveness Quality

System

SEA follow-up

Source: Retief, 2007; 2005



Define scope and place in context

Assess institutional arrangements

Assess directoutputs

Assess process

Assess methods

Assess documents

Feedback

Assess indirectoutputs

Macro level

Micro level

Macro and

micro level

EIA quality analysis

EIA effectiveness

analysis

word to use in order to avoid confusion withthe word ‘impact’ in EIA.

l effectiveness as compared with efficiency:While these two terms are also often usedinterchangeably, there is a distinct differencebetween the two. Retief (2008) suggests that“generally speaking, effectiveness asks thequestion ‘are we doing the right things?’,while efficiency asks, ‘are we doing thingsright?’”.

l effectiveness as compared with quality: Retiefexplains that ‘quality’ is a measure for ‘inputs’to an EIA, including e.g. dealing withapplication of regulations, application ofmethods, and information products.‘Effectiveness’, on the other hand, is about

‘outputs’ (see also Lawrence, 1998). The twoare connected, as many believe that goodquality inputs can lead to effective outputs;

l effectiveness review as compared withperformance evaluation: Retief (2008)suggests that effectiveness review is a formof performance evaluation. Whileeffectiveness has been said to mean whetherthe EIA process works satisfactorily to meetthe intended purpose (Sadler, 2004),performance is more about the successfulaccomplishment of the task at hand.

l effectiveness review as compared with EIAfollow-up: While EIA effectiveness review isinterested in the effects during and afterproject planning (i.e. during implementation),

Figure 13.2: EIA quality/effectiveness analysis framework

Source: Retief (2008, p.126), based on Lawrence, 1997


follow-up is about the latter. However, it isimportant that follow-up also features duringEIA processes in that it needs to beconsidered early on.

Lawrence (1997) depicted a holistic frameworkwhich he named an ‘ideal EIAquality/effectiveness analysis’. This is shown inFigure 13.2. His framework requires the macrocontext to be defined. Afterwards, a micro levelreview is conducted, which includes looking atthe quality of process, methods anddocumentation. Furthermore, direct and indirectoutcomes are to be reviewed. A feature of theframework is that it is structured and clearlydifferentiates between macro and micro levels.

13.3 EIA effectiveness criteriaThere are two main aspects involved in measuringEIA effectiveness (Retief, 2007). The first involvesidentifying and formulating specific effectivenesscriteria. Secondly, methods are required formeasuring conformance with these criteria. Somehave argued that as the main purpose of EIA isabout influencing decision-making, onlyqualitative or subjective measurement may bepossible (Wood, 2003, p.10). Also, criteria maydiffer, depending on the specific context ofapplication (Annandale, 2001; Fischer andGazzola, 2006).

Marsden (1998) argues that criteria should bechosen that allow for the determination of theextent to which objectives may be achieved. Heputs forward an approach to effectivenessevaluation, consisting of three aspects:objectives, principles and criteria. These aregoing to differ, depending on the specific EIAsystem.

Retief (2008, p127) argues that a distinctionshould be made “between criteria designed tomeasure enabling conditions that would supporteffectiveness and criteria designed to actuallymeasure if EA was effective”. This is importantbecause there are different approaches todevising aspects that enable effective EIA. Theseinclude criteria that consider the whole EIA

system (Elling, 1997; Wood, 2003; Fischer, 2007),those that consider the quality of EIA reports (Leeand Colley, 1998; Curran, et al., 1998; Bonde andCherp, 2000) and those that consider the qualityof EIA processes (Fischer, 2002; IAIA, 2002;Noble, 2003). With reference to the previoussection, these criteria would broadly speaking beclassified as ‘input quality’ criteria rather than‘output effectiveness’ criteria. While someauthors have argued that to date input quality hasa weak link with output effectiveness (Retief,2005c), more recently Phylip-Jones and Fischer(2013) found a statistically significant correlationbetween the two for wind farm EIAs in Germanyand the UK. This was also confirmed to someextent by Arts et al. (2012). However, there canbe no doubt that the level of effectiveness isinfluenced by other factors, too. This includes inparticular a willingness of decision makers andproponents to use the instrument effectively.

Overall, there is consensus among theprofessional community that the ‘litmus test’ forEIA effectiveness is whether more informeddecisions were made on the basis of EIA.Furthermore, there is also a substantive aim,namely to maintain, or possibly ‘restore’,environmental quality. With regards to the latter, itis not possible to make direct comparisons ofenvironmental quality with and without EIA. Apossibility is to compare the same projects insimilar environments with and without theinstrument. This was done by Wende (2001) whofound a statistically significant difference withregard to the environmental quality resulting fromprojects with and without EIA in Germany.

Sadler (2004) proposed an effectiveness packageconsisting of a framework and a checklist. Theframework consists of: (1) a preliminary audit of the adequacy of

institutional arrangements; (2) a step by step review of EIA implementation

and operational performance;(3) a review of the technical, consultative and

administrative components of the EIAprocess; and



(4) a review of the influence of EIA on decision-making.

Following on from this, an overall review of EIAeffectiveness and performance is attempted.While this package provides a good starting pointfor reviewing the effectiveness of EIA, criteria willdiffer depending on the specific context ofapplication, i.e. between different countries.

Based on a multi-track approach put forward byPartidario and Arts (2005), Retief (2008) outlinedfive possible pathways for designing EIAeffectiveness criteria, as follows:l Track 1: Monitoring and auditing;

l Track 2: Evaluating achievement of statedobjectives;

l Track 3: Evaluation of the performance of thestrategic initiative;

l Track 4: Checking conformance ofsubsequent decision-making with thestrategic initiative and SEA; and

l Track 5: Monitoring and evaluation of theactual impacts of a strategic initiative on theenvironment and sustainability.

13.4 Empirical evidence for EIA effectivenessInitially, during the early years of EIA application,many EIA advocates were convinced that EIA wasindeed able to protect the environment and leadto better decisions. Wandesforde-Smith andKerbavaz (1988, p.162), for example, stated that:

“At the US federal level, impact assessmentworks. We know it works to influence projectselection and design and to mitigateenvironmental impacts”

Subsequently, EIA became subjected to muchcriticism, in particular in the second half of the1990s and the first few years of the 2000s. Thiswas connected with the so-called ‘post-modern’turn in decision-making and planning. Thosepropagating it did not believe that an instrumentbased on a rational framework was able toinfluence decisions. This, they argued could onlybe achieved through discourse. However, studiesevaluating EIA at the time found that while thereclearly were problems, overall EIA clearly did havean impact on decision-making and was makingdecisions more environmentally sustainable. Oneexample is shown in Table 13.1, looking at variousaspects that are said to contribute to EIA as asuccessful policy instrument, following work bySadler (2004).

Table 13.1: Current performance of aspects that contribute to making EIA a successful policy instrument

Aspect Evaluated Score / ratingTest 1: Wide adoption and use B+Test 2: Record of process innovation or improvement BTest 3: Inclusion of new areas and aspects A-Test 4: Added value to decision-making and condition setting C+Test 5: Effective means of achieving environmental protection C-

Evaluation scale:A = The feature is represented fully and completelyB = The feature is represented well but there are minor qualificationsC = The feature is represented but there are a number of reservationsD = The feature is not represented wellE = The feature is represented only minimally or incipientlySource: Sadler, 2004


Another study by Wood (2003) compared theinfluence of EIA reports on decisions for sevencountries (See: Table 13.2). He found that in allcountries there were regulatory requirements forthe EIA report to be considered in decision-making and that in practice six of the sevencountries could demonstrate partial influence.Wood concluded that although all countries haddiffering mechanisms for trying to make sure EIAgets considered, decision makers often try tocircumvent them, based on other political orsocial agendas. Quite a few other studiesconfirmed his results, establishing an overallmoderate impact of EIA only (Wood and Jones,1997; Cashmore et al., 2004; Christensen et al.,2005; Jay et al., 2007).

In 1990, the Dutch Evaluation Committee (inSadler 1996) found that early (i.e. pre-1990) ECDirective based EIAs had only a negligible or at

best small influence on project development, ifcompared with the time and money spent onthem. However, it also found that just over half(52%) of the EIAs had led to concretemodifications of the project and that 68% hadinfluenced the parties involved in the projectmaking process.

Papoulias and Nelson (1996) conducted a surveyof EU member states’ competent authorities’opinions on the effectiveness of EIA. They foundthat overall, EIA was perceived as being effective.Furthermore, they established that overall, EIAwas perceived as having an overall positive cost-benefit ratio, i.e. EIA was value for money in termsof leading to changes in underlying projects.

Ten Heuvelhof and Nauta (1997) found that EIAsin the Netherlands had a great impact, suggestingthat 79% of Dutch EIAs showed high direct

Criterion question: Must the findings of the EIA report and the review be a central determinant of the decisionon the action?

Jurisdiction Criterion met? Comment

United States Partially Consideration in and explanation of, decision and disclosure ofenvironmental effects mandatory. In practice, EIS often influencesdecisions

United Kingdom Partially Environmental information is a material consideration but notnecessarily a central determinant. Practice varies.

The Netherlands Partially Explanation of way environmental impacts considered in decision-making mandatory. In practice, EIA generally influences decisions.

Canada Partially Findings of self-directed assessment influence minister’s decision:reason must be given by relevant authority when cabinet disagreeswith recommendations of public review report

Australia Partially Environment Australia’s assessment report based on EIA report mustbe taken into account in determining Environmental Minister’s decisionon approval.

New Zealand Partially Act makes EIA central to decision but, in practice, EIA is sometimesnot given appropriate weight. Practice improving.

South Africa No Environmental authorisation must be based on scoping report orenvironmental impact report but decision sometimes narrowly basedon nature conservation matters, not on full range of EIR issues.Refusals rare.

Source: Retief, 2008, based on Wood, 2003

Table 13.2: Consideration of EIA in project level decision-making


Higher Education Institutions in Pakistan 151

benefits. Furthermore, they specified that evenwhen taking into account the time and financialefforts required to produce an EIA, 69% of themwould still have a beneficial impact. Theyidentified three reasons for their findings: (1) theprocess-bound nature of EIA; (2) the possibility ofconsidering EIA as part of the negotiation arena;and (3) the presence of the EIA Committee and itsrole in the process.

Marr (1997) examined EIA practice for wastewatertreatment plants conducted between the late1980s and 1993 in the UK and Germany. Herfindings of practice in the early days of formal EIArequirements in both countries indicate a rathervaried picture regarding the influence of EIA ondecision-making. While half of 27 interviewedcompetent authorities from the UK whoexpressed an opinion said that EIA had led tomodifications in a wastewater treatment project(more than 80% said the EIA-report was animportant consideration), only one third of the 34interviewed German competent authorities sharedthis opinion (with less than 50% saying that theEIA-report was an important consideration).Marr’s study is particularly useful in terms ofraising questions on possible differences betweendifferent countries and sectors, but also regardingthe importance of considering the overall contextwithin which EIA is applied. Thus, thecomparatively low impact in the German casewas found to be connected with the existence ofa formal landscape / environmental planningsystem which had been in existence in Germanysince the late 1970s, following requirementsformulated in the Federal Nature Conservation Act1976. This was already fulfilling many of the tasksthat EIA is supposed to deliver.

Based on a quality review of 112 EIA reports fromeight EU member states i.e. Denmark, Germany,Portugal, Spain, the UK, Belgium, Ireland andGreece, Barker and Wood (1999) concluded that

‘there is no doubt that the EIA process is bringingabout modifications to the projects assessed,

although many of the mitigation measuresproposed are of minor significance’.

Nitz and Holland (2000) looked at environmentalmanagement commitments made within 285Australian EIA reports. They found that a majorityof these contained environmental monitoring andmitigation commitments. More than half of theEIA reports also contained suggestions forcorrective actions.

Wende (2001) examined the performance of 125EIAs in Germany that had been prepared between1990 and 1997. In this context, he looked at theimpacts of these EIAs on ‘spatial modifications inplanning decisions’, and compared outcomeswith eleven projects which did not include EIA(these ranged from roads and waterways, overshopping and recreational to waste disposal andsewage treatment projects). Importantly, hefound that there was a significant difference in thepredicted direction i.e. spatial modifications ofprojects involving EIA.

Christensen et al. (2005) evaluated 36 DanishEIAs. They found that in 90% of these, projectswere modified based on EIA. However, they alsoestablished that most of these were only minor.

Finally, a comment on post-EIA auditing. Auditingallows to establish whether EIA ‘greening’ effortsare based on correct predictions. If predictionsturn out to be largely incorrect, then ‘greening’may be judged as not having been successfullyachieved. In this context, it appears that we arewitnessing a slow improvement of the situation.Thus, while in 1988, Bisset and Tomlinsonidentified 95% of all EIS predictions as eitherincorrect, unsure, unverifiable or non-quantifiable,Dipper et al.(1998) found that ‘only’ 55% fell intothis category. Of those predictions that wereauditable, nearly three -quarters were accurate.More research in this context is urgently needed.

More recently, Phylip-Jones and Fischer (2013)evaluated the application and impact of EIA for


0

2

4

6

8

10

12

14

16

18

20

Reduction in the number of turbines

Change in the wind farm layout

A stipulation of a specific wind turbine

type or size

Condition on the overall operating life-

time

Condition for site re-instatement

Restrictions on construction activity

(hours)

Conditions relating to electrical cable

routing

Num

ber o

f miti

gatio

n m

easu

res

UK Onshore Wind Farm EIA UK Offshore Wind Farm EIA German Onshore Wind Farm EIA German Offshore Wind Farm EIA

twenty wind farms (ten onshore and ten offshore)in the UK and Germany. They established a majorto moderate impact on the decisions made(Figure 13.3).

They also provided for an overview of the typeand extent of measures adopted in wind farmdevelopments based on EIA. This is summarisedin Figure 13.4. In all twenty cases conditions

were included on the overall operating lifetime ofthe wind farm and the site re-instatement afteroperation. Furthermore, fifteen cases included areduction in the number of turbines and tenrestrictions on construction activity. Furthermeasures considered included changes to windfarm layouts, stipulations of specific wind turbinetypes or sizes and conditions relating to electricalcable routing.

Figure 13.3: Decision makers’ perceptions on the overall influence of EIA

Source: Phylip-Jones and Fischer, 2013

Figure 13.4: Type and extent of mitigation measures in wind farm EIAs

Source: Phylip-Jones and Fischer, 2013

0

1

2

3

Major Moderate Minor None

Num

ber o

f res

pond

ents

Effect of EIA on decision-making

UK Onshore EIA Decision Makers German Onshore EIA decision makers

UK offshore EIA decision makers German Offshore EIA decision makers

N=20

3

5

2

5

111

4 35

5

5

5

53 3

111

3

2

2

5

5

5

211



13.5 How to support effective EIAMuch has been written on how to improve EIA.This includes e.g. the existence of best practiceguides and principles, local guidance and others.Also, there is now a wide range of trainingcourses and capacity building programmesavailable. Sadler (2004) summarised supportmeasures in terms of two aspects. First, there arerequirements for appropriate institutionalarrangements e.g. sound administration,management and EIA process review. Secondly,he introduced three competencies for conductingEIA, referred to as the ‘three Rs’ of good practice,namely: rigorous analysis, responsive consultationand responsible administration.

Various authors have looked at factors that makeEIA effective. More recently, in this context, thefocus has been on strategic environmentalassessment (SEA). Most authors have focusedon the overall context within which the instrumentis applied, and it is therefore suggested here thatthey are also applicable to a large extent to EIA.Two publications from the last decade haveprovided literature reviews on the subject.Runhaar and Driessen (2007), for example, lookedat how fifteen publications were looking ateffectiveness. The following importanteffectiveness criteria were identified:l SEA needs to be flexible in order to fit into

the decision-making context;

l Stakeholders need to be given an opportunityto participate;

l The SEA process needs to be transparent;

l SEA needs to have a binding character;

l Assessment needs to be of good quality;

l Values in SEA should reflect the values of thepolicy context;

l Decision makers should be open toenvironmental / sustainability issues;

l SEA needs to be tiered with otherassessments;

l Adequate resources need to be madeavailable; and

l Communication needs to be effective.

Fischer and Gazzola (2006) evaluated 45professional publications, identifying two broadcategories of criteria that support effectiveness.These include context and methodologicalcriteria, as follows:l Context criteria for effective SEA application:

- the existence of an established institutionalframework for the effective consideration ofthe environment including, in particular,biophysical aspects in PPP making,including an awareness for environmentalproblems as well as the existence of asustainable development framework thatprovides for SEA objectives;

- the existence of effective co-operation andpublic participation in PPP making; and

- the existence of an effective project EIAsystem with which SEA can be tiered.

l Methodological criteria for effective SEAapplication:- a high degree of accountability and quality

control in SEA;

- a stakeholder driven, focused, iterative,flexible and adaptable SEA process that isopen to the input of the general public; and

- cost and time efficient generation ofsufficient, reliable and usable informationon environmental baseline, impact andalternative assessments in SEA making.

Retief (2007) looked at SEA practice and itseffectiveness in South Africa. His findings are ofimportance for many other developing countries,too. He suggests that even in a system with no


formal SEA requirements extensive practice candevelop. In this context, he says that a range offactors are important, including an enabling legalframework combined with a strong consultancysector. What is of particular importance ofRetief’s findings is that in contrast to what manyother authors are saying, he suggests thatextensive practice may even be able to develop inthe presence of a lack of clarity on what exactlySEA comprises, a lack of explicit SEA legislationand possibly even without a strong commitmentfrom decision-makers and weaknesses ofcapacity within the public sector. However, whatis also important is that extensive practice doesnot necessarily mean the instrument is appliedeffectively. An important implication of Retief’sfindings is that countries can have voluntary SEAsystems in place, but they may not be able toimplement recommendations of SEA in practice.

