an evaluation framework for effective public participation in eia in pakistan

Environmental Impact Assessment Review 31 (2011) 36–47

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An evaluation framework for effective public participation in EIA in Pakistan

Obaidullah Nadeem a,⁎, Thomas B. Fischer b

a Department of City & Regional Planning, University of Engineering & Technology, Lahore, Pakistanb Department of Civic Design, the University of Liverpool, Liverpool, UK

⁎ Corresponding author. Tel.: +92 42 9029203; fax:E-mail addresses: [email protected] (O. Nad

(T.B. Fischer).

0195-9255/$ – see front matter © 2010 Elsevier Inc. Aldoi:10.1016/j.eiar.2010.01.003

a b s t r a c t
a r t i c l e i n f o
Article history:Received 20 June 2009Received in revised form 20 January 2010Accepted 31 January 2010Available online 19 March 2010

Keywords:EIAPublic participationEvaluation frameworkPakistan

Evaluating the effectiveness of public participation in EIA related decisions is of crucial importance fordeveloping a better understanding of overall EIA effectiveness. This paper aims to contribute to theprofessional debate by establishing a country specific evaluation framework for Pakistan, which, it issuggested, could also potentially be used in other developing countries. The framework is used to evaluateperformance of public participation in EIA in terms of 40 attributes for four selected projects from theprovince of Punjab. The evaluation is based on interviews with stakeholders, review of EIA reports as well aspublic hearing proceedings and environmental approval conditions. The evaluation of the selected projectsrevealed an overall weak influence of public participation on substantive quality of EIA and on the finaldecision. Overall, EIA public participation has succeeded in providing a more egalitarian environment.Furthermore, it appears fair to say that sufficient time for submitting written comments on EIA reports aswell as for raising concerns during public hearings had been given. Also, public consultation was significantlycontributing to educating participants. Despite some impediments, it is argued that public participation inEIA is gradually gaining ground in Pakistan. Recommendations to enhance EIA public participationeffectiveness in Pakistan include applying a more proactive approach which should take place before EIA isconducted and before site selection for development projects is happening.

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1. Introduction

Public participation is considered an essential and ‘integral’component of EIA (Hartley and Wood, 2005; Palerm, 2000; Wood,2003; Jay et al., 2007; Fischer et al., 2008). Furia and Wallace-Jones(2000) argued that for public participation in EIA to be effective, theobjectives of involving the public need to be satisfied. Beierle andCayford (2002), as well as GoP (1997a), identified objectives of publicparticipation. These include:

• To provide adequate opportunities to stakeholders to raise theirconcerns and influence decision making at early stages of a project

• To educate and increase awareness of the stakeholders about theprojects and its potential environmental impacts

• To obtain local and traditional knowledge• To reduce conflicts among the participants• To make informed decisions by considering possible adverseimpacts andmitigationmeasures in the EIA report and final decision

• To enhance transparency and accountability in decision making• And to build trust in the proponents and government institutions.

Several authors have pointed out that to date public participationhas often failed in achieving these objectives (see eg Ahmad and

Wood, 2002; Glasson et al., 2005; Hartley and Wood, 2005; Paliwal,2006; Petts, 1999; Wang et al., 2003; Wood, 2003). The reasons forthis are said to include a late initiation in the EIA process, an intrinsiclimitation of the participation mechanisms, a poor contribution ofgenuine stakeholders, as well as excessive time and cost requirementsinvolved in participation exercises (Bisset, 2000; Hartley and Wood,2005; Paliwal, 2006).

In developed countries, whilst public participation is often said tohave a moderate influence on the project design and environmentalapproval conditions of EIA, it appears that to date it has not frequentlysucceeded in building trust in the competent authorities andproponents. This is mainly due to poor communication, poor accessto information and lack of transparency of the decision makingprocess (Beierle and Cayford, 2002; Bowler and Shepherd, 1997;Hartley and Wood, 2005; Sinclair and Diduck, 2001). These short-comings can possibly be explained by the proponent driven nature ofEIA preparation and consultation processes (Glasson et al., 2005;Wood, 2003). Generally speaking, there is some evidence that overall,benefits of public participation and resulting improvement in thequality of adopted projects exceed costs (Aschemann, 2004; Glassonet al., 2005).

Transparency of decisionmaking is important, as “in practice, thereis amove away from an elitist model in which expert advice acts as theauthoritative source for regulation to one in which citizens have avoice in framing government decisions” (Frewer and Salter, 2002,p.142). Nevertheless, “despite the [recent] resurgence of interest in

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37O. Nadeem, T.B. Fischer / Environmental Impact Assessment Review 31 (2011) 36–47

public participation, no consistentmethod has emerged for evaluatingthe success of individual processes or the desirability of the manyparticipatory methods” (Bierele, 1998, p.2). An important reason maybe that every participation exercise is unique in termsof objectives andsocio-political context (Rowe and Frewer, 2004). Hence, the regionalor country context and the objectives of participation are keydeterminants for effectiveness criteria. As Palerm (Palerm, 2000,p.582) suggested, “empirical evidence consistently shows that best[public participation] practice is essentially country-specific”. Someauthors have therefore suggested that the influence of publicparticipation on the final decisions related to EIA has varied betweencountries. Thosewith a good record are said to include theNetherlandsand Denmark, particularly due to early public involvement and, in theformer case, the existence of an independent EIA commission (Glassonet al., 2005; Van de Gronden et al., 1994; Wood, 2003).

