environmental legislation in pakistan – compliance perspectives
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Environmental Legislation in Pakistan – Compliance Perspectives. Ibad ur Rehman Deputy Director (Projects) Cleaner Production Institute. What we will NOT talk about. History of environmental legislation in Pakistan Development process of environmental legislation - PowerPoint PPT PresentationTRANSCRIPT
CPI Cleaner Production Institute
Environmental Legislation in Pakistan – Compliance Perspectives
Ibad ur RehmanDeputy Director (Projects)
Cleaner Production Institute
CPI Cleaner Production Institute
What we will NOT talk about
• History of environmental legislation in Pakistan
• Development process of environmental legislation
• Statutory details contained in the ext of PEPA 1997
• Roles & responsibilities of regulatory institutions
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CPI Cleaner Production Institute
What we WILL talk about
• Compliance mechanism for non-environmental professionals
• Types of compliances required
• Some recommendations
• Some limitations
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Environmental Concerns raised by EPAs
• No enrolments under SMART program• No environmental reports submitted• No monitoring report submitted• Organizations’ commitment for environment
is not visible• No reports submitted to Associations by
member units
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Regulatory Compliance – I
• Environmental Impact Assessment (EIA)
• Initial Environmental Examination (IEE)
• Environmental Statement / Environmental Audit
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Projects requiring EIA
Projects likely to cause adverse environmental impacts
Projects in Environmental Sensitive Areas may require EIA
Listed on schedule A of Pakistan Environmental Assessment Procedures
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Projects requiring IEE
Projects with uncertain effects on the environment
Not located in Environmental Sensitive Areas
Listed on schedule B
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Scope of Environmental Report
• Description of the Proposed Project
• Description of the Environment
• Legislative and Regulatory Considerations
• Determine the Potential Impacts of the Proposed Project
• Analysis of Alternatives to the Proposed Project
• Mitigation and Management of Negative Impacts
• Development of a Monitoring Plan
• Assistance in Inter-Agency Coordination and Public/NGO Participation
8Cont…
CPI Cleaner Production Institute
Recommendations
• EPA should include concept of Cleaner Production and Energy Efficiency in the scope of environmental report
• Proponents should also consider the above, specially for EA, for cost benefit
• Proponents’ responsibility is limited to submission of report and responding to queries. Follow-up for NOC is NOT required.
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Regulatory Compliance – II
• Regular monitoring of emissions
• Compliance with NEQS
• Preparation of Environmental Management Plans
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CPI Cleaner Production Institute
Categorization of Industries
In accordance with the international standards and practices the industries have been categorized as follows:
Category A. Category B. Category C.
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Self Monitoring & Reporting Under Normal Plant Condition
CategoryReporting Frequency
Liquid Effluent Gaseous Emissions
A Monthly Monthly
B Quarterly Quarterly
C Biannually (Six Monthly)
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Industries in Category A would be required
to maintain a record of times during which
start-up and upset conditions occur.
Total time for start-up and upset conditions
would be reported on a periodic basis.
Recording and Reporting of Plant Start-up and Upset Schedules
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Scope of Monitoring Assignment
• Develop sampling plan
• Conduct sampling
• Engage an EPA approved laboratory for environmental testing
• Evaluate test results based on professional experience
• Prepare environmental monitoring report for onward submission to EPA, having sections on monitoring results, technical discussion on results, and mitigation measures (if any).
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NEQS Compliance - Limitations
• Space limitation specially for WWTP
• Huge Capital expenditure involved
• Technical limitations specially in some cases of air emissions
• Technical basis of NEQS
• Individual ETP vs CETP
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WHAT IF OUR EFFLUENT OR EMISSIONS
DO NOT MEET NEQS???
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Scope of Environmental Management Plan
• Identification of Environmental Improvement
Options
• Prioritization of Environmental Improvement
Options
• Action Planning
• Report Formulation and Submission to EPA17
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Implications in Case of Non-Compliance
Pollution Charges
Environmental Protection Order
Environmental Tribunal
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