13.6 Practical element

The practical element for the theme EIAeffectiveness can involve students in exercisessuch as role plays and games. Students can thustest how they may be able to influence othersduring assumed decision-making processes.Subsequently, short essays may be prepared onhow EIA is thought to be effective in greeningdecision-making. In this context, Pakistaniexamples should be sought and described.



This chapter is divided into six sections. First, what SEA is and how it differsfrom EIA is explained. Next, the SEA process is introduced. SEA is definedand its potential benefits are explored. The substantive focus of SEA anddifferences from project EIA are elaborated on, before principles of SEA anddifferent SEA approaches are introduced. Some international plan andprogramme SEA case studies are presented. While the complimentary NIAPdocument to the curriculum, the ‘EIA Handbook’ lists a range of EIA casestudies, there is currently a lack of suitable SEA cases. This is the main reasonfor including those here. The main sources this chapter draws on includeFischer (2007), Furman and Hilden (2001), and Department of EnvironmentalAffairs and Tourism (2004b).

14.1 Introduction to SEA - what is it and how does it differ from EIAThe primary purpose of EIA is to determine and evaluate the environmentalimpacts of development and to inform decision-making at the project level.However, there are a number of more strategic decisions that are typicallymade at plan, programme and policy levels of decision-making. These canhave a major impact on the nature of later development. At these more‘strategic’ levels of decision-making, strategic environmental assessment(SEA) has evolved. This is supposed to determine the environmentalimplications of policies, plans and programmes and is complementary to EIA.

Initially, SEA was mainly thought of in terms of the application of project EIAprinciples to PPPs (Fischer and Seaton, 2002). However, subsequentlydifferent interpretations emerged that were connected in particular with:l the different geographical and time scales of SEA and EIA (Lee and

Walsh, 1992);

l the different levels of detail at strategic and project tiers (Partidário andFischer, 2004); and

l the different ways in which strategic decision processes are organised,when compared with project planning (Kørnøv and Thissen, 2000; Nitzand Brown, 2001).

To date, SEA has been applied in a wide range of different situations, including

14 Introduction to SEA


Figure 14.1: EU Directive based SEA process

Source: Fischer, 2007; see also European Commission, 2006

trade agreements, funding programmes,economic development plans, spatial/land useand sectoral, such as transport, energy, waste,and water policies, plans and programmes(PPPs). Numerous examples for SEA applicationsin a range of sectors can be found in theprofessional literature, including spatial/land useplanning (Therivel, 2008; Fischer, 2010), transportplanning (Fischer, 2002; 2006), wastemanagement (Arbter, 2005; Verheem, 1996;Fischer et al. , 2011), trade (Kirkpatrick andGeorge, 2004), oil and gas extraction (DTI, 2001),

economic development plans (Fischer, 2003b),wind farms (Kleinschmidt and Wagner, 1996;Schomerus et al. 2006; Phylip-Jones andFischer 2013), water/flood management (DEFRA,2004), tourism (Lemos et al., 2011) and fundingprogrammes (Ward et al., 2005). Finally, policySEA has been the main focus of two publications,including Sadler (2005) and the World Bank(2005).

Currently, probably the best-known SEA‘framework law that establishes a minimum

Plan and programmemaking process

Identify aims andobjectives of

strategic action

Identify alternativeways to achieve

objectives

Assess alternativesand choose preferred

alternative

Prepare draftpland and have

it reviewed

Decision Making-

approve plan

Implement andmonitor strategic

action

Notes: 1 not explicitly required by the Directive.2 according to the Directive, at least at scoping and report stages of the SEA process.

Screening: is aSEA likely to be

necessary?

Scoping: Issues tobe considered;

baseline, objectivesand targets

Assessment: avoid,minimise, mitigate,

compensate

SEA Report:(and

Review1)

Decision Making:–

approve SEA

SEA Monitoringand follow-up

SEA process

A

B

C

D

E

F

Consultationand

participation2



common procedure for certain official plans andprogrammes’ (Dalal-Clayton and Sadler, 2005,p.37) is the European Directive 2001/42/EC on theassessment of the effects of certain plans andprogrammes on the environment (‘SEA Directive’;European Commission, 2001b). This Directiveadvocates the application of a systematic, pro-active EIA-based and participative process that isprepared with a view to avoiding unnecessaryduplication in tiered assessment practice. In thiscontext, however, policies and cabinet decision-making are not mentioned. In its short lifetime todate, the SEA Directive has not only had animpact on EU member states, but also within awider international context. It has been areference point for practice, for example, in Asia,Africa and South America. Furthermore, the Kievprotocol to the Espoo Convention (UNECE, 2003)on trans-boundary SEA formulates almostidentical requirements to the Directive, though italso explicitly mentions the possibility of applyingSEA at the policy level. This protocol and theassociated Resource Manual (UNECE, 2006) arelikely to enhance SEA application in UnitedNations Economic Council for Europe (UNECE)states outside the EU.

14.2 The SEA processFigure 14.1 shows a SEA Directive-based

assessment process. This is EIA based and islinked to plan and programme making stages in acontinuous and integrated decision flow. Thisprocess is objective-led namely, trying toinfluence PPP making so that certain objectivescan be reached) and baseline-led namely, relyingon baseline data to be able to make reliableprojections in assessment), and reflects ideas ofinstrumental rationality (Faludi, 1973). If applied inthe way shown in Figure 14.1, the SEA process isthought to be able to influence the underlying planand programme making process, with a view toimproving it from an environmental perspective.Furthermore, a SEA that is applied in this mannermay reshape the plan and programme decisionflow, supporting not only the consideration ofenvironmental issues at each stage of theprocess, but also leading to improvedtransparency and governance (Kidd and Fischer,2007).

Describing non-EIA-based SEA, applied in policyand cabinet decision-making situations, at timesalso referred to as ‘policy assessment’-basedSEA, is not as straightforward, as this is normallyportrayed as being flexible, adaptable and attimes communicative i.e. reflecting ideas ofcommunicative rationality (See: Healey, 1996).However, even non-EIA-based SEA is normally

Box 14.1: Definition of SEASEA aims to ensure that due consideration is given to environmental and possibly other sustainability aspects inpolicy, plan and programme making above the project level. It is:• A systematic, objectives-led, evidence-based, proactive and participative decision-making support process

for the formulation of sustainable policies, plans and programmes, leading to improved governance; it canfunction as:– a structured, rigorous and open project EIA-based administrative procedure in public and, at times, private

plan and programme making situations;– a possibly more flexible assessment process:– in public and at times private policy-making situations; and– in legislative proposals and other policies, plans and programmes, submitted to cabinet for decision-

making.

• A policy, plan and programme making support instrument that is supposed to add scientific rigour to decision-making, applying a range of suitable methods and techniques; and

• A systematic decision-making framework, establishing a substantive focus, particularly in terms of alternativesand aspects to be considered, depending on the systematic tier (policy, plan or programme), administrativelevel (national, regional, local) and sector of application.

Source: Fischer, 2007


perceived as being a systematic process, whichmay take different forms (See: Kørnøv andThissen, 2000). To date, attempts to define non-EIA-based SEA in a generic way have either led toa somewhat blurred picture of SEA or, ironically,have made it look similar to EIA-based SEA. Thiswas described by Fischer (2003a), based onobservations made by Tonn et al. (2000) andNielsson and Dalkmann (2001). Generallyspeaking, non-EIA-based assessmentapproaches are considered to be lessmethodologically rigorous than EIA basedprocesses, and descriptions of non-EIA-basedSEA frequently mention the following coreelements:l Specifying the issue (problem identification);

l Goal setting (what are aims, objectives andtargets);

l Information collection;

l Information processing and consideration ofalternatives;

l Decision-making; and

l Implementation.

While there are a range of non-EIA-basedsystems, there is currently hardly any empiricalevidence available for what makes non-EIAprocess-based SEA effective.

14.3 Definition and potential benefits of SEASEA’s main aim is to ensure due consideration isgiven to environmental and possibly othersustainability aspects in PPP making above the

project level. Furthermore, it is supposed tosupport the development of more transparentstrategic decisions. It attempts to providerelevant and reliable information for thoseinvolved in PPP making in an effective and timelymanner. As mentioned above, the exact form ofSEA will depend on the specific situation andcontext it is applied in. Procedurally, differencesare particularly evident between administration-led SEA and cabinet SEA. Regarding thesubstantive focus, that is, the issues andalternatives to be considered, differences mayexist between different administrative levels (forexample, national, regional, local), strategic tiers(for example, policy, plan and programme) andsectors (for example, land-use, transport, energy,waste, water). While certain key elements arelikely to be reflected in every SEA system, otherswill differ depending on established planning andassessment practices, as well as on the specifictraditions of the organisations preparing PPPsand SEAs. Based on what has been described inthe previous section, Box 14.1 presents an up-to-date definition of SEA.

Generally speaking, a range of benefits aresupposed to result from the application of SEA.In this context, SEA aims at supporting PPPprocesses, leading to environmentally sound andsustainable development. Furthermore, itattempts to strengthen strategic processes,improving good governance and building publictrust and confidence into strategic decision-making. Ultimately, it is hoped that SEA can leadto savings in time and money by avoiding costlymistakes, leading to a better quality of life. Box14.2 shows those SEA characteristics, based onwhich benefits are thought to result.

Box 14.2: SEA characteristics, based on which benefits are thought to result1. SEA allows for a more systematic and effective consideration of wider environmental impacts and alternatives

at higher tiers of decision-making, leading to more effective and less time-consuming decision-making andimplementation.

2. SEA acts as a proactive tool that supports the formulation of strategic action for sustainable development.3. SEA increases the efficiency of tiered decision-making, strengthens project EIA and identifies appropriate and

timely alternatives and options; in this context, it helps to focus on the right issues at the right time and aimsto uncover potentially costly inconsistencies.

4. SEA enables more effective involvement in strategic decision-making, creating knowledge at low costs.

Source: Fischer, 2007; adapted from Fischer (1999a) and Dusik et al. (2003).



14.4 Focus of SEA and differences from projectEIASEA is applied in strategic decision-makingcontexts that precede project decisions. Beingassociated with decisions on aims and objectivesfor future development, SEA may deal with issuessuch as need and demand management,evaluating, for example, different fiscal, regulatoryor organisational and spatial developmentoptions. Project EIA, by contrast, deals withdetailed decisions that are normally concernedwith the location and design of a project. Inpractice, project EIA has frequently shown torevolve around measures for mitigating negativeenvironmental impacts. Alternatively, SEA wouldnormally aim at preventing negative impacts andat proactively enhancing positive developments.Furthermore, whereas in project EIA, alternativesto be assessed are often limited to minor variants,SEA may address a broad range of alternativescovering different sectors.

SEA can be applied in a range of situations thatmay differ in terms of their ‘strategicness’, and therange of different SEA applications is much widerthan the range of project EIA applications. Box14.3 summarises the changing focus of SEA,depending on how far away from the project levelit is applied, that is, how ‘strategic’ it is. This

shows a transition in the shape that SEA is likelyto take from lower tiers of decision-making tohigher tiers. Whereas at lower tiers, SEA is likelyto be based on a more rigorous EIA-basedapproach, at higher tiers it is likely to be moreflexible, and possibly non-EIA based. Methodsand techniques applied vary, depending on thespecific situation of application. At lower tiers,methods and techniques typically used in EIA forexample, field surveys, overlay mapping andmulti-criteria analysis (MCA) for comparingdifferent spatial alternatives may be useful andappropriately applied.

At higher tiers, methods and techniques typicallyapplied within policy-making may be moreappropriate, such as forecasting, backcasting andvisioning. Furthermore, there are methods andtechniques that may be applied at both, higherand lower tiers, including, for example, checklists,matrices and impact trees. Generally speaking,quantification within assessment is more difficultto achieve at higher tiers that come with a greaterdegree of uncertainty. However, this does notmean that it is impossible to apply morequantitative techniques, as the frequent use ofscenario analysis and mathematical modellinghave shown (See Fischer, 2002).

Box 14.3: The changing focus of SEA from lower tiers to higher tiers

Source: Fischer (2007)

SEA EIA

Decision making Policy Plan Programme ProjectlevelNature of action Strategic, visionary, Immediate,

conceptual operationalOutput General DetailedScale of impacts Macroscopic, Microscopic,

cumulative, unclear localisedTimescale Long to medium term Medium to short termKey data sources Sustainable development Field work

strategies, state of the sample analysisenvironment reports, vision

Type of data More qualitative More quantitativeAlternatives Area wide, political, regulative, Specific locations, design,

technological, fiscal, economic construction, operationRigour of analysis More uncertainty More rigourAssessment Sustainability benchmarks Legal restrictions andbenchmarks (criteria and objectives) best practice

Role of Mediator for negotiations Advocator of values and normspractitioner Technician, using stakeholder valuesPublic perception More vague, distant More reactive (NIMBY)

‘Higher tiers’ / ‘Lower tiers’


14.5 Principles of SEA and different SEAapproachesThe rationale for applying SEA is connected withcurrent shortcomings of PPP making. In thiscontext, the necessity for SEA results from theneed for:l a stronger representation of strategic

environmental thinking in PPP making;

l more effective reasoning in decision-making;

l more efficient decision-making; and

l better support of good governance andsustainable development in decision-making.

These four needs are subsequently described infurther detail.

14.5.1 The need for a better representation ofstrategic environmental thinking in PPPmakingThe main reason for introducing SEA has been theperceived weak representation of environmentalaspects in PPP making (Dusik et al., 2003;Morrison-Saunders and Fischer, 2006). In thiscontext, and despite the widespread claim bypolicy makers and planners in many countriesthat a balanced evaluation is achieved, non-material, cultural, social and ethical values havetended to be underrepresented due to utilitarianand economistic views prevailing in planning(Ortolano, 1984). Having identified this as aproblem, many countries now have introducedformal environmental assessment requirements,aiming to improve the consideration of theenvironmental dimension in decision-making.However, in spite of the efforts made,environmental issues – and particularly those thatare of a strategic nature – are still frequentlytreated as simple ‘add-ons’ that are taken intoaccount not during, but after PPP processes havebeen conducted. This means that environmentalissues are dealt with in a reactive way.

A reactive approach, however, means that themain focus of assessment is on mitigation of

negative environmental impacts, rather than onproactively finding ways for avoiding negativeimpacts and enhancing positive impacts.Furthermore, applying SEA in a reactive mannermeans that environmental standards – if available– are unlikely to be effectively used to guide PPPmaking. In current PPP making practice,concrete quantitative environmental thresholdsare only rarely available. Also, if they do exist,they are frequently not respected (Fischer, 2002).In addition, there are indications that long-termvisions of sustainable development andassociated aims and objectives, with timehorizons of between 20 to 30 years are notconsistently followed through (Fischer, 2004).Rather, short-term political interests frequentlyappear to prevail. This problem is closelyconnected with the duration of election cycles.

Finally, a consistent consideration of thresholdswithin the whole planning system, that is,throughout all sectors and administrations, isnormally difficult because in most countries andsystems, different planning tiers, levels andsectors are isolated rather than effectivelyintegrated and may have different aims andobjectives (Stead et al., 2004). In this context,SEA may be used as a reconciliatory tool ofdifferent administrative levels, systematic tiersand sectors. How this might happen wasdiscussed by Barker and Fischer (2003) for thepre-2004 English spatial or land use planningsystem.

14.5.2 The need for more effective reasoning indecision-makingSEA is more than the application of predictiontechniques and methods within an assessmentprocess. Rather, it provides for a systematicdecision-making framework, identifying tasks tobe addressed at different tiers and administrativelevels (Fischer, 2006). In this context, SEA canhelp decision-makers to ask questions relevant toa specific tier, leading to more effective reasoningin decision-making. A generic SEA frameworkcan thus guide decision-makers in systematicallyaddressing, for example:



l initial ‘why’ and ‘what’ questions; typically atthe policy tier of decision-making:– identifying and/or defining underlying –

sustainability – objectives and targets;– supporting identification of possible

development scenarios and policyoptions;

– enabling the assessment of impacts ofpolicy options on objectives and targets;

l subsequent ‘what’, ‘where’ and ‘how’questions; at the plan tier of decision-making:– proactively developing possible – spatial –

development options;– enabling the assessment of impacts of

these options on objectives and targets;

l ‘where’ and ‘when’ questions at theprogramme tier of decision-making:– supporting ranking of possible projects

and/or alternatives in terms of, forexample, benefits and costs.

The value of a tiered approach to SEA lies in itspotential to enable greater transparency andintegration, supporting more effective streamliningof strategic planning. Furthermore, connectionswith other PPPs may be made explicit, thushelping to avoid duplication. Tiering within PPPmaking and SEA is not just a conceptual idea; thisis evident when looking at current practice, forexample, in transport planning in northern andwestern European countries (Fischer, 2006).Here, practice has been observed to fall into oneof four main categories, which may be dubbedpolicy SEA, network-plan SEA, corridor-plan SEAand programme SEA. In this context, whereastransport policy SEAs have been found to addressinitial ‘why’ and ‘what’ questions, network-planSEAs were found to revolve around subsequent‘what’ and ‘where’ questions. Corridor plan SEAswere found to address ‘where’ and ‘how roughly’questions, and programme SEAs, finally, werefound to focus on ‘when’ questions. At times,categories are combined, for example, policy andnetwork plans, as was the case with the regionalDutch transport strategies in the 1990s; (See:

Fischer, 2002) or corridor plans and programmes ;in other words, in practice boundaries are oftenflexible. Tasks may not only be allocated todifferent systematic tiers such as policies, plansor programmes, but also to differentadministrative levels.