This paper aims at contributing to the literature by establishing aframework for evaluating public participation in EIA in Pakistan.Whilst public participation during EIA of development projects inPakistan has been taking place for the last decade, to date, empiricalevidence of its effectiveness and influence on decision making hasremained scant. Furthermore, the paper also reports on the results ofapplying the framework to four EIA case studies from Pakistan. Resultsmay also be of interest for other developing countries withcomparable contexts, including eg India, Bangladesh and Sri Lanka(Rajvanshi, 2003).

Subsequently, first the context of public participation in EIA inPakistan is outlined. Then themethodology of the research underlyingthis paper is explained. The evaluation framework is set out next, therationale for the selection of case study projects is presented andresults of applying the framework to the selected EIA cases areportrayed. Results are discussed and finally, conclusions are drawn.

2. The context of public participation in EIA in Pakistan

Public participation is mandatory under section 12(3) of thePakistan Environmental Protection Act (PEPA) 1997 (GoP, 1997) andneeds to take place during the competent authority review stage ofEIA. Furthermore, the Pakistan Environmental Protection Agency(Review of IEE and EIA) Regulations 2000 under section 10 requirethat the public notice or invitation for participation to be published inan English or Urdu national newspaper and a local newspaper ofgeneral circulation in the project affected areas 30 days before thehearing (GoP, 2000). The public notice is also required to containinformation on project type, location, name and address of theproponent and the places at which the EIA report can be accessed.Formal public consultation does not generally take place during EIAs,except on socio-economic impacts of projects, taking the form of anopinion survey. EIA review is normally carried out by the competentauthority in-house. Independent experts are also occasionallyinvolved. Environmental Protection Agencies (EPAs) are legallyrequired to make a decision and grant environmental approval withinfourmonths of the submission of the EIA report. An appeal against anydecision of the Federal or Provincial Environment Protection Agenciescan be made to the Federal/Provincial Environmental Tribunal within30 days of the date of communication of the decision. The tribunal willthen either endorse the approval or reject it.

3. Research methodology

First an evaluation framework was developed, based on (a) reviewof the relevant literature, (b) legal provisions and guidelines, and(c) interviews with concerned officials, EIA consultants and experts.The reviewed literature mainly included scholarly articles and bookson the evaluation of public participation in EIA. Legal provisions of thePakistan Environmental Protection Act, the EIA regulations and theguidelines for public consultation (GoP, 1997a) were reviewed with

respect to identifying the mandatory and non-mandatory require-ments regarding timing and procedures of public involvement. Theevaluation framework thus established was continuously refinedduring the course of the research as new aspects emerged duringinterviews with stakeholders.

To investigate how the affected and interested public are consultedand to establish the extent to which their concerns are addressed inthe EIA reports, as well as the final decisions of development projectsin Pakistan, a case study approach was adopted. The decision on howmany cases to consider was of particular importance. Although asingle case can meet most of the requirements to confirm, challengeor extend a theory as well as significantly contribute to knowledgeand theory building, it often has a high risk of misrepresentation (Yin,2003). In order to strengthen findings, multiple case studies weretherefore undertaken, leading to more robust results (Creswell, 1994;Herriott and Firestone, 1983).

Four case studies were finally selected, including two transportprojects and two industrial development projects. The projects arelocated in the most populous province of Pakistan, namely Punjab,where more than 50% of the total EIA reports submitted to all EPAs inthe country are processed and public hearings are held. Out of all EIAsconducted in Punjab, amajority of EIA reports (60%) belonged to thesetwo development sectors. Other criteria for identifying suitable casesincluded: (1) projects should be of national interest, attracting theattention of a wider public; (2) some projects should be in urban andothers in rural areas, representing both, urban and rural character-istics; and (3) projects should be affecting people belonging to diversesocio-economic backgrounds.

Interviews with 40 stakeholders of each case study project (i.e. 160in total) were conducted. Stakeholders belonged to different groups,including those who participated in public hearings, ie those con-cerned officials of the Environmental Protection Agency (EPA) Punjab,project proponents, EIA consultants, academics and representatives ofNGOs, as well as non-participating direct affectees. The latter wereselected for interviews, using stratified random sampling technique.Hearing participants were selected, using purposive sampling. Theevaluation of interviewees' responses included establishing satisfac-tion levelwith thefinal decision, using Yeh's Index of Satisfaction (YIS)method (Yeh, 1975). A negative sign of the satisfaction index suggestsa bigger percentage of unsatisfied than satisfied stakeholders.