14.5.3 The need for more efficient decision-makingSEA can support more efficient decision-making,particularly by, first, helping to achieve morestructured decision-making frameworks, thuscreating the context for more focused PPPmaking and subsequent project planning and EIA,and second, by supporting more systematic PPPprocesses. A systematic decision-makingframework may support addressing ‘the rightissues at the right time’ at different tiers, asexplained above. Ultimately, a framework, withinwhich different tiers and levels address differentissues, tasks and alternatives, may help avoiddelays in subsequent project preparation. In thiscontext, SEA should help to address problemsearly enough in order to be able to proactivelysolve them, thus maximising positive impacts andpreventing damage rather than only aiming atmitigating negative impacts.

Acting as a proactive decision framework andsupporting more systematic PPP processes, SEAmay help to detect not only direct, but alsoindirect, cumulative and synergistic effects.Providing for a participative process, SEA mayenable the effective gathering of information andinputs from a wide range of stakeholders.Furthermore, providing for a tiered decisionframework, SEA may support decision-makers toask the right questions at the right time. In thiscontext, SEA can also advise decision-makersand assessors on how to act, based on thetechnical knowledge and the expected potentialconflicts in a certain situation, therefore helpingthem to act more efficiently.

‘Acting strategies’ may revolve around: first,mediation, for example, in more vague policysituations, where ‘why’ and ‘what’ questions are


addressed; second, advocacy in planningsituations in which ‘where’ and ‘how’ questionsare addressed and in which policies are supposedto be implemented; and third, technicalapproaches, where ‘when’ questions areaddressed, based on, for example, MCA andcost–benefit analysis (CBA). While advocacy andtechnical approaches may work well in structuredEIA-based processes, they may be less helpful inprocesses, in which the assessor needs to act asa mediator, requiring a higher degree of flexibility.Required skills in the context of mediation are lesstechnical and include communication andnegotiation capabilities (Heikinheimo, 2003).

14.5.4 The need for supporting goodgovernance and sustainable development indecision-makingMore recently, the use of SEA has been discussedin the context of its potential for improvinggovernance (Kidd and Fischer, 2007). This ismainly based on its capability to increasetransparency, participation and inclusiveness byadvocating a participatory and structuredassessment process. In SEA, communication,participation and reporting have an important roleto play by introducing perspectives and inputs ofdifferent stakeholders to the PPP making process.Expected achievements can be subdivided intotwo main streams:

1 Long-term public empowerment:– leading to, for example, conflict

resolution, gain of public support forfuture actions, increased publicconfidence in decision-making and inpoliticians, development of socialownership and belonging.

2 An improved and more effective PPP process:– leading to, for example, the identification

of public concerns and the introduction ofnew ideas for possible solutions;

– ensuring that alternatives are consideredand that decision makers and proponentsare accountable; and

– providing opportunity to share expertiseand to benefit from local knowledge andfresh perspectives on the SEA process.

The practice of public participation in SEA shouldanticipate and, if possible, help to avoid NIMBY(not in my back yard) and LULU (locally unwantedland use) situations, that often occur at projectlevels of decision-making. Ultimately, this shouldlead to reduced costs and avoidance of decisiondelays. The results to be achieved throughcommunication, participation and reporting inSEA are likely to differ from those achievable inEIA. In this context, it is important toacknowledge that the general public is unlikely tobe equally interested in all strategic issues, whichat times may appear too unclear and unspecific.By providing for a systematic decision-makingframework, SEA may lead to increasedeffectiveness and efficiency of decision-making.Ultimately, if applied in a systematic, participativeand structured manner, SEA should lead toincreased accountability, better integration,increased responsiveness and resilience ofdecision-making, thus supporting goodgovernance. As explained above, SEA works asan effective decision-making support instrumentfor sustainable development. In this context,various authors have shown that it is potentiallyable to support PPP formulation for sustainabledevelopment by providing for an objectives-led,alternatives-focused and participatory instrument(Sheate, 1992; Fischer, 1999b).

Generally speaking, what makes definingsustainable development difficult is not justdifferent attitudes and value systems, but alsodifferent dimensions and speeds of the varioussustainability aspects to be considered. While, forexample, fens or moorlands can take up to 1,000to 10,000 years to develop fully, in businessplanning, a time horizon of ten to twenty yearswould in many cases already be consideredstrategic. Modern shopping centres, for example,are built for a lifespan of about fifteen years.Planning for sustainable development cantherefore only be considered effective if clearobjectives are in place for what a society wants toachieve in the short-, medium- and long-terms(see also below and Chapter 3). Furthermore, it isimportant to appreciate that planning forsustainable development is frequentlycontroversial, coming with great uncertainties.



14.6 Case studiesThis section introduces six SEA case studies (A toF), four reflecting practice in spatial or land-useplanning and two in transport planning. The mainpurpose of presenting the case studies here is toshow that there are different methodologicalapproaches to SEA, i.e. case studies are notnecessarily cases of good practice. This isimportant in a country like Pakistan, where SEA isonly just emerging. All case studies follow thesame structure. First the context is explained.Then the planning situation and context areelaborated on. The SEA action is explainedbefore finally an evaluation of the SEA isattempted.

14.6.1 SEA for a local land use plan of themunicipality of Ketzin, Germany (case A)This was a formal SEA conducted by themunicipality of Ketzin for a land-use plan in themid 1990s

The Context:Location, population and development prospects:Ketzin is a municipality located in the state ofBrandenburg, Germany, about 40 km west of thecity centre of Berlin. It has a population of 6,400,

covering 93 km2. A stagnant population andeconomy is expected for the foreseeable future.

Political system: Germany is a federal anddemocratic country with written constitutions atFederal and state levels. There are democraticallyelected bodies at four levels, including Federal(national), state, county/municipal and local levels.

Spatial or Land-use planning system and SEA:There are four main planning levels, with state andmunicipal planning levels matching those of thedemocratically elected bodies. Furthermore, inparallel to statutory spatial or land use plans,landscape plans and programmes are prepared,some of which include SEA. Table A1.1summarises spatial/land-use and landscape/SEAinstruments. There are legal requirements forpreparing state-wide landscape programmes,region-wide landscape framework plans and locallandscape plans. Generally speaking, there is nostrict planning hierarchy. Instead, the counter-current principle is applied, meaning that eachlevel needs to take the plans of other levels intoaccount. Decision-making aims at being‘administration consensus-based’.

Table A1.1: Land use and landscape planning/SEA instrumentsPlanning level Spatial/Land-use Planning Landscape Planning/SEA Scale of maps

State State Spatial Development Plan Landscape Programme 1:500,000 to (Land) (Landesentwicklungsplan/-programm) (Landschaftsprogramm) 1:200,000Region Regional Plan (regionales Raumordnungskonzept) Landscape Framework Plan 1:100,000 to

(Landschaftsrahmenplan) 1:25,000

County (Kreis) County Development Plan(informal) (Kreisentwicklungsplan)Community, City Land-use Plan (Flächennutzungsplan, §1 Federal Landscape Plan1 (Landschaftsplan) 1:50,000 to

Construction Law Book - BauGB) 1:5,000

City District e.g. city district plan (Bereichsentwicklungsplan) Around 1:3,000(informal)

Part of the Master Plan (B-Plan, §1 Federal Construction Open Space Master Plan 1:2,500 to 1:1,000Community Law Book - BauGB) (Grünordnungsplan)

Source: Fischer, 2005b1 There are about 430 landscape plans in Brandenburg


The Planning and SEA Action:The land use plan to be assessed: Statutory localland use plans were prepared for the fiveadministrative areas of the municipality of Ketzin.Their overall goal was to create the basis for apositive future economic, social andenvironmental development.

The SEA: A SEA was prepared between 1995 and1996 in parallel to the local land use plans,formulating environmental developmentobjectives and assessing the potentialenvironmental impacts of land use changes, asbrought forward by the land use plans.

The actors involved: The planning authority Ketzinwas responsible for both, the preparation of thelocal land use plan and the SEA. Documentationwas prepared by private consultants. Whereasland use plans are approved by the State Buildingand Construction Authority, the SEAs areconfirmed by the State Environment Agency.There is some extensive consultation in land useplan making and SEA with both, statutory andnon-statutory bodies, including investors andother stakeholders. Furthermore, there waspublic participation within the formal land useplan making processes, during which the SEAwas open to the general public for comment.

The SEA process: All main ‘conventional’ SEAstages were covered, either directly, or as in thecase of monitoring and public participationthrough the land use plan making process.General environmental monitoring is done by theLower Environmental Protection Agency. The

SEA was conducted in a pro-active manner, i.e. itplayed a vital role in setting the developmentagenda for the land use plan. Table A1.2summarises those stages covered by the land useplans and SEA Ketzin.

The assessment of environmental impactsapproach: In the SEA process, varioussuggestions for future land use were assessed. Inthis context, alternative sites were compared andevaluated. Evaluation was based on existing dataand some own data collection. Generallyspeaking, site alternatives with the leastenvironmental impacts were identified based onoverlay mapping. These were later included in theland use plans. An environmental developmentconcept was designed, mainly aiming to promotemeasures in the areas of environmentalprotection, agriculture, water management andsettlements. This concept was developed basedon area sensitivities, identified through overlaymapping. Measures will partly be implementedthrough compensation for project impacts, asdetermined in project EIA, following formalrequirements of the Federal Impact InterventionRule.

The SEA report: The SEA report consists of sixsections. These include an introduction, abaseline description and evaluation (climate andair, geology and soils, water, flora and fauna,landscape and recreation), land use conflicts, adevelopment concept, further action and asummary. Figure A1.1 shows the area wideenvironmental development concept for themunicipality.

Table A1.2: Main procedural stages covered land use plan making and SEA

• = yes ⇔ = indirectly, through land use plan = no

Screening Scoping Prediction Report Review Monitoring Consultation Public /evaluation preparation participation

Land use Plan • • • • • • •

Landscape Plan • • • • • ⇔ • ⇔



Evaluation of the SEAOverall evaluation of the SEA: The SEA for theland use plan Ketzin can be considered asuccessful case. Generally speaking, it was wellreceived by all participating authorities oragencies and by those involved in the process.The land-use plans cannot be approved withoutcompletion and confirmation of the SEA. TheSEA had a considerable positive impact on theland use plan. It was able to set the context foravoiding harmful environmental impacts and itidentified environmental objectives and adevelopment concept that will be the basis forfuture action.

Crucial factors for success: Factors that werecrucial for overall success include in particular a

good facilitator (i.e. consultant), the widespreadconsultations done with various stakeholders, theexistence of formal plan making and SEAprocedures and the checks and support by thestate agencies. Problems and shortcomings: The SEA itself is agood practice case. However, there are aspectsof the overall context in which SEA is happeningthat could be improved. First of all, one SEA wasprepared for five land use plans combined,making co-ordination of activities a lot morecomplicated. Furthermore, the planning system israther complex and simplification could lead togreater clarity. Finally, no proper assessment ofeconomic and social effects was done and, as aconsequence potential trade-offs are somewhatdifficult to establish.

Figure A1.1 Development Concept of SEA Ketzin

Source: own design, following landscape plan Ketzin

Measures for environmental protection and development (E1-10) Measures in settlement areas (S 1-14) Measures in agriculture (A1-13) Water management measures (W 1-8) Resource Development Contamination of soils; see measures C 1-5 Private gardens/ nursery Open Space Master Plan to be prepared

Landscape Plan Ketzin-

Development Concept

Scale 1:50,000

Municipality of Ketzin

N


14.6.2 Sustainability appraisal of the OldhamUnitary Development Plan – Appraisal of theReplacement Unitary Development Plan FirstDeposit Draft, England (case B)

This was a SEA conducted by the municipality ofOldham for a land-use plan review at thebeginning of the new millenium

The Context:Location: Oldham is one of the 10 metropolitanboroughs that form Greater Manchester. It issituated in the North West of England (UK).According to the 2001 census, Oldham had atotal population of 217,273.

Political system: The UK is a unitary state and ademocratic constitutional monarchy, with an un-codified and unwritten constitution. The UK hasfour constituent parts, which are also consideredas territories or nations, including England,Scotland and Wales and Northern Ireland. InEngland, at the time the SEA was prepared, therewas a two-tier government structure, consistingof county and local councils besides a one-tiergovernment structure of unitary authorities(normally metropolitan areas, including Oldham).In England, local governments are regularlyundergoing reforms.

Spatial or Land-use planning system and SEA:England’s planning system is known for itsdiscretion, allowing for a high degree of flexibility.This administrative discretion is mainlyconcentrated in central and local governmentbodies. The main purpose of this discretion is toachieve a balance between public and privateinterests, within the framework of planningpolicies. Another feature of the UK planningsystem is the strong role of the localgovernments. England has a SEA system thattakes the form of sustainability appraisal (SA),which tests the consistency and performance ofplans and their objectives against sustainabilityobjectives.

The Planning and SEA Action:The land use plan to be assessed: The UDP (localland use plan) sets out the policies that thecouncil needs to follow when considering

applications from prospective developers inOldham Metropolitan Borough over the next tenyears. It sets out a process of developmentcontrol, aiming at balancing different types ofdevelopment and aims at ensuring that theplanning decisions that are made in a rational andconsistent manner.

The SEA/SA: The SEA/SA was done for aReplacement UDP. In this context, theconsistency and performance of the plan and itsobjectives against sustainability objectives weretested. SA ran in parallel with the formulation ofpolicies, i.e. it was an integrated exercise and notan add-on process.

The actors involved: The objectives of the UDPwere defined by Oldham Partnership . TheSEA/SA team was composed by: the OldhamBorough Environment Forum, the Planningcommittee, a “critical friend” (a consultantaccompanying the process), GONW , OldhamChamber, Oldham Groundwork, EnvironmentAgency, and Oldham Metropolitan BoroughCouncil (MBC). The SEA/SA team was split intotwo groups: the sustainability appraisal groupwhose purpose was to carry out a detailedappraisal at each stage of plan preparation; andthe sustainability appraisal sounding board,constituted primarily of elected members, with theaim of providing a greater degree of thoroughnessand an ongoing political input. According togovernment regulations, the UDP review processmust be subjected to public participation atregular intervals throughout the process.However, the way the public can influence itscontents varies from stage to stage. Unresolvedobjections are considered in a public inquiry.

The SEA/SA process: The UDP was the keystrategy for providing a suitable framework forsustainable development at the local level. Allpolicies and proposals had to be tested againstkey sustainability objectives, based on the NW’sstrategy for sustainable development “Action forSustainability (AfS)” (See: Table 1.1). The SAprocess consisted of 9 steps. These are listed inTable B1.2.



The assessment of environmental impactsapproach: A discussion based approach wastaken, with the sustainability appraisal teamdiscussing proposed policies in terms of theirsustainability impacts. In this context, matriceswere used to support the appraisal. Theseshowed impacts of proposed policies onsustainability objectives, based on qualitativejudgements by the members of the group.

The SEA report: In August 2001, Oldham BoroughCouncil published a report on the sustainabilityappraisal of the first deposit draft replacementUDP. The UDP plan review had been an ongoingprocess, in 2003 it had reached the reviseddeposit stage, in which the objections submittedduring the first deposit stage, had beenconsidered by the Council and where appropriate,changes had been made to the draft plan. At thisstage the changes are placed for “deposit” forpublic comment. A report on the appraisal of therevised deposit –changes to the draft plan– hadbeen published in October 2003.

Evaluation of the SEAOverall evaluation of the SEA: The SEA/SAbrought many changes to the UDP. It acted as alearning process for those involved, contributingto changing views of individuals andorganisations. The SEA/SA was considered agood practice case in North West England.

Crucial factors for success: Factors that werecrucial for overall success include in particular,the widespread participation and consultationfrom various stakeholders to the process;furthermore, information was made accessible tothe general public.

Problems and shortcomings: Some essential SEAstages and elements were missing in the process,including formal reporting of findings for all of thekey stages of the process; the development ofoptions and a comparative appraisal of thoseoptions – prior choices being made – as well asthe appraisal of the option selected; andmitigation measures. Furthermore, the reportdescribed the process of how the assessmentwas done, rather than providing information onthe results, the alternatives and impactsconsidered.

14.6.3 SEA for new development areas forRotterdam and Leiden, The Netherlands (case C)This was a formal SEA conducted by the DutchMinistry for Spatial and Environmental Planningfor new housing and business development areasin regions surrounding the municipalities ofRotterdam and Leiden in the mid-1990s;development areas proposed by thosemunicipalities were in conflict with national spatialand environmental policy, as they touchedprotected sites

Step 1 Screening, using the regional Action for Sustainability as a starting point for the appraisal

Step 2 Appraisal of the Issues Paper (document that sets out topic by topic, the current policy approach, the drivers for policy change and key issues) against the AfS

Step 3 Development of local sustainability objectives, indicators and targets

Step 4 Appraisal of site selection criteria

Step 5 Appraisal of the first draft policies

Step 6 Appraisal of second draft policies

Step 7 Appraisal on the future use of difficult sites

Step 8 Consultation strategy

Step 9 Future appraisal stages

Table B1.1: Main procedural steps covered in the SA of the UDP’s replacement plan


The Context:Location, population and development prospects:Rotterdam and Leiden are part of the Randstad ,the main metropolitan region of the Netherlands.Rotterdam has a population of about 600,000 andLeiden of about 115,000. Between 2005 and2010, Leiden was predicted to need 4,000 newhomes and some 20 ha for economic activities,Rotterdam needs some 225 ha for economicdevelopment.

Political system: The Netherlands is a democraticcountry with a written constitution. There aredemocratically elected bodies at four levels,including national, provincial, municipal and local.

Spatial/Land use planning system and SEA: Thereare three main planning levels, with national andmunicipal levels matching those of thedemocratically elected bodies. In addition, there isa regional level that may cover a whole provinceor only parts of it. At each of these three levels,formal spatial/land use plans are prepared. Thereis no strict planning hierarchy. While plans of ahigher hierarchical level set the context for thoseof a lower hierarchical level, municipalitiestraditionally have had some rather strongautonomy in decision-making. SEA has beenapplied for major development ideas and planssince 1986, based on the requirements of theproject EIA Act.

The Planning and SEA Action:The plan to be assessed: Leiden wanted to focusdevelopment activities in the ‘Grote Polder’ area,which is part of the Green Heart, a type ofprotected green belt between Amsterdam, TheHague, Rotterdam and Utrecht. Rotterdamwanted to focus on industrial development in the‘Hoeksche Waard’ area, which is currently aprotected ‘open area’. Suggestions were not inline with development policy formulated in theVINEX Dutch National Spatial Plan.

The SEA: A formal SEA was prepared, as part of astatutory ‘core plan decision’ process for nationalspatial policy. The decision to conduct a SEAwas the outcome of considerations on whethernational spatial policy should be changed in orderto accommodate the proposed developments. It

was decided to not only consider environmental,but also economic and social aspects. Variousalternative development areas were selected asthe basis for evaluation, including those preferredby the municipalities of Rotterdam and Leiden.The preparatory administrative ‘core plandecision’ process lasted for than more two and ahalf years from mid-1995 until the end of 1997,before the plan and the SEA were submitted toparliament for approval. The SEA took intoaccount national transport policy (based on theSecond Transport Structure Plan), ‘green spaces’policy (based on the Green Spaces StructurePlan), military areas (based on the Structure PlanMilitary Areas), the economically driven note‘Space for Regions’ and the Development Plan forthe main Dutch international airport Schiphol,which lies adjacent to the Leiden region.

The actors involved: The SEA process wasconducted by the national Ministry for Spatial andEnvironmental Development (VROM). Variousnational ministries, the two affected provinces(North and South Holland), the city regions ofRotterdam, The Hague and Amsterdam and theAssociation of communities in the Leiden regionwere part of the main working group. Institutionalsupport was provided by the national EIACommission, the Commissioner for EnvironmentalHygiene and the Spatial Planning Advice Council.The process included public participation andwas concluded by a national parliament decision.

The SEA process: All main ‘conventional’ SEAstages were covered, according to national EIAregulations, including screening, scoping, reportpreparation, review, consultations and publicparticipation. Monitoring was done indirectlythrough national spatial and environmentalmonitoring.

The assessment of environmental impactsapproach: In the SEA process, various alternativesuggestions for development areas wereassessed. Evaluation was based on existing data.Most and least favourable developmentalternatives were identified in terms of fiveaspects: liveability (local environmental quality),environment, sustainability (global environmentaleffects,i.e.CO2), economy and development



costs. Sub-elements to these aspects wereevaluated. Visualisation of the impacts wasachieved through an impact matrix identifying‘good’ (+), ‘mediocre’ (0) and ‘bad’ (-) scores. Inaddition, flexibility in terms of opportunities forfurther future development was verballydiscussed. Based on the results of the SEA,preferred development alternatives wereformulated from the view of the national

government. Whereas in the Leiden case, the‘Grote Polder’ area was not confirmed as apreferred alternative, in the Rotterdam case, the‘Hoeksche Waard’ was supported. Figure C1.1shows the development alternatives for theLeiden region as an example. Table C1.2 showsmost and least favourable alternatives for the fiveevaluation aspects.

Figure C1.1 Development alternatives

Source: own design, following SEA for the Leiden and Rotterdam regions

Leiden’s preferred alternative

Study area

Alternative

1

2

3 4

5

6

7

8

Leiden

The Hague

‘ Green Heart’ (protected)

North Sea

Schiphol Airport

Table C1.1 Final results for different alternatives

Most favourable Least favourable

Liveability 5 3

Environment 2, 7 8

Sustainability 1 8

Economy 2, 8 1, 3

Costs 3 5


The SEA report: The SEA report consists of twomain parts. Part A presents the overallassessment results in four chapters, including anintroduction, an explanation of the background tothe assessment and a comparison of alternativesfor the two regions. Part B provides for somebackground information, with a generalexplanation of scoring, the presentation of thebaseline for the two regions and a summary ofknowledge and data gaps. Furthermore, part Bincludes an annex, listing workgroup participants,sources, terminology used and a glossary.

Evaluation of the SEAOverall evaluation of the SEA: Overall, the SEAcan be considered a good practice case. Soundmethods and techniques were applied in aformalised process that was conducted in arigorous manner. However, the case alsoprovides an interesting example in terms of long-term acceptance of planning decisions. Manyyears later in 2004, an internet search by theauthor found that the municipality of Leiden wasstill attempting to push forward their preferreddevelopment alternative, despite the significantenvironmental impacts, based on the perceivedeconomic benefits.

Crucial factors for success: Factors that werecrucial for overall success undoubtedly includethe existence of a formalised and participatoryEIA based process. The supporting role of theEIA Commission was of particular importance andthe involvement of all major stakeholders. Problems and shortcomings: The SEA itself is agood practice case. However, as mentionedabove, it also provides for an interesting insightinto what may happen if a planning decision is notin line with the interests of main economicstakeholders. Political lobbying for Leiden’spreferred development alternative (i.e. GrotePolder) was still ongoing many years later,seemingly unperturbed by the planning/SEAdecision made earlier.

14.6.4 SEA for Municipality of Weiz Urban Planrevision on future use of 27 areas, Austria(case D)

This was a pilot SEA conducted at the beginningof the new millennium and sponsored by theFederal Ministry of Environment, Youth and Familyfor the Municipality of Weiz for its Urban Planrevision regarding future use of 27 areas. A mainobjective of the exercise was to test the feasibilityof the SEA Directive in existing plan making

The Context:Location, population and development prospects:The Municipality of Weiz is a district capital in theFederal Province of Styria with about 9,200inhabitants, covering 507 hectares.Political system: Austria is democratic federalcountry with a written constitution. There aredemocratically elected bodies at four levels,including national, provincial, municipal/countyand local.

Spatial/Land use planning system and SEA: Thereare four main planning levels, including national,provincial, which has the main responsibility forspatial planning, district and municipal levels. Ahierarchical land use planning principle is in place,i.e. land use planning works in a top-downmanner of decision-making.

The Planning and SEA Action:The plan to be assessed: The Municipality of Weizidentified 27 areas with present or potential claimsfor new or re-development. In order to supporteffective and efficient decisions on their best use,a decision was made to revise the existing UrbanPlan and to conduct a voluntary SEA. Themunicipality of Weiz was responsible for thepreparation of both, Urban Plan revision and SEA,with the latter being sponsored by the FederalMinistry of Environment, Youth and Family(FMEYF). The time horizon of the plan was fiveyears (2000-2005).



Area no. x (from 1 to 27)Alternatives Information provided Old urban plan no action intentions best

of municipality environmentaloption

Environmental criteria

Socio-economic criteria

weighting Recommendations,mitigation measures andcomments

The SEA: A SEA process was conducted that wasin line with the 1996 draft of the European SEADirective. Problems with the implementation ofDirective requirements were to be identified.Furthermore, the development of a suitable SEAmethod and an effective communication strategywere key objectives of the exercise.

The actors involved: The SEA process wasconducted by the City Council of the Municipalityof Weiz. The Styrian provincial governmentapproved both, plan and SEA. Furthermore, theStyrian Environment Ministry was included in thescoping exercise. There was public participationin both, plan making and SEA. An interdisciplinaryteam, consisting of air, noise, climate, natureprotection and spatial planning experts waspresent at a total of three SEA scoping meetings.

The SEA process: Main ‘conventional’ SEA stageswere covered, including screening, scoping,report preparation, review, consultations andpublic participation. Only monitoring was notconsidered, yet, in this pilot SEA. A scopingdocument was prepared, based on the draftrevision plan. There was a high degree ofintegration of plan making and SEA processes.Public participation of plan and SEA wereintegrated and conducted according to therequirements of the Austrian Spatial Planning Act.Information on plan revision and SEA to the publicwas mainly done through the ‘City Gazette’, a

local newspaper that was distributed to everyhousehold free of charge. A non-technicalsummary of the SEA was distributed to thegeneral public in this way.

The assessment of environmental impactsapproach: Each of the 27 development areaswere assessed individually. In this context, threealternative development options were considered.Besides a ‘no-action alternative’, an ‘intentions ofthe municipality of Weiz’ alternative and a ‘mostenvironmentally friendly alternative’ wereconsidered. Furthermore, for reference purposes,the land use allocated by the existing urban planwas also included. Environmental and socio-economic criteria were used to evaluate differentuses in each of the 27 development areas.Environmental criteria included soils, fauna andflora, water, air, landscape and climate. Socio-economic criteria included economic performanceand development, settlement areas, technical andsocial infrastructures and the population.Evaluation was done, based on a scoring systemfrom 1 (very positive effect) to 5 (very negativeeffect). If no data were available, a question markwas allocated. If criteria were not relevant in acertain situation, this was also marked. TableD2.1 shows how the alternatives were comparedin terms of the evaluation criteria within an impactmatrix. Furthermore, Figure D2.2 shows thedevelopment areas within the Urban Plan revision.

Table D1.1 Impact matrix SEA Urban Plan Revision Weiz


Figure D1.1 Development areas that were assessed

Source: own design, following SEA

Development areas

Municipality of Weiz

M 1:10000

The SEA report: The SEA report consists of eightchapters. An introduction describes aim, methodand approach. An outline of the plan revision, adescription of the environmental baseline, aimsand objectives and potential significant effectsfollows, before alternatives are explained, reasonsfor rejecting certain alternatives are given andmitigation and compensation measures areintroduced. Finally, problems and data gaps areidentified and a non-technical summary isprovided. Appendices include the scopingdocument and a glossary.

Evaluation of the SEAOverall evaluation of the SEA: Overall, the SEAcan be considered a good practice case. Theprocess was positively perceived and had apositive impact on a more environmentallysustainable revised Urban Plan. However, not all

SEA recommendations were included in the plan,due to investor interests and political pressures,i.e. in certain instances the final decision did notreflect the best possible environmental option.

Crucial factors for success: Factors that werecrucial for overall success particularly include thecross-fertilisation of experts from different subjectareas. In a participatory plan making approach,the SEA was perceived as not having delayed theplan making process, raising its acceptanceamong those involved. Effective communicationand co-ordination processes were considered tobe of particular importance in achieving aneffective SEA process.

Problems and shortcomings: While the SEA itselfis positively perceived, there were also a fewproblems and shortcomings. Most importantly,the SEA started much later than the initial informal



Figure E1.1 Corridor region in broader context

Source: own design, following SEA of Gothenburg-Jönköbing Transport Corridor

Stockholm

Göteborg

Existing railway

Existing Road

New Road

New railway

Southern Sweden

Study Area

Lake

Approx. 100 kms

Jönköbing

meeting on the plan revision. Furthermore, only afew persons from the general public activelyparticipated in the plan making / SEA process,despite the wide distribution of relevantinformation.

14.6.5 SEA for the Gothenburg – JönköpingTransport Corridor, Sweden (case E)This was a pilot SEA conducted in the second halfof the 1990s.by the Swedish National RoadAdministration for a transport corridor betweenthe two cities of Gothenburg and Jönköping,which are located at a distance of 95 km. In thestudy several multi-modal transport options wereassessed.

The Context:Location, transport situation and prospects:Gothenburg is Sweden’s second largest city withabout 500,000 inhabitants. Jönköping is a

medium-sized town with about 90,000inhabitants. The corridor SEA was triggered by aperceived need to make traffic on the mainexisting national road connection, No 40, saferwith fewer accident related deaths and injuries.Currently, there is no direct rail link between thetwo cities and a rail journey means taking the busfor parts of the trip. Only very limited populationand economic development is expected in thecorridor, particularly in the rural areas. Linkingtogether the urban areas in the corridor was partof the vision of the National Board of HousingBuilding and Planning for Sweden. Figure E1.1shows the corridor region considered in the SEAin its broader context.

Political system: Sweden is a democratic countrywith a written constitution. There aredemocratically elected bodies at three levels,including national, regional and local.


Transport planning system and SEA: There wasan extensive national road and rail network,administered for the government by national roadand rail administrations. National TransportPlanning is organised in a tiered manner, with anational transportation policy, summarised in onepolicy document, setting the context for regionalinfrastructure plans and action programmes.

The Planning and SEA Action:The plan to be assessed: There is no plan assuch. The Chamber of Commerce for WesternSweden had previously studied economicimpacts of six main transport corridors ondevelopment potentials in the region. Thecorridor considered in the SEA was found to offerthe greatest development potential.Subsequently, county boards stressed theimportance of improving the existing railconnection, particularly for environmentalreasons.

The SEA: A pilot SEA was conducted, aiming atdeveloping suitable methods for transportcorridor-SEAs. The corridor was about 95 kmlong and 40-55 km wide. An objectives-ledapproach was followed, with the formulation ofenvironmental objectives for the corridor, basedon existing national and regional environmentalgoals standing at the beginning of the process.Seven alternative combinations of road and rail,plus a zero alternative were assessed. The extentto which each of the alternatives was able tocontribute to environmental objectives wasidentified. The SEA report was prepared in1997/8 and the time horizon of assessment was2010.

The actors involved: The SEA was conducted onbehalf of the Swedish National RoadAdministration. Most of the technical studieswere done by consultancies. Views on the SEAstudy were obtained from national and regionalauthorities and from nature conservation bodies.

The SEA process: The main aim was to produce aSEA report to be used later in project specificplanning and as a basis for transport relatedpolitical decision-making. Traffic modelling wasthe basis for the assessment. Stages includedscoping, where environmental goals were

identified and adapted for the specific situation ofthe corridor, considering the opinions of variousexperts. This was followed by an impactassessment of the various alternatives,considering impact minimisation and mitigationmeasures. Conclusions were drawn within theSEA report and recommendations given for laterpolitical and project related decision-making.

The assessment of environmental impactsapproach: The assessment aimed at establishingthe extent to which the seven combinations ofroad and rail and the zero alternative werecompatible with environmental goals, taking intoaccount impact minimisation and mitigation.Existing data were largely used in assessment.Environmental goals considered in the SEAincluded climate, over-fertilisation andacidification with a focus on regional scaleimpacts of harmful emissions. They also includedthe conservation of natural resources, use of fossilfuels, agricultural land, ground and surface waterresources, the natural and cultural environmenti.e., formally protected area, other valuable areasand ancient remains, ecological infrastructure andthe landscape with a particular focus on culturaland historical aspects, recreation and outdooractivities and living conditions and health (viabletown centres, public communications, residentialseverance, air quality, noise, visual environmentand road safety). In addition, the socio-economicdevelopment of the corridor region was taken intoaccount. Main methods and techniquesemployed included the use of theme specificsensitivity maps, forecasting based on computermodelling and an impact matrix, showing theimpact of the various alternatives on theenvironmental goals, with a scoring system basedon nine main scales, ranging from very largepositive contribution to extremely large negativecontribution (+++, ++, +, (+), 0, (-), -, --, ---). Inaddition, combinations of scores were used.

The SEA report: The SEA report consists oftwenty chapters plus references and appendices.These include background information, aims,baseline data description, a detailed portrayal ofkey issues, alternatives studied, minimisation andmitigation measures, road safety effects, a cost-benefit analysis and conclusions. Furthermore, asummary of the results is provided. The report



concludes that the two alternatives that includethe development of railway infrastructure withsome minimal upgrading of National Road 40 arethe preferred transport solutions in the corridor. Itwas noted that road and rail alternatives did notappear to have influenced each other very much.The report stresses the fact that rail transportmodelling currently has major shortcomings.

Evaluation of the SEAOverall evaluation of the SEA: Various pilottransport corridor-SEA studies were conducted inthe context of methods’ development of thetrans-European transport networks. In thiscontext, the SEA described here is one of the bestknown examples and can be considered a goodpractice case. The SEA report came up with aclear recommendation, while at the same timebeing open about problems and gaps inknowledge. However, while the SEA reportprovided a basis for discussion on suitablemethods, the report was not subsequently usedas a basis for decision-making, as the overallcorridor development strategy had subsequentlychanged.

Crucial factors for success: Factors for successparticularly include a very experienced person incharge of the project in the Swedish NationalRoad Administration. Furthermore, the expertiseprovided by the involved consultants and theinputs by external experts were crucial.

Problems and shortcomings: The main problem isthat the case is a pilot study that was notintegrated into any formal planning process.While it aimed at providing recommendations fordecision makers in later decisions, this did notmaterialise, due to a changed development vision

in the region. Furthermore, while some expertswere consulted, there was no wider participation.Finally, the scoring system appeared somewhattoo detailed and complicated.

14.6.6 SEA of the bridge over the MessinaStrait, Italy (case F)This was a ‘big-project’ SEA for the plannedbridge between Sicily and mainland Italy,conducted in the first decade of the newmillennium.

The Context:Location: The Messina strait is a stretch of sea,separating the island of Sicily from mainland Italy.The narrowest part of the strait is about 3 kmwide, connecting the cities of Messina (in Sicily)and Reggio Calabria (in Calabria). There iscurrently a ferry service for people, cars and rail.

Political system: Italy is a parliamentarydemocracy with a written constitution. At apolitical-administrative level, Italy is subdividedinto twenty regions, five of which have a specialautonomous statute; provinces, some of whichare still being instituted; and local governments.

Transport planning system and SEA: There arefour main levels of decision-making, matching theadministrative governments, i.e. national, regional,provincial and local. Due to devolution, majorresponsibilities – including planning andenvironmental assessments – have beendelegated to the regions. Transport decisions aremade at the national, regional and provincial level.Multi-modal transport decisions are made at thenational level (see Table F1.1.). Multi-modalprojects tend to follow an accelerated design andEIA process because of their national value.