In order to identify the extent to which stakeholders' concernswere actually incorporated in EIA reports, a five point scale wasdeveloped, using various symbols, as follows:

not mentioned○ mentioned● discussed in detail

discussed in detail and included in mitigation measuresdiscussed in detail and included in project design

There are certain limitations of this approach. Firstly, it wasdifficult to identify stakeholders, particularly of participants of publichearings, as their complete addresses were not mentioned in theattendance sheets. It was felt that interview questionnaires shouldhave been distributed to the stakeholders during public hearings andlater on collected. Furthermore, the questionnaire was rather lengthyand contained questions for both, hearing participants and non-participants. Non-participant interviewees were unable to respond toquestions pertaining to methods and framework for consultation,composition and awareness of the public involved. Evaluation of theseaspects is therefore only based on the responses of hearing partici-pants. Finally, many interviewees did not see the EIA reports andwereunable to comment on its overall quality. It is important to mentionhere that proceedings on several petitions against projects are stilldealt with in the High Court. Therefore, cases cannot be named.

38 O. Nadeem, T.B. Fischer / Environmental Impact Assessment Review 31 (2011) 36–47

4. Evaluation framework

The EIA public participation practice evaluation frameworkincludes the following main components (see also Table 1):

• Legal requirements (1)• Effectiveness of methods used (2) and access to/quality ofinformation (3)

• Timing (4) and venue of public consultation (5); time given tocomment (6)

• Composition and awareness of the public involved (7)• Methods and framework for consultation (8)• Consideration of public concerns in the EIA report and incorporationof public concerns into the final decision (9)

• Transparency of decision making process (10)

Table 1Framework for evaluation of public participation in EIA in Pakistan.

Nature Major component Questions/attributes

Contextual Legal requirements 1. Did participation take place durin2. Did participation take place after3. Was the public notice for particip4. Was the public notice for particip

project affected areas?5. Did the public notice mention pro

where EIA report can be accessed6. Were the stakeholders given a rig

Methodological Methods and qualityof information

1. Were directly affected communiti2. Was the language of public notice3. Did the public notice contain info4. Did the available document conta

understandable by the stakeholde5. Was the EIA report easily accessib

Methodological Timing and venue ofpublic consultation

1. Were the timing and venue of pu2. Were stakeholders consulted at th3. Were stakeholders consulted duri4. Were stakeholders given sufficien5. Were stakeholders given sufficien6. Were stakeholders provided with7. Were poor stakeholders provided

them to participate?Contextual Composition and awareness

of the public involved1. Did the participants represent all2. Were the participants aware of en3. Do the participants believe that th

the project's impacts?Methodological Methods and framework

for consultation1. Do the methods adopted for cons2. Were the project details, possible3. Did the process provide for an eg4. Was the language of communicat5. Was there any provision of a med6. Did the process provide for any m7. In case of conflicts, was any genu

Substantive Consideration of publicconcerns in the EIA report

1. Were adequate significance and c2. Were adequate significance and c3. Were adequate significance and c4. Was adequate consideration given5. Were the participants/stakeholde

in the EIA report and project desi6. Were justifications acceptable to

given to any of the concerns raiseInfluencing Incorporation of public

concerns into thefinal decision

1. Were the concerns raised by the pconditions of approval?

2. Were new opportunities for trade3. Were the conditions of approval t

Methodological Transparency of decisionmaking process

1. Were the participants provided w2. Were the participants/stakeholde

in the decision making by the pro3. Were justifications acceptable to t

into the final decision/conditions4. Did the consultation process help

Source: Developed by the authors based on review of literature cited in Sections 1 and 4, studlocal EIA experts.

Components are sub-divided into criteria, allowing to establish theextent to which objectives of involving the public (see Section 1) wereachieved. Some components also pertain to the stages of the EIApublic participation process in order to establish how far stakeholderswere enabled to participate in decisionmaking and to identify hurdlesin the participation process. The choice of each component and asso-ciated evaluation criteria are briefly introduced here.

The first component is themost basic of the evaluation framework.It aims at establishing the extent to which legal requirements forinvolving the public and stakeholders during the EIA process weretaken into account.

Methods and quality of information provided pertain to the meansused for informing, as well as inviting the affected and interestedpublic. This is particularly important for many developing countriessince the majority of the population here still lives in rural areas and

g EIA review before starting construction work of the project?the legal notice period?ation published in an English and Urdu national newspaper?ation also published in a local newspaper of general circulation in the

ject type, its location, name and address of the proponent and the place?ht to appeal against the decisions?es and other potential stakeholders directly invited by writing letters/phone calls?understandable by a majority of the stakeholders