Planning level Transport planning instrument

European Union Transport European Network Plan

National Programme of the Strategic “Productive” Infrastructures and Settlements; National Transport Plan

Regional Regional Transport Plan

Provincial Provincial Transport Plan

Table F1.1: Transport planning tiers for the Bridge over the Messina Strait


Legal system: A legislative decree declared theroad and railway link between Sicily and themainland a project of national interest. Therefore,it could follow an accelerated planning process.Table F1.2 shows the relevant regulatoryframework for this case.

The Project and SEA Action:The project to be assessed: The Bridge issupposed to complete one of the main Europeannorth-south axes; at the national level, it closes aninfrastructure gap; at the sub-national level thebridge aims to improve the situation of theunderdeveloped Southern Italy.

The SEA: The SEA was set in a sustainabledevelopment context, aiming to achieve anintegrated approach according to regionaldevelopment objectives. The SEA assessedenvironmental impacts; transport efficiency;economic efficiency, urban and regional benefitsof the project.

The actors involved: Stretto di Messina (SdM) isthe concessionaire company, responsible for thedesign, construction, operation and managementof the connection between Sicily and themainland. It is governed by public law. Thecompany needs to assign all activities related tothe construction and management, to a generalcontractor, by public tender. The environmentalassessment was prepared by a temporary groupof societies. The Ministry of the Environment andTerritorial Protection (METP) were also involved.Various companies acted as advisors and therewas a Technical Scientific Committee instituted atthe Ministry of Infrastructure and Transport.Various responsible ministries, Italian Rail and

SdM signed a Framework agreement inNovember 2003. The SEA process: The SEA was integrated withenergy balance assessments to comparealternative scenarios and hypotheses. It included(a) a transport analysis and economic feasibilitystudy, (b) a multi-criteria analysis to compare twoalternatives, (c) mitigation and compensationmeasures and (d) EMAS certification, to monitorthe impacts of the proposed project and bettercontrol the expected impacts during theconstruction and operating phases. The SEA wasconducted in a reactive manner to an existingdesign. The SEA was applied to comply withexisting and, at the time, forthcoming legislationsi.e. the SEA Directive. The process started in1992 and was updated in 2002 to comply withnew regulations, and in 2003 a SpecialCommission of the MEPT granted “environmentalcompatibility” to the project. In January 2005,tender notice for project management waspublished.

The assessment of environmental impactsapproach: Two alternatives were compared, theMessina Strait Bridge and an upgraded ferrysolution. Current demand and supply of transportfrom and to Sicily were considered, includingmaritime services, traffic flows, passengernumbers, vehicles, goods, trains and freight.Various hypotheses were considered withinmacro-economic scenarios in order to decide oneconomic and financial feasibility. The hypothesisset for the cost/benefit analysis was based on theGDP growth for Southern Italy (high and low) andon transport growth (favourable and non-favourable). Table F1.3 summarises the fourscenarios considered.

Law 443/01 "Legge Obiettivo", Regulations on Infrastructure and Public Works facilitating GovernmentLaw 190/02 and Law 166/02 plans on infrastructure

Strategic Infrastructure 2001 The Strait of Messina Bridge is part of the Government Programme for"Fast Tracking" Strategic Infrastructures

Law 1158/71 Stretto di Messina S.p.A. is the concessionaire to study, design, buildand operate the bridge

Table F1.2: Relevant regulatory framework for the bridge over the Messina Strait



The SEA report: The SEA report consists ofsections on the legislative framework, the existingplanning framework (all regional plans andprogrammes, sectoral plans as well asenvironmental and archaeological aspects); theproject design framework and the environmentalframework (water, vegetation, flora, fauna andecosystems; atmosphere; noise and vibrations;ionisation and non-ionisation radiations; publichealth; and landscape). Figure F1.1 shows theproject.

According to the SEA findings, from anenvironmental, transport and economic point of

view, the permanent bridge connection wasadvertised as the best option. The cost/benefitanalysis proved the economic feasibility of theproject even in the worst scenario (scenario 4)and benefits exceeded costs in all scenarios.

Evaluation of the SEAOverall evaluation of the SEA: The environmentalassessment was politically driven. The followingaspects were not given due consideration:l Geo-seismic-tectonic problems: the area has

the highest risk for significant earthquakes;

l The bridge will destroy a unique landscape

Scenario 1 Scenario 2

High Growth High growth

Favourable transport Unfavourable transport

Scenario 3 Scenario 4

Low growth Low growth

Favourable transport Unfavourable transport

Table F1.3: Four scenarios for the Bridge over the Messina Strait

Figure F1.1 Messina Strait Bridge

Source: own design, following the bridge over the Messina Strait project

SICILY

CALABRIA

Messina

Reggio Roads - railways openRoads in gallery Railways in gallery


and precious ecosystems, the opportunity toimprove the local economy based on thoseresources will be lost. The bridge will toucheleven sites of European Communityimportance;

l Migration of sensitive species, noise and lightpollution;

l Impact on aquifer layers;

l Traffic growth is overestimated; there‘s a gapbetween project costs and estimatedincomes;

l The finances for the project (4,732 M Euro)could be used to improve the region’sinfrastructure; and

l The bridge is not connected to the railwaysystem in Calabria.

Crucial factors for success: The SEA cannot beconsidered a success, as it did not suggest a go-ahead with the most environmentally friendlyoption.

Problems and shortcomings: The relevantregulatory framework made the bridge over theMessina Strait project “untouchable” because ofits national, strategic importance.

14.7 Practical elementStudents to write a summary document on howSEA differs from EIA.



This chapter is divided into five sections. First policy level SEA is introduced.Next, evidence for the effectiveness of SEA at the policy level is presented.Then specific challenges with applying SEA at policy levels of decision-making are discussed before a policy SEA case study is introduced onrenewable energy policy in Scotland. Finally, different planning processes inPakistan are explained with regard to a possible integration of SEA. The mainsources this chapter draws on include Au et al.(2008), Sadler and Canter(1997) and World Bank Sustainable Development Network EnvironmentDepartment (2010).

15.1 Introduce policy level SEAPolicy SEA is frequently distinguished from plan and programme SEA. This isbecause the policy-making processes usually follow different methodologicalpaths from plans and programmes. Following Sadler (2005, p.2), policies areunderstood to include the following:l “Legislation, including draft bills, regulations, rules and agreements;l Government strategies, papers, memoranda or statements of intent that

outline new policies or proposed directions or options at the highest level;and

l Norms, guides, principles or arrangements that are understood or actedupon as if they were policy or law”.

The same author suggested that a policy can be expressed as a strategic aimor a broad vision which proposes a direction of development and/or legislativeor fiscal commitments and that set the context for courses of action thatgovernments intend to pursue. Being on top of the decision-makinghierarchy, policies usually set objectives that serve as overall frameworks forlower tiers, i.e. for plans and programmes.

Policies can take many different forms. They may be very general or ratherdetailed. They may also be sector-specific, formal or informal,transformational or incremental in character (Bregha et al., 1990). From theperspective of SEA, major policy reforms or legislative proposals that areenvironmentally significant are of particular interest. Policies with potentiallywide-ranging interest also include government expenditure priorities orprocurement strategies. Sadler (2005) defined types of policy and legal

15. SEA application at the policy leveland in Pakistani planning processes

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proposals that are potentially subject to SEA.These are shown in Box 15.1.

The US National Environmental Policy Act (NEPA)distinguishes between different tiers of actionssubjected to SEA, policies, plans andprogrammes, and EIA projects. Article 3 of theEuropean SEA Directive 2001/42/EC and Article 4of the SEA Protocol to the Espoo Convention onTrans-boundary EIA defined plans andprogrammes only to be subjected to SEA.However, the Protocol also includes a non-binding commitment to cover policy or legislation(Article 13), without defining those further.

In the UK, the term ‘policy’ is said to comprise“the Government’s strategic objectives in aparticular area and framework for decidingprogrammes and projects” (DETR 1998).

The Aarhus Convention on Information onEnvironmental Matters, Public Participation andAccess to Justice on Environmental Issues alsoapplies to policies (Article 7), making reference inthis context to laws and rules (Article 8). Aftermany years of negotiations for the EC SEADirective, policies were not included, mainly

because they were seen as being ‘too’ political.Furthermore, institutional, procedural andmethodological problems were seen to be too big(Sadler, 2005).

It is crucially important to apply SEA at policies,as it is here where potential impacts can best beprevented. Policies are the ultimate source ofimpacts at decision-making levels further downthe line, i.e. at the levels of plans, programmesand projects. If applied early-on, majoralternatives should still be open. In this context,it is of interest to note Dovers’ (2002) distinctionbetween ‘deep’ and ‘shallow’ SEA. He portrays‘deep SEA’ as the one that deals with the rootcauses of unsustainable development. Thisincludes e.g. policies dealing with patterns ofproduction and consumption, mobility orsettlements. ‘Shallow SEAs’, on the other hand,are more reactive, focusing on the immediateimpacts on the environment. Dovers (2002)noted that ‘deep SEA’ is more complex andchallenging than ‘shallow SEA’ but the latter,when systematically applied to governmentpolicies, can still significantly advance thesustainability agenda”.


Box 15.1: Types of policy and legal proposals potentially subject to SEA

l Government proposals and consultative documents that outline new policy directions (e.g. draft nationalstrategies);

l Bills, draft regulations or proposed rules (e.g. relating to private or common property rights);

l International agreements and treaties that a government is negotiating or proposes to enter into (e.g. tradeagreements);

l Budget, financial appropriation and expenditure priorities;

l Government or departmental purchasing and procurement policies or strategies;

l Government or Ministerial statements of intent that are commonly accepted or can be reasonablyinterpreted to be policy;

l Policies that are contained in or govern plans or programmes, including objectives, directives, guidelines,etc.; and

l Standing policies or arrangements that promote or are permissive with regard to development activitieswith potential cumulative effects (e.g. land clearance, habitat alteration, wetland loss).

Source: Sadler (2005, p.4); adapted from Buckley (2000), Sadler (1994)

15.2 Evidence for the effectivenessof SEA at the policy levelIn 2010, the World Bank published a report onthe application of policy-SEA. In this, they drewsome lessons on its effectiveness, based on theevaluation of various case studies. Theselessons can be summarised as follows (WorldBank, 2010): l Policy SEA can, under conducive conditions,

contribute to an improved formulation andimplementation of sector reform, stemmingfrom an ability to raise attention to priorityenvironmental and social issues affectingstakeholders;

l Ownership, capacity and trust are necessaryconditions for effective environmentalmainstreaming at the policy level, includinggovernments, civil society organisations andlocal communities;

l There is a need for long-term constituency-building, as policy SEA is but a small andbounded intervention in the continuousprocess flow of policy-making; and

l Contextual factors are of overridingimportance in hindering or facilitating theattainment of the main benefits of policy SEA.

The report then also provides a key message,namely the need to clearly articulate the potentialbenefits of policy SEA.

“Developers of policy SEA mustrecognise that incumbent actors havecertain interests when engaging in SEAactivities. Their participation will bedriven by the benefits from engagingbeing greater than the risks and costs.First and foremost, policy SEA must beunderstood as a strategic decisionsupport process that will enablegovernments to put in motion betterpolicy-making, and not merely as anenvironmental safeguard. Speakingdirectly to the development priorities ofthe country, policy SEA not only workstowards improving policy-making from anenvironmental mainstreaming perspective,

but also supports better planning andpolicy-making from an overarchingdevelopment point of view. As analysis ofthe potential economic and growthimpact of sector reform is undertaken inthe “sector review”, policy SEA couldcomplement this analysis by exploring theeconomic and growth implications ofenvironmental and social priorities” (WorldBank, 2010, p.88).

15.3 Present the specific challengeswith applying SEA at policy levels ofdecision-making; the need to considerdifferent policy situationsA particular challenge is to accommodate SEAwithin the different modes of policy-making(Sadler and Verheem 1996). This has to start withdeveloping an understanding of how policy-making processes work (Nitz and Brown 2001).In this context, suggestions have been made thatimportant insights can be gained from thetheories of the policy and decision sciences.These can help when designing or strengtheningSEA activities (Kørnøv and Thissen 2000).Experiences gained to date with the applicationof SEA at the policy level confirm that it isimportant to adapt it to the ‘political culture’ ofnorms, rules and relationships that shape nationalpolicy-making.

Factors to be considered when designing policySEA include the style of policy-making, e.g. openor closed, the mechanisms used to monitor andenforce accountability and the opportunities forpublic and stakeholder involvement (O’Riordanand Sewell 1981). Constitutional conventions,including cabinet confidentiality or parliamentarysovereignty are important when deciding on whatis feasible or practical with regards to policy SEAarrangements.

Sadler (2005, pp.7-8) introduced other aspectsand issues that need to be taken into accountwhen attempting to conduct SEA at the policylevel. These include:



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1) Communicating the benefits Even if SEA of policy has gained politicalacceptance, its application may be resisted orcircumvented because it intrudes on territory andprerogatives that traditionally have been off limitsto outside scrutiny. Many in government stilldoubt that SEA can add real value to policyformation or fear that it will metamorphose intoEIA ‘with all its procedural bells and whistles’.While often overdrawn, these concerns need tobe addressed if the SEA process is to workeffectively. How to ‘sell SEA’ has been aperennial theme of discussion among theconverted, e.g. at IAIA annual meetings. A muchbetter job needs to be done of communicatingthe contribution that this process can make topolicymakers (Verheem and Tonk 2000).

2) Dealing with variability Policy-making is a highly variable, often non-uniform process that calls for a range ofadjustments to SEA procedure. For simplicity,two main approaches to policy formulation maybe contrasted. A structured process followsidentifiable steps that lend themselves to someform of SEA application, for example, theformalised procedures for legislation and thecentralised policy apparatus of many ex-socialistcountries. By contrast, unstructured policydevelopment is fluid, issue-driven and reactive toevents as they unfold, and likely to be accessedbest through the application of simple, rapidappraisal tools that provide immediate insights.Other policy-making processes may combinefeatures of both approaches, for examplebeginning as unstructured and moving towardgreater formality in the final stages whendocumenting options and consequences (Rentonand Bailey 2000).

3) Focussing on realities Often policy-making may be not so much theexercise of a specific choice as the creation ofwhat O’Riordan (1976) called a ‘decisionenvironment’ through which proposals andoptions are formulated and filtered. In suchcircumstances, policy and institutional ‘mapping’

can help SEA practitioners to gain a firmer graspof the context and nature of policy-making andthe agencies and stakeholders involved (See:Dalal-Clayton and Bass 2002). This analysis canindicate areas and junctures at which SEA cancontribute and add value to government policy-making. A parallel review of environmental lawand policy can help to identify the key objectivesand policies that should provide the referents foridentification and evaluation of effects in SEA.

4) Addressing key issues and links Policy initiatives in certain sectors, such asenergy, transport and trade, are known to havepotential environmental effects or consequences.At this level, cause-effect relationships aremodulated by a range of intervening factors andoften expressed as implications or issues ratherthan impacts. In many cases, the environmentaleffects of policy will be long-term, transmittedthrough the subsequent preparation of plans orprogrammes or other processes. These includethe ‘knock on’ effects of policies onenvironmental objectives across other sectors,which are little discussed in the SEA literaturecompared to vertical integration or ‘tiering’.Further attention should be given to the horizontaldimensions or boundary conditions for SEA.

5) Capitalising on opportunities All reforms of the policy-making process providean opportunity to introduce or strengthen SEA.Such changes have taken place recently or areunderway in a number of countries andinternational organisations [...]. For example, therecent UK initiative on modernising governmentand World Bank environment strategy wereinstrumental in introducing new forms of SEA [...].In some cases, the implementation of measuresmay involve long lead times as exemplified by theintroduction of the first crop of SEA-equivalentpolicy statements under the New ZealandResource Management Act (1991) [...]. Lookingahead, international trends and developmentsindicate there will be a number of opportunitiesfor the further development of SEA at the policylevel [...].


6) Learning by doing This will be particularly important in capitalisingon opportunities or introducing new systems [...].More generally, the ‘variable geometry’ of policy-making underscores the need for a flexible, trialand error, learn and adapt approach to SEA(Sadler and Verheem, 1996). So far, the means todo so are largely missing. Even though SEApractice at the policy level is increasing anddiversifying, there is relatively little systematicmonitoring and follow up including ex-postreviews of process effectiveness andperformance (Partidario and Fischer 2004, Sadler,2004). Much can be learnt in the first instancefrom an understanding of current SEA systemsand their implementation.” (Sadler, 2005, pp.7-8)

15.4 Case study: Renewable energypolicy in ScotlandThis section introduces a policy SEA case study,namely the SEA of two Supplementary PlanningGuidance (SPG) documents on RenewableEnergy for Fife Council (a local authority in theEast of Scotland, UK) for (1) wind energy, and (2)renewable energy technologies other than windenergy. This was originally published as Fischer TB and Phylip Jones J., (2008). StrategicEnvironmental Assessment of the FifeSupplementary Planning Guidance for RenewableEnergies (pp. 141-149); in: SEA – materials forChina’s ‘International Conference on StrategicEnvironmental Assessment (SEA)’, SEPA.http://content.undp.org/go/cms-service/download/asset/?asset_id=2083586.

Subsequently, first an introduction to the planningsystem and to SEA in Scotland is provided. Thenthe case study is described. Finally, anevaluation of the case study is presented.

15.4.1 Introduction to the Scottish planningsystemThe planning system in Scotland is establishedby statute, principally in the Town and CountryPlanning (Scotland) Act 1997). Scotland is one ofthe four constituent parts of the United Kingdom(besides England, Wales and Northern Ireland).The Scottish Executive considers planning to

have a key role in achieving policy objectives.This is particularly evidenced by the fact thatplanning is the responsibility of the Social JusticeMinister.

One area that causes particular problems forScottish planning and the Scottish Executive, isthe diversity of needs within Scotland. Thus,pressures in the sparsely populated areas of thecountry are very different from the central beltaround Glasgow and Edinburgh, where the casestudy is located.

Until 1996, Scotland had a “two-tier” system oflocal government with regional and districtcouncils. Then, the regions were responsible forstrategic policy by the preparation of structureplans, while district councils were responsible formore project oriented local plans anddevelopment control issues. Now, there is aunitary system in place, with local authoritieshaving a wide range of responsibilities and arange of tasks to fulfil. They are, for example,obliged to prepare both, structure plans and localplans, i.e. development plans. Together, theseplans contain policies for the future developmentand use of land in an area. In addition, districtcouncils also prepare the policy orientedsupplementary planning guidance for specificplanning aspects. Plans and guidance can covera wide range of issues such as housing,transport, employment, shopping, recreation andconserving and protecting the countryside.

15.4.2 SEA in ScotlandThe Environmental Assessment (Scotland) Act2005 (EAA 2005) came into force on February20th, 2006. The Act repealed the EnvironmentalAssessment of Plans and Programmes (Scotland)Regulations 2004 (EAPP, 2004), which was inforce prior to the Act. As opposed to most otherEU member states, Scottish legislation not onlyaims at plans and programmes, but also atstrategies, i.e. policies – including planningguidance. Guidance on the form and content ofthe Environmental Report is set out in SEA Toolkitpublished by the Scottish Executive in



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September, 2006. The Scottish Executive is alsoproducing an annual SEA report which outlinesthe progress made with SEA. Table 15.1indicates the plans, programmes and strategiesthat have been subject to SEA in 2005 and 2006.

As indicated in Table 15.1 ‘Town and Countryplanning and land use’ plans, at 53%, made upthe largest proportion of plans, programmes andstrategies entering the SEA process in 2006,followed by ‘Transport’ at 17%. Together, thesesectors accounted for over 70% of SEA activity in2006. Telecommunications was the only sector inwhich no SEAs were submitted in 2006. Forenergy, the subject of this section, only 5% ofSEAs (i.e. six in total) were undertaken.

15.4.3 Energy planning and SEA in Scotland -the context The Scottish Executive has set some ambitiousrenewable energy targets for Scotland. Thus, by2020, 40% of the country’s electricity supplyshould be from renewable energy sources.Attaining this target is thought to be possiblethanks in part to the wealth of natural resourceswhich Scotland possesses, including wind, bothonshore and offshore, wave and tidal energypotential.

15.4.4 Introduction to the case study Fife is a council area of Scotland, situatedbetween the Firth of Tay and the Firth of Forth.Fife is a peninsula in eastern Scotlandbordered on the north by the Firth of Tay, on


Sector Number of PPS Number of PPS Total number of Percentagecarried over from started in 2006 PPS in 2006

2005

Agriculture 0 3 3 2.5%

Forestry 1 2 3 1%

Fisheries 1 0 1 1%

Energy 1 5 6 5%

Industry 0 3 3 2.5%

Transport 3 18 21 17%

Waste management 1 2 3 2.5%

Water management 0 1 1 1%

Telecommunications - - - -

Tourism 0 1 1 1%

Town and country

planning and land use 13 51 64 53%

Miscellaneous 0 14 14 12%

TOTAL 20 100 120 100

Source: Scottish Executive (2007)

Table 15.1: Plans, programmes and strategies (policies) entering into the SEA process

the east by the North Sea and the Forth of Firthto the south. Fife is Scotland’s thirteenthlargest local authority area with a residentpopulation of just over 350,000 (see Map 15.1).Almost a third of the population live in the threeprinciple towns of Dunfermline, Kirkcaldy andGlenrothes.

Two SPGs were prepared and subjected to SEA.One was an SPG on wind energy (wind farms,both onshore and offshore) and the other was anSPG for renewable energy technologies otherthan wind.

The SEA conducted was based on a rigorousframework for assessing the nature of the impactand likely time scale of any impact consistentwith the requirements of the legislation. Thevarious policy elements were assessed againstevaluation criteria specified in Schedule 2 (6.a-e)of the SEA Regulations (See: Box 15.2).

The aim of the SEA was to demonstrate that thevarious policy elements for renewable energy

uptake in the Fife area contribute positively tosecuring a sustainable energy supply.

The SEA was conducted as follows:(1) Screening: SPGs in Scotland formally require

SEA (according to EAA 2005, EAPP 2004);(2) Scoping: a scoping document was submitted

to the Scottish Executive on 31.01.2007, and (3) formally commented on by three statutory

consultees (consultation): ScottishEnvironmental Protection Agency (SEPA),Scottish Natural Heritage (SNH) and HistoricScotland (HS);

(4) an environmental (SEA) report was prepared,which was subject to

(5) public consultation (8 weeks; March 26th –May 21st,2007);Furthermore, in the future, compliance withthe terms and conditions of the SPG/SEA willneed to be

(6) monitored.

This is happening based on the incorporation ofthe SPGs into the area’s local planning (2007-2010).

The main aim of the SEA was to ensure that noadverse environmental impacts would arise when



Map 15.1: The fife area

Source: Scottish Executive (2007)

Box 15.2: List of evaluation Criteriaaccording to the Scottish SEA Regulations1. Biodiversity/Flora/Fauna; 2. Population;3. Risk to Human Health;4. Soil;5. Water;6. Air;7. Climatic Factors;8. Material Assets;9. Cultural Heritage (Including archaeological and

architectural);10. Landscape;11. Secondary, cumulative and/or synergistic effects

of criteria 1-10; and,12. Natura 2000 sites

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the Supplementary Planning Guidance isimplemented in conjunction with otherDevelopment Plan proposals. Furthermore, SEAfor the SPG on Wind Energy aimed at identifyingsuitable sites for wind farms.

Finally, SEA for the SPG on Renewable EnergyTechnologies other than wind aimed at providingadvice to potential developers on the range oftechnologies which could be developed in Fife,including:1. hydro power;2. heat pumps (air/water);3. geothermal;4. combustion plants (biomass-based);5. shoreline and offshore technologies (wave

and tidal power); and 6. solar technologies (heat and photovoltaic).

Fife Council used a simple matrix method forevaluating the significance of impacts that eachof the policy elements of the SPGs may have onthe environment. This matrix method and scoringmechanism are demonstrated below in Figure15.1. Furthermore, Box 15.3 shows the list ofassessment criteria.

Finally, Figure 15.2 shows how the scoring wasdone, using a qualitative approach of justifying eachscore assigned to an individual policy element.

The potential impact of each policy element (i.e.wind farm sites for the SPG on wind energy andthe six renewable energy technologies for theother SPG) on each of the factors listed in Box 1was considered and a score was allocated. Themethod provided scope to indicate situations


Assessment Criteria (See Box 15.2)

Evaluation 1 2 3 4 5 6 7 8 9 10 11 12criteria Policy Element

SS1: +/-- +/-- + +/-- +/-- -- -- + +/-- +/-- +/-- --Settlement LT LT LT LT LT LT LT LT Strategy

Figure 15.1: Framework for Assessment

BOX 15.3: Symbols for assessment matrix

+ Significant positive environmental effects

- Significant negative environmental effects

-- No significant environmental effects

? Don’t know

+/-- In the positive spectrum if any effect

-/-- In the negative spectrum if any effect

+/-/-- Range of possible scores

LT Long Term

MT Medium Term

ST Short Term

P Permanent

T Temporary

where it may not be possible to predict effects,i.e. taking into account uncertainty. Not onlysignificant negative effects were identified, butalso those that were deemed positive. Whereappropriate, the duration of effects wasconsidered with the option to value it as long-term, medium-term or short-term. In addition, itwas indicated whether effects would betemporary or permanent. The assessment wason the basis that any later development planproposals would need to be in line with what wasset out in the SPG.

15.4.5 Strategic Environmental AssessmentResults – Main Findings The main aim of the SEA was to ensure that anyrenewable energy developments consistent with

the Supplementary Planning Guidance shouldnot have an adverse impact on the environment.Figure 15.3 shows the assessment results for thevarious policy elements. It can be seen thatnone of the policy elements have a significantnegative effect on 1 (biodiversity, flora, fauna), 8(material assets), 9 (cultural heritage), 10(landscape) and 12 (Natura 2000 sites).Furthermore, all policy elements score positiveon 7 (climatic factors).

While it was found that the main significantnegative environmental effects of the SPG policyelements related to soil disturbance and soilremoval for placing the foundations of the windfarms, overall, no major significant negativeeffects were identified. Rather, positive effects



Policy element of SPG Criteria

1 2 3 4 5 6 7 8 9 10 11 12SG1 : Wind Farms (also policy elementR1: Wind Turbines) -- +/-- + -/-- -/-- + + -- -- -- +/-- --

LT LT LT/T

SG2 : Shoreline Technologies and Landfall Installations -- -- -- -/-- -/-- + + -- -- -- -- --

LT/T

SG3 : Renewable Energy – All Technologies -- -- -- -/-- -- -- + -- -- -- -- --

LT/T

SG4 : Renewable Energy Technologies -- -- -- -/-- -- -- + -- -- -- -- --

LT/T

SG5 : Combined Heat and Power Plant -- -- -- -- -- -- + -- -- -- -- --

PSG1 : Offshore Activities -- -- -- -- -- -- + -- -- -- -- --

Figure 15.3: SEA of SPG policy elements – Summary

Component of Plan Impact Duration JustificationBiodiversity/Flora/Fauna

Policy element SS1: +/-- Policy element requires that allocation of land forSettlement Strategy LT new development must avoid damage to natural

environment features. Long term over life of Plan.

Figure 15.2: Speciment Policy/Proposal Scoring

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were predicted as a result of SPG implementationon the local population in terms of job creation,reducing greenhouse gas emissions andimproving local air quality. Therefore, overall, theSEA found that the SPGs should be leading toimprovements to environmental quality. This isnot to say that the SEA is not, therefore, requiredfor such SPGs in the future as the SEA processdid flag up some very important environmentalissues which will need to be mitigated againstwhen the SPGs are implemented and integratedinto the Fife Local Plan.

Figure 15.4 summarises the justifications givenwithin the assessment of the SPG policyelements, taking the evaluation criterion ‘soil’ asan example.

The main concerns that the statutory consulteeshad, related to the fact that the scoping process,and, thus, the SEA process in general, startedlate into the preparation of the draft SPGs. Both,SEPA and HS picked up on this point and statedthat:


Policy element Impact Duration JustificationSoil

SG1: Wind Farms -/-- Development of turbines would have small effect on soils(also Policy element R1: LT T as area required per turbine and associated works isWind Turbines) limited. Sites probably restored after use. Long-term use

but temporary.

SG2: Shoreline -/-- Development of shoreline technologies and landfallTechnologies and LT T installations likely to have limited impact on soil which Landfall Installations can be addressed through conditional planning

permission. Policy seeks to prevent shoreline technologies and landfall installations causing coastal erosion and any associated loss of soil. Long-term use but temporary.

SG3: Renewable Energy -/-- Development of renewable technologies would have – All Technologies LT T small effect on soils as area required for most

technologies and associated works is limited. Sites probably restored after use. Long-term use but temporary.

Policy element SG4: -/-- Development of renewable technologies would haveRenewable Energy LT T small effect on soils as area required for most Technologies technologies and associated works is limited. Sites

probably restored after use. Long-term use but temporary.

Policy element SG5 : -- Policy promotes more efficient use of energy which wouldCombined Heat and reduce greenhouse gas emissions with associated Power Plant environmental benefits from a reduction in waste

combustion materials.

Policy elements PSG1: Not applicable Not applicableOffshore activities

Figure 15.4: Justifications of scores given for the evaluation criteria soil

“It is noted that the draft Supplementary PlanningGuidance on “Wind Energy” and on “RenewableEnergy Technologies other than Wind Energy” arein an advanced stage of preparation while theSEA is still at the early stage of scoping. Pleasenote that the purpose of the SEA is to informdecision-making as the plan is prepared as wellas before its adoption and that SEA should beundertaken during the plan preparation and notafter substantial decisions about the plandirection and content have already been taken”(SEPA, 2006).

It was suggested that the scoping report shouldhave included more information on the types ofrenewable energy technologies covered i.e. notjust wind. Furthermore, it was felt that moredetailed baseline environmental data should havebeen produced than those that were availableand which were rather limited. It was alsoproposed that the scoping report should haveasked for the SEA to assess the evolution of thelocal environment in the absence of anyrenewable energy development, i.e. the ‘no-action alternative’ should have been included.

Furthermore, it was also suggested that thebaseline data on existing “brownfield sites” couldhave been linked to the percentage of renewableenergy facilities located on brownfield land. Asthe SPGs set out policy elements and advice forplanning for renewable energy developments inFife’s coastal waters, it would have beenappropriate to include baseline data on the Fifemarine environment and consider potentialimpacts on the marine environment, marineinfrastructure and particular areas of importancefor fisheries or recreation and tourism.

Finally, the consultees stressed that “EconomicDevelopment” should not be a SEA topic and isnot relevant to the environmental assessment. Itwas stated that the consultees supported thematrix based approach. However, it would havealso been helpful to demonstrate how the SPGswill be monitored to ensure that any wind energydevelopments conform to the SPGs policies and

that any mitigation is effective. The latter wasseen by the consultees as an integral andimportant part of the SEA process.

15.4.6 Evaluation The SEA was conducted for a policy level activity,focusing on evaluating the policy elements setout within the two SPG documents prepared byFife Council. The policy elements within the SPGwere scrutinised and impact significancevaluations were assigned to each policy area in aqualitative manner. It was found that the policyelements advocated in the SPGs would have nosignificant adverse long-term effects on the localor regional environment. Furthermore, it wasfound that there would be long-term positiveimpacts in the reduction of carbon dioxideemissions in the area.

The matrix method adopted was simple buteffective in the evaluation of significance.Following the consultees’ responses on the SEAscoping document, the final environmentalstatement was greatly improved, taking intoconsideration the ‘no-action alternative’, i.e. theevolution of Fife without a renewable energypolicy. The SEA was considered very useful inoutlining the main areas of concern with regard tothe uptake of renewables in the Fife area and thesubsequent integration of the SPG into the localarea plan will ensure that the local plan is moresensitive to the needs of environmentalprotection, while balancing the global need forincreased renewable energy uptake in light of theglobal warming dilemma the world faces.

15.4.7 Success factors, problems,shortcomings and outlook and conclusions Producing an initial scoping report which threestatutory consultees had a chance to commenton served to greatly improve the overall SEAquality. Without the scoping stage and thecomments by the consultees, the quality of theSEA process would have diminished. Theconsultees identified some highly relevant points,most importantly that the scoping stage mayhave been carried out too late in relation to thepreparation of the draft SPG, stating that the



190

purpose of SEA was to work in tandem with thepolicy (guidance) making process in order to pro-actively influence its content. Also, the scopingstage ensured that additional and crucial baselinedata was collected and inserted into theenvironmental statement.

Consultees stated that Fife Council had handledthe input of the consultees very well and includedall of the additional information that wasrequested. Overall, the SEA process mostdefinitely ensured that the SPG became moreenvironmentally sensitive and the process ofintegrating the SPGs into the local plan will nowbe undertaken in Fife between 2007 and 2010.The only criticism of the SEA procedure was thatit started too late in relation to the initialpreparation of the draft SPGs, which may havepotentially reduced the level of influence that theSEA exerted on the final SPG version.Nevertheless, this study illustrated that policylevel SEA for renewable energy policies andstrategies is beneficial and results in moreenvironmentally considerate guidance.

15.5 Planning system and processesin PakistanPlanning, in the broadest sense, is usuallyconsidered to be a process for assessing thenature and extent of present as well as futureeconomic, social and spatial needs, resulting in adecision on how to cater to those needs withinavailable resources and timeframe. Its outcomemay take the form of a policy, programme, planor at times specific projects. Essentially, “a planis a package of economic and social policiesexpressed with quantified targets and objectivesto be achieved during a laid-down period”(PC/GoP, 2010, p.2). Planning in Pakistan stemsfrom the identification of development needs andallocation of economic resources. Other formsand manifestations of planning also exist in thecountry. The planning system and processes canbetter be understood by analysing institutionalset-up and nature of planning activities at variouslevels. Generally speaking, planning in Pakistanis done at three levels, including national,

provincial and district levels. Institutional set-upand planning process or activities at each ofthese levels are explained in the followingsections, depicting possibilities of the integrationof SEA.

15.5.1 Planning at National Level At the national level, the Planning Commission ismainly responsible to periodically preparenational plans or strategies and annualdevelopment programmes (ADP) for theeconomic and social development of the country.It is also responsible to seek approval of suchplans from the Federal Government andcoordinate its activities with the Ministries andconcerned Departments or Agencies forimplementation of the development programmes.It prepares a Public Sector Development Program(PSDP) for providing financial resources forvarious projects to facilitate economicdevelopment and reduce poverty. The FederalMinistries and Divisions prepare programmes andprojects relevant to their respective areas ofresponsibility. These are approved by theDepartmental Working Party (DWP) up to certainfinancial limit. The programmes and projectsexceeding certain financial limits are thensubmitted to the Planning Commission forapproval by the Central Development WorkingParty (CDWP). The schemes costing Rs. 100million and above are submitted to the ExecutiveCommittee of the National Economic Council(ECNEC) for final approval (PC/GoP, 2010).

The Planning Commission has so far preparednine five-year plans from 1955 to 2003. The ninthplan was halted due to a change of governmentand the draft 10th five year plan has not beenapproved. While recognising the need forsustainable development in the country, theseplans are mainly comprised of policies andtargets for economic development as well assectoral policies and programmes regardingphysical planning, housing and infrastructureprovision, etc. The Environment Section of thePlanning Commission of Pakistan has beenassigned the task of ensuring consideration of


environmental aspects in the policies, plans,programmes and EIA of projects. However, dueto its limited resources, this section has not so farbeen able to provide an effective support forstrategic environmental assessment (SEA) ofpolicies.

A few years ago, the Planning Commissionprepared a Medium-Term Development Framework(MTDF) 2005-10. This suggested that the

“integration of social and environmentalconsiderations into developmentprocesses of crosscutting sectors ofeconomy, in a holistic manner, is essentialto achieve positive environmentaloutcomes. Strategic EnvironmentalAssessment in development planningprocess is, therefore, a pre-requisite forintegration of environment at policy,planning and programme level of differentsectors” (PC/GoP, 2005, s.11.1).

For the purpose of integrated rural and urbandevelopment, the MTDF envisaged to preparingNational Spatial Development Strategy, ProvincialSpatial Plans, District Structure Plans and TehsilMaster Plans (PC/GoP, 2005). It is worthmentioning that the National Environmental Policy2005, prepared by the then Ministry ofEnvironment, Government of Pakistan,particularly emphasised the need for promotingSEA as a tool to integrating the environment intodecision-making (MoE/GoP, 2005). The morerecently prepared ‘Pakistan: Framework forEconomic Growth’, 2011 recognisesenvironmental issues “as an essential elementcontributing to the quality of life” (PC/GoP, 2011,p.43). It suggests “climate proof economicgrowth from the impacts of climate change, inparticular on the agricultural, water and energysectors” while promoting ‘green growth’ byattracting investment in low-carbon technologies(PC/GoP, 2011, p.143) .

Policies or programmes pertaining to drinkingwater and energy (power generation) sectorshave been identified by some experts as

opportunities of possible integration of SEA athigher levels of planning decision-making duringthe first phase of institutionalising SEA in thecountry (NIAP/IUCN, 2011; Khan and Ahmad,2011). The following National level policies orprogrammes may be considered for integration ofSEA: l Pakistan: Framework for Economic Growth

2011;l National Flood Reconstruction Plan 2010;l National Sanitation Policy 2006;l Clean Drinking Water for All Programme

2006; andl National Transport Policy (Draft).

15.5.2 Planning Provincial Level The Planning and Development Department (Pand DD) is the principal planning organisation atthe Provincial level. Its functions include theformulation of Provincial Government visions,policies and strategies for economic planning anddevelopment, preparation of an AnnualDevelopment Programme (ADP) or Medium-TermDevelopment Framework (MTDF), Public SectorDevelopment Programmes (PSDP), includingshort-term and long-term provincial developmentplans. Other than the P and DD, departments ofProvincial Ministries also formulate sectoraldevelopment policies or plans in the light of theFederal Government Policies. These policies orplans are scrutinised by the ProvincialDevelopment Working Party (PDWP) andapproved up to certain financial limit. Projectsexceeding the financial limit of the PDWP aresubmitted to the CDWP for approval.

The Provincial P and DD is responsible formonitoring the implementation of policies, plansand projects in coordination with Provincial andFederal Government departments. It is alsoentrusted with the task of capacity building of theProvincial Government departments/agencies forgood governance (P and DD/GoPb, 2013). Likethe Planning Commission, P and DDs of twoProvinces (Punjab and Khyber Pakhtunkhwa -KP) have also got separate EnvironmentSections, while other P and DDs have assigned



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this function to allied sections/cells, e.g. Foodand Agriculture. These sections and ProvincialEnvironment Departments are responsible topromote environmental considerations indevelopment projects. But in many cases publicsector development projects obtain financialapproval prior to EIA. The EIA of such projects isnormally carried out as a result of frequentreminders from the Provincial EnvironmentalProtection Agencies (EPAs) once the constructionwork starts (Nadeem and Hameed, 2008).

The MTDF 2012-15 and Development Programme2012-13 of Punjab envision “promotion andattainment of sustainable development in theprovince through integration of economicdevelopment and environmental consideration”(Pand DD/GoPb, 2013). Its urban developmentstrategic intervention includes the provision ofwater supply schemes, rehabilitation andaugmentation of trunk and secondary seweragesystems and provision of wastewater treatmentplants in three big cities. The regional planningstrategy allocates funds for mini dams, water andinfrastructure projects as well as povertyalleviation through economic development (PandDD/GoPb, 2013). Thus, socio-economicdevelopment is given due consideration, but howthe socio-economic development can beachieved in an environment friendly mannerneeds more attention, for example, through SEA.

The Punjab Power Generation Policy, 2006(revised in 2009) prepared by its EnergyDepartment reiterates that all the relevantprovisions of the PEPA 1997 and EIArequirements shall be followed but it does notsuggest a need for SEA (GoPb, 2006). TheDisaster Risk Management Plan 2008 of theSindh Province indicates the deterioratedenvironmental conditions and assigns theresponsibility of implementing the requirements ofthe PEPA 1997 and the NEQS, but it does not sayanything about SEA (PDMA/GoS, 2008). Oncethe legal and institutional mechanism for SEA isin place, some of the provincial policies, assuggested below, may possibly be revised to

undergo a formal SEA. l Punjab Power Generation Policy 2006;l Disaster Risk Management Plan Sindh

Province 2008;l Khyber Pakhtunkhwa Hydel Policy 2006; and l Provincial Disaster Risk Management Plan for

Balochistan (Draft).

Nevertheless, it is worth mentioning that theEnvironmental Protection Agency of the AzadGovernment of the State of Jammu and Kashmirhas initiated SEA for the A.J. and K HydroDevelopment Plan, under the National ImpactAssessment Program (NIAP), at Muzaffarabad. Inthis regard, the AJK-EPA has also organisedcapacity building and training workshops (AJK-EPA, 2013). Once completed, review of this SEAexperience would provide lessons for the futurecourse of action.

15.5.3 Planning at District Level The Provincial Local Government and CommunityDevelopment/Rural Development Department isthe third tier of government to act asadministrative/umbrella department for theplanning and development management of urbanand rural areas at the District level. For thispurpose, various rules or regulations are preparedby the department. It is also responsible forcoordinating activities with other provincialgovernment departments and allied agencies.

During the year 2001, a Provincial LocalGovernment Ordinance (PLGO) was promulgatedin every province as part of the devolution plan ofthe then military regime. Under this Ordinance,the rural and urban local councils had beenmerged to form City District Governments(CDGs)/District Governments (DGs) andTehsil/Town Municipal Administrations (TMAs).Every province has a few CDGs and several DGsand TMAs. For example, the Punjab province hadbeen divided into 34 districts having CDGs in itsfive big cities and the DGs in the rest of thedistricts. Every CDG consisted of several TownMunicipal Administrations and every DGconsisted of Tehsil Municipal Administrations.


Development Authorities also exist in the bigcities, working as part of CDGs. Similarly, otherprovinces had been divided into this District leveladministrative hierarchy commensurate with theirnumber of big cities and districts and tehsils, etc.

Due to a lack of trust in the devolution plan of thepast military regime and the changing politicalinterests/environment within the country, thePLGO 2001 has been replaced by a new LocalGovernment Acts in all four Provinces of thecountry. In the province of Sindh, the PLGO 2001was initially repealed in July 2011, while thePLGO 1979 was restored. The Sindh Local Govt.Ordinance 2012 was promulgated. Karachi,being the largest city of Pakistan, has got fiveDistricts now working under the KarachiMetropolitan Corporation. The city has also got abuilding control authority. In KP, the PLGO 2001has been replaced by the KP Local GovernmentAct 2012 and the CDG/TMAs have been renamedas Metropolitan Corporation (MCL)/MunicipalCommittees (MC). The rural areas have beengiven under the control of Zila Councils (ZC). InBalochistan, the same set up was restoredthrough the Balochistan Local Government Act,2010. More recently, the Punjab LocalGovernment Act 2013 has been approved. Thecity of Lahore will soon have a MetropolitanCorporation and a Distrcit Council/ZC in place ofCDG. Other big cities shall have MunicipalCorporations; whist intermediate cities wouldhave Muncipal Committees, to manage urbanareas and District/ZCs for rural areas.

Whatever the administrative set up, eachCDG/TMA/MCL/MC is responsible to executeprovincial government rules/regulations for landuse classification, reclassification, housing andother issues. These are also responsible for theprovision of infrastructure services, including, butnot limited to, water supply, sanitation, solidwaste management, maintenance of parks,construction of roads and streets and others.Master plans are required to be prepared for thearea under each municipal administration toguide the future growth of cities as well as the

provision, operation and maintenance ofinfrastructure services. Big cities have also gottraffic engineering and transportation planningagencies and transportation plans for theirrespective jurisdictions.

Preparation of the Master Plan for Greater Lahoremarked the beginning of master planning inPakistan in 1961. However, it was only approvedduring the year 1972 due to some political andadministrative constraints. The second MasterPlan was prepared for Karachi during 1970 to1974. Subsequently, a number of master planswere produced for various cities of the countryincluding, for instance, Quetta, Peshawar,Rawalpindi, Faisalabad and Multan. Some ofthese were named Structure Plans. Most ofthese plans were prepared with foreignassistance. Besides, a large number of, whatmay be termed mini master plans, had also beenprepared under the name of Outline DevelopmentPlan (ODP) using local technical and financialresources. Such plans are approved by therespective local council or development authority.

All the land uses viz. residential, commercial,industrial, public buildings, etc. in a town or cityand now even in suburban areas are supposed tobe developed in the light of the proposalscontained in the respective master plan of thatcity. Furthermore, the building regulations areformulated in line with the master plan. Butunfortunately, all of the above mentioned planswere prepared without considering cumulativeenvironmental impacts of development proposalsfor various land uses in cities. Consequently,adverse impacts on natural resources and humanhealth are on the rise and the environment incities is deteriorating (World Bank 2006; Hameedand Nadeem, 2007). This situation calls for aformal strategic environmental assessmentsystem with necessary legal and institutionalframework at district/local level as well. Thus, thefollowing Metropolitan/City level strategic/masterplans may possibly be revised and subjected toSEA: l Karachi Strategic Development Plan 2020;



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l Integrated Master Plan for Lahore-2021;l Integrated Strategic Development Plan for

Lahore Region 2035 (ToR); l Quetta Master Plan 2011-2032; andl Muzaffarabad Master Plan 2007.

15.5.4. Integrating SEA with policy formulationin PakistanThe following course of action is proposed tointegrate SEA with policy formulation and higherlevel planning and development decision-makingprocesses in the country:

1. Legal Framework: The foremost requirementis to introduce an amendment in the PEPA1997 and Provincial Environmental ProtectionActs, making SEA of policies, plans andprogrammes a mandatory requirement. In thelight of such an amendment, SEA regulationsand guidelines would need to be developedin consultation with all the stakeholders,including representatives from the PlanningCommission, Federal and ProvincialMinistries and attached departments oragencies engaged in formulating policeswhich may have adverse cumulativeeconomic, social and environmental impacts,for example, water and power, oil and gas,communication and works, industries andmineral development. These should alsoinclude the representatives from the LocalGovernment or District Government andUrban Development Authorities. This shouldbe followed by amendment in the Rules ofBusiness pertaining to approval of policies,plans and programmes. Relevant forms (e.g.PC-II) for allocation of funds for surveys andfeasibility studies should also have SEArequirements added during the hiring ofconsultants for this purpose. As an interimarrangement, amendments in the Rules ofBusiness and relevant forms may help kick-start the process.

2. Institutional strengthening: once the legalframework is in place, institutionalstrengthening/capacity building of the

concerned departments/agencies includingEPAs and training of concerned staff shouldbe done.

3. Draft policy and stakeholders’consultation: after formulation of draft policyin consultation with concerneddepartments/agencies, the draft policy maybe submitted to the concerned environmentalprotection agency for screening.

4. Screening: screening lists should beprepared and made part of SEA regulations.Since this is policy level screening, settingthresholds in terms of project cost andcapacity may not be possible. Screeningcriteria should, therefore, be based on thenature and extent of policy in terms of typesand nature of ecosystems and human beingsto be affected. While screening the policy,concerned EPA should decide the level ofSEA, whether ‘shallow or deep SEA’ (section15.1).

5. Scoping: consultants should be hired toundertake the scoping and SEA of the policyin consultation with the concerneddepartments/stakeholders and the EPA.

6. Report preparation: this should necessarilyinclude but not limited to: impactidentification, assessment, mitigationmeasures and others following SEAguidelines.

7. Stakeholders’ consultation: this should bejointly organized by the proponentdepartment/agency, EPA and the consultant.Stakeholders may include officials ofconcerned departments/agencies, SEAexperts/academia, NGOs, and well educatedand or elected representatives of potentiallyaffected communities.

8. Proposed modifications: the concerneddepartment/agency should look foralternative policy options to achieve the


objectives of policy in the light of SEA andstakeholders concerns and makemodifications in the policy accordingly.

9. Approval of SEA: final SEA of the modifiedpolicy, as prepared by the consultant, may besent to the concerned EPA forverification/evaluation and grantingenvironmental approval.

10. Final approval of modified policy: afterfollowing the aforementioned steps, theconcerned/proponent department/agencyshould seek final approval of the policy bythe competent authority.

15.6 Practical element Students to reflect on the way in which policy,plans and programmes are prepared in Pakistanand how SEA may fit into existing procedures.




This chapter is divided into three sections. First, the rationale for integratingdifferent assessment aspects in assessment is explained. Secondly, potentialproblems of integration in assessment are outlined and thirdly, possiblesolutions for integrating economic, social and environmental aspects arediscussed. Finally, a real life integrated assessment system is introduced.The main sources this chapter draws on include European Commission(2009), Department of Justice (2006), HIA Gateway (2007), and Morrison-Saunders and Fischer (2006).

16.1 Rationale for integrating different aspects inassessmentRecent years have seen an intensifying debate about the most appropriateform of environmental assessment, both at project and at strategic levels.This debate has particularly revolved around two questions:(a) whether economic and social aspects should be considered at par with

environmental aspects; and(b) how impact assessment can be integrated better into decision-making.

An important rationale behind the desire to integrate different aspects is tostreamline processes and to be able to present results to decision makersthat are easy to understand and digest. Therefore, more integrated forms ofassessment have been and are being developed. There are different types ofintegrated assessment. The two most common are:(1) integrated assessments that function as reporting instruments and that

aim at presenting information on phenomena or products in an integratedmanner (see, for example, The Integrated Impact Assessment Society,http://www.tias-web.info/); and

(2) integrated ex-ante assessments that are used to assess possible impactsof proposed policies, plans, programmes or projects (see for example,sustainability assessment or appraisal, Pope et al., 2004 and integratedassessment, Kidd and Fischer, 2007).

The focus here is on (2) ex-ante assessments of policies, plans, programmesand projects. Essential features of these assessments are the bringingtogether of environmental, social, and economic considerations and the

16 Developing EIA and SEA further:Integrating different aspects andsustainability assessments

balancing of these different substantive concernsin a single appraisal exercise. Although still at arelatively formative stage in comparison toenvironmental impact assessment (EIA) andstrategic environmental assessment (SEA), therehas been growing international support forintegrated approaches to appraisal.Governmental institutions have been particularadvocates of this development. For example,both the United Nations (UNEP, 2003) and theEuropean Union (CEC, 2002) are encouraging theuse of integrated-appraisal methods within theirown activities.

Although in theory there are many positivefeatures connected with integrated appraisal ofpolicies, plans, programmes, and projects, inpractice its use also presents some significantchallenges. These relate to tensions between thetwo main driving forces behind the developmentof integrated appraisal, the promotion ofsustainable development and the promotion ofgood governance. The HIA gateway(http://www.apho.org.uk/resource/view.aspx?RID=48174) provides several arguments forintegrated impact assessments, as follows:l “There is a problem of “impact assessment

fatigue”. People are being urged to do toomany different impact assessments;

l Many of the issues covered in the differentforms of assessment are the same. There isno sense in covering them twice in differentassessments;

l People working in organisations such as localgovernments and government departmentsare very busy and need to use their time asefficiently as possible;

l Integrated Impact Assessment simplifies andreduces work for policy, programme andproject developers;

l Champions for different issues can worktogether to ensure that “their” issue isproperly considered; and

l Those cases, for which a single issue such ashealth needs more detailed consideration,can be singled out for a separate HIA or othersingle issue impact assessment.”

However, the same author also sees potentialproblems and pitfalls when attempting tointegrate. These are said to include:l “Health (or whatever is your favourite issue)

will not be properly considered or receiveadequate attention;

l There is a danger of superficial treatment ofissues and encouraging a “tick boxapproach”;

l The need to involve people representing allareas covered by an IIA could createadditional work; and

l An Integrated Impact Assessment can onlybe as good as the people who contribute toit.”

In the subsequent section, potential problems ofintegration in assessment are discussed in furtherdetail.

16.2 Potential problems ofintegration in assessmentThere are five main problems for why a cautiousapproach should be taken towards integratingdifferent aspects in assessment (Kidd andFischer, 2007). These are connected with theoverall objectives for assessment, the maindriving forces behind the move towardsintegration, availability of time and resources,potential loss in depth in assessment and‘double-dipping’ of socio-economic issues whencompared with environmental issues. These aresubsequently explained further.

The first problem is connected with the use ofobjectives in EIA (and SEA) from sustainabledevelopment strategies that, in many systems,are insufficiently defined and work within anoverall economic growth paradigm. In the UK,for example, the national sustainabledevelopment strategy (Prime Minister, CabinetOffice, 1999) aimed at four main objectives,namely:l social progress which recognises the needs

of everyone;l effective protection of the environment;l prudent use of natural resources; and



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l maintenance of high and stable levels ofeconomic growth and employment.

Here, only economic growth and employmentlevels appear sufficiently well defined. All otheraspects are open to interpretation. Furthermore,there are problems of compatibility, as it isquestionable whether an effective protection ofthe environment can be achieved in the presenceof ‘high and stable levels of economic (GDP)growth.’

The second problem is connected with the maindriving forces behind the move towardsintegration. In the UK, for example, the maindrivers of integration are the aims formulated inthe ‘White Paper on Modernising Government’(Prime Minister, Cabinet Office, 1999), revolvingaround an ‘open government’ and ‘goodgovernance’. Environmental aspects only play aminor role in this context. Therefore, generallyspeaking: ‘integrated appraisal may reflect asubtle, but perhaps significant shift in the focusfrom substantive environmental and sustainabilityconcerns to the procedural aspects of effectivegovernance’ (Kidd and Fischer, 2005). In thiscontext, Kidd and Fischer (2005) suggested thatthe loss of environmental emphasis is a productof: ‘An over-reliance on participatory andqualitative methods (that) may promote dominant

economic perspectives at the expense ofsustainability and environmental concerns andresult in inadequate appraisal processes’.

The third problem is connected with theavailability of time and resources to devote toimpact assessment. EIA practitioners have longbeen criticising that in EIA, insufficient time andeffort goes into pre-decision activities such asbaseline monitoring and other investigations andthe preparation of environmental impactstatements (EIS) (e.g. Sadler, 1996; Dalal-Claytonand Sadler, 2005). It is likely that the move tointegrated assessment processes will furtherexacerbate this. As Scrase andSheate (2002, p.283) have argued: ‘The limits oftime and resources going into any assessmentmean that there will necessarily be a loss ofdepth in consideration of the environment if socialand economic objectives and criteria areconsidered simultaneously.’

The fourth problem follows on from the loss indepth and concerns the way in which thedifferent components of sustainable developmentare integrated. The previously noted trend for EIAto expand into numerous different categoriesbeyond the biophysical environment, along withthe addition of social and economicconsiderations favoured in integrated assessment


Figure 16.1: Extent of integration of different assessment and their effectiveness

Source: Tajima and Fischer, 2013

Extent of IA instruments Integration

Output and Assessor Integration

Effe

ctive

ness

of I

nteg

ratio

n

Process Integration

(a) Independent

EqIA HIA

EqIA HIA

SA/SEA

SA/SEA

HRA TIA

HRA TIAEqIA HIA

SA/SEA

HRA TIA

(c) Captured

(b) Linked

processes runs the risk of sustainabilityassessment taking on the whole world; i.e.people may want to include any possible factor.In this context, there is a real danger that witheverything included in the impact assessmentprocess, quantity may eventually overcomequality and no aspect of the assessment is donewell. More recently this was supported byresearch findings of Tajima and Fischer (2013).They established that assessments in Englishspatial planning appear to be most effective inachieving their aims when applied in close co-operation (‘linked’), but not fully integrated(‘captured’). This is shown in Figure 16.1,resulting from seventeen spatial plan makingexercises that had four other types of impactassessment conducted, as well, including HealthImpact Assessment (HIA), Equality ImpactAssessment (EqIA), Habitats RegulationsAssessment (HRA) and Transport ImpactAssessment (TIA).

The fifth and final problem concerns thepresentation of sustainability elements todecision-makers regarding the possibility thatsocio-economic factors are presented orconsidered more than once during the process,i.e. a kind of ‘double-dipping’, but that the samedoes not apply for environmental elements. Theenvironmental assessment of plans is supposedto occur in conjunction with normal planningprocedures which are based on socio-economicassumptions. In land use planning, for example,most developments considered will relate tosocio-economic benefits and the land use planmaking process already seeks to trade-offbetween environmental, social and economicfactors to find the optimum land use. EIA andSEA come into this process as advocacyinstruments that are supposed to support theweakest aspect in this trade-off process, namelythe bio-physical environment. Therefore, if SEAprocesses are expanded to include social andeconomic factors, then double-dipping of thesefactors will occur and the environment will bedisadvantaged (See: Kidd and Fischer, 2005;Fischer, 2005). In this context, criticism has been

expressed, for example, in Australia at thenational level, where Dovers (2002, p.32) statedthat in the federal SEA system: ‘We have thesituation where an implicitly lower priority isattached to the discretionary environmentalconsiderations compared to the mandatoryeconomic and social considerations in SEAprovisions of the Commonwealth EnvironmentProtection and Biodiversity Conservation Act1999. That reflects a policy position at odds withsustainability principles, and most importantlyallows a ‘double trading off’ of environmental —and probably social—concerns against economicconcerns when decisions subject to SEA then areconsidered by core economic agencies andCabinet.’

16.3 Possible Solutions forIntegration of Economic, Social andEnvironmental Aspects Subsequently, a range of solutions are identifiedon how to best go ahead with integrating thedifferent substantive elements in assessment(following Morrison-Saunders and Fischer, 2006).Probably the most important approach is todevelop sustainability criteria and indicatorswhich stem from fundamental sustainabilityprinciples (George, 2001a; Gibson, 2000, 2005).Here, rather than treating environmental, socialand economic elements as individual ‘pillars’, theapproach is to start from principles which areintended to reflect the changes needed in humanarrangements and activities to move towardssustainable behaviours. The assessment processmust be based on objectives ‘by whichsustainable development can be defined’(George, 2001b). This is necessary, because asGibson (2000) notes the pillars approach tends topitch the economic pillar and the environmentalpillar as ‘foundations of warring houses’. In thiscontext, it is important that clear minimumthreshold levels are identified for economic,social and environmental criteria. Sadler (1999,p. 20) identifies different win-lose relationshipsagainst a hypothetical minimum threshold towhich trade-offs must conform for decision-making to be integrated and for development to



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be classified as sustainable and notes that:‘beyond these boundaries, one set of criteria arebeing either unduly promoted or undulydiscounted against the others’. In case any ofthese threshold levels are violated, alternativesolutions should be sought, as otherwise ‘wheretrade-offs between the economy and theenvironment are seen as legitimate in the pursuitof sustainability, sustainability assessment couldbe regarded as a means for economicrequirements to override those of the environmentor the social context’ (Fuller, 2002).

An important prerequisite for effective integrationis transparency. In this context, Sheate et al.,(2003) advocated that: ‘Trade-offs should betransparent and carried out by the decision-making process, rather than by the tool beingused’. Similarly, while advocating a sustainabilityassessment approach, George (2001a) cautionedthat: ‘When the assessment is done in aggregate,

any trade-offs between individual aspects orcomponents are hidden. Deterioration in qualityof life for some social groups may not becomeapparent, and potentially unsustainableenvironmental effects may go undetected’. Ratherthan focus on separate environmental, social andeconomic elements in an integrated SEA process,George (2001b), Gibson (2000, 2005) advocate aprocess in which sustainability criteria andprinciples are the driving consideration. The aimof assessment would thus be to seek positivegains over all such principles and over the long-term. In this context, a number of authors haveadvocated the definition of sustainability criteriaor thresholds which should not be crossed(Sadler, 1999; George, 2001b; Pope et al., 2004).

However, there are several problems inherent inthis approach. For the purposes of assessment itwould be crucial to specify in advance what thesecriteria are in order to allow proposals to be


Table 16.1: Trade-off decision rules for Sustainability Assessment (Gibson, 2000)

1 Trade-offs in (all or specified) sustainability-related matters are undesirable unless proven otherwise; inother words the burden of proof falls on the proponent of the trade-off.

2 No significant trade-offs with adverse sustainability effects are acceptable. These include:l trade-offs of permanent losses against temporary gains;l trade-offs of nearly certain losses against highly uncertain gains (precautionary principle);l significant compromises to ecological integrity;l significant increases in inequity of opportunity and influence;l significant increases in energy and material flows, except where the gains address serious deprivation

and inequity;l trade-offs where the adverse effects are uncertain and the undertaking is not designed for adaptive

response; andl trade-offs where more than one aspect of sustainability may suffer adverse effects.

2 Only undertakings that are likely to provide neutral or positive overall effects in each principle category e.g.no net efficiency losses, no net additional inequities, can be acceptable.

3 No significant adverse effects in any principle category can be justified by compensations of other kinds, orin other places, this would preclude cross-principle trade-offs such as ecological rehabilitationcompensations for introduction of significantly greater inequities.

4 No displacement of (significant, net, any) negative effects from present to future can be justified.5 No enhancement can be accepted as an acceptable trade-off against incomplete mitigation if stronger

mitigation efforts are feasible.6 Only compromises or trade-offs leading to substantial net positive long term effects acceptable.7 No compromises or trade-offs are acceptable if they entail further declines or risks of decline in officially

recognised areas of concern, set out in specified official national or other sustainability strategies, plans,etc..

Source: Gibson (2000), as summarised by Morrison-Saunders and Fischer (2006)

evaluated in accordance with them. This has notbeen undertaken to date. Secondly, theapproach implies that there are certain factorsthat should not be traded off during theassessment process and yet it is rather unlikelythat all sustainability factors can be maintained allof the time. Thus some trade-offs are likely tooccur in practice.

Gibson (2000) established some ‘trade-offdecision rules’ to guide the trade-off process(See: Table 16.1). These rules are intended tomaximise positive outcomes for all sustainabilitycategories and eliminate net losses or negativeeffects. Proponents would be required to justifytheir proposals in accordance with these rules asa means of demonstrating the sustainability oftheir activities. Subsequently, Gibson (2000)defined a number of process requirements to putsuch a SA process into effect. These include:l explicit commitment to sustainability

objectives and to application of sustainabilitybased criteria;

l mandatory justification of purpose; andl provisions for transparency and effective

public involvement throughout the process.

16.4 Real life integrated assessmentsystem The system considered here is the EuropeanCommission impact assessment (IA) of policyinitiatives(http://ec.europa.eu/governance/impact/commission_guidelines/docs/iag_2009_en.pdf. There areguidelines, summarising the process. Theseguidelines are for Commission staff preparingimpact assessments. They consist of a core textand annexes. The core text explains what IA is,presents the key actors, sets out the proceduralrules for preparing, carrying out and presentingan IA, and gives guidance on the analytical stepsto follow in the IA work. The annexes containmore detailed guidance that may also be of help.Additional guidance material to help withanalysing specific impacts has been prepared byvarious Directorates General and is available ontheir internal websites.

According to the guidelines, Impact assessmentis a set of logical steps to be followed when youprepare policy proposals. It is a process thatprepares evidence for political decision-makerson the advantages and disadvantages of possiblepolicy options by assessing their potentialimpacts. The results of this process aresummarised and presented in the IA report. Indoing an IA, the assessor will have to answer anumber of questions: l What is the nature and scale of the problem,

how is it evolving, and who is most affectedby it?

l What are the views of the stakeholdersconcerned?

l Should the European Union be involved? l If so, what objectives should it set to address

the problem? l What are the main policy options for reaching

these objectives? l What are the likely economic, social and

environmental impacts of those options? l How do the main options compare in terms

of effectiveness, efficiency and coherence insolving the problems?

l How could future monitoring and evaluationbe organised?

The IA work is a key element in the developmentof Commission proposals, and the IA report willbe taken into account when decisions are taken.It is important that the IA supports and does notreplace decision-making – the adoption of apolicy proposal is always a political decision. The key analytical steps which the assessor hasto follow when carrying out an IA are summarisedin Table 16.2.

16.5 Practical element Student to give a personal account whetherintegration is desirable or not.




1 Identifying the problem Describe the nature and extent of the problem. Identify the key players/affected populations. Establish the drivers and underlying causes. Is the problem in the Union's remit to act? Does it pass the necessity and value added test? Develop a clear baseline scenario, including, where necessary, sensitivity analysis and risk assessment.

2 Define the objectives Set objectives that correspond to the problem and its root causes. Establish objectives at a number of levels, going from general to specific/operational. Ensure that the objectives are coherent with existing EU policies and strategies, such as the Lisbon andSustainable Development Strategies, respect for Fundamental Rights as well as the Commission's mainpriorities and proposals.

3 Develop main policy options Identify policy options, where appropriate distinguishing between options for content and options fordelivery mechanisms (regulatory/non-regulatory approaches). Check the proportionality principle. Begin to narrow the range through screening for technical and other constraints, and measuring againstcriteria of effectiveness, efficiency and coherence. Draw-up a shortlist of potentially valid options for further analysis.

4 Analyse the impacts of the options Identify (direct and indirect) economic, social and environmental impacts and how they occur(causality). Identify who is affected (including those outside the EU) and in what way. Assess the impacts against the baseline in qualitative, quantitative and monetary terms. Ifquantification is not possible explain why. Identify and assess administrative burden/simplification benefits (or provide a justification if this is notdone). Consider the risks and uncertainties in the policy choices, including obstacles totransposition/compliance.

5 Compare the options Weigh-up the positive and negative impacts for each option on the basis of criteria clearly linked to theobjectives. Where feasible, display aggregated and disaggregated results. Present comparisons between options by categories of impacts or affected stakeholder. Identify, where possible and appropriate, a preferred option.

6 Outline policy monitoring and evaluation Identify core progress indicators for the key objectives of the possible intervention. Provide a broad outline of possible monitoring and evaluation arrangements.

Table 16.2: Summary of key analytical steps of the European Commission’s IA guidelines

Source: European Commission (2009)



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The authors are grateful to a range of people, including:

(1) Those taking part in seven NIAP workshops on EIA curriculum development and thosecommenting on draft versions of the curriculum, namely:

Muhammad Javed Malik,Dr Audil Rashid, Prof Dr Amir H Malik, Dr Aneel Salman, Dr Aqeel AhmedTaimoor, Dr Azeem Khalid, Dr M Zafar, Dr Muhammad Anwar Baig, Dr Noor Jehan, Dr Riffat N Malik, EngrSaima Iqbal, Bashir Khan, Mahmood Akhtar Cheema, Main Khalid Mahmood, Beenish Saba, ShahidMehmood Khan, Dr Aurangzeb Khan, Dr Muhammad Aamer Maqsood, Aqeel Victor, Dr Amin-ul-HaqKhan, Amina Zafar, Almas Hamid, Dr Farhat Abbas, Prof Dr Muhammad Faheem Malik, Dr Iftikhar Ahmad,Prof Dr Khalid Mehmood, Dr Husnain Haider, Prof Dr Nikhat Khan, Dr Muhammad Nawaz, Prof AbdulRashid Memon, Dr Badar Ghauri, Gohram Malghani, Imran Sabir, Kaneez Fatima, Dr Moazzam Ali Khan,Dr Mirza Arshad Ali Beg, Inam Ullah Khan, Sunila A. Wassey, Engr Shahid Lufti, Waqar Hussain Phulpoto,Usman Azhar, Dr Yasmeen Nargis, Zahoor Ahmad Bazai, Zabardast Khan Bangash, Abdul Manan,Ghulam Mohayuddin Marri, , Aneeza Umer, Arsalan Altaf, Arfa Zaheer Azmat, Abrar Mustafa, AbneerAnees, Ch Mazhar, Farhat Javed, Hira Waheed, Hidayat Hasan, Hammad Saeed, Imran Nabi, Jawed AliKhan, Jawairia Imtiaz, Javeria Rehman, Kanwar Javed Iqbal, Mahboob Elahi, Maqsood Ahmed, UsmanMalik, Umar Hayyat, Naseer Ahsan, Naik Bano, Naila Jabeen, Najma Rasheed, Nageena Tariq, NailaYasmin, Nasim ur Rehman, Nazia Zakir Ahmed, Nida Maqbool, Qurat ul ain Naveed, Rabia Sarfaraz,Rukhsana Tariq, Raja Javed Ali Bhatti, Rahman Qureshi, Sohail Khan, Shumail Javed Bhatti, SadafRashid, Sundus Tanveer, Khalid Shah, Sadia Shah, Sarah Amir, Saleha Irfan, Sajid Mehmood, ShehzadShigri, Dr Saleema Bashir, Sidra Abbas, Sadia Shah, Dr Tehseen Ullah Khan, Tahir Durrani, Usman Butt,Wajiha Tariq, Zia ul Islam, Jamal ud Din, Dr Zuhaib Siddiqui, Abdul Hamid Marwat, Prof Shafique urRehman, Prof Dr Rizwan Hameed, Fiza Sarwar, Rabia Zafar, Yasmin Jawed Khan, Aden Khan, IjlalHussain, Mansoor Khan, Hadia Khan, Ayesha Wasti, Sohail Islam, Azfar Hasan Ansari, Saadia Hina,Muhammad Shafiq Abbasi, Asif Sahibzada, Kaleemullah Khilji, Sana Akhtar, Samia Saif, Safia Shafiq,Umera Shamshad, Mehwish Durrani, Abida Ayub, Miriam Kugele, Ahsan Rafi Kiani, Dilawar Khan Azad,Dr Zahiruddin Khan, Asim Mahmood, Engr Kishan Chand Mukwana, Saima A Khawaja, Azheruddin Khan,Zirgham Nabi Afridi, Khadija Amir, Madiha Saba Kashif, Abid Wahab, Muhammad Husnain, FarooqHameed, Naseer Khan Kashani, Dr Sami uz Zaman, Dr Shahid Amjad, , Dr Faiza Sharif, Nadia Akbar,Siddique Irfan, Bilal Ali Quresh, Dr Sofia Khalid, Asif Javed, Uzma Noureen, Habib Ullah.

(2) Those representing the partner institutions of NIAP, i.e.Government of Pakistan - Environment Section, Planning Commission; Environment Wing, ClimateChange Division, Pak-EPA Netherlands Commission for Environmental Assessment IUCN Pakistan

(3) Dr. Muhammad Irfan Khan, Dr Bobbi Schijf and Ahmad Saeed





Documents

Environmental Impact Assessment Course Curriculum …cmsdata.iucn.org/downloads/niap___eia_curriculum_for_hei.pdf · Environmental Impact Assessment Course Curriculum for Higher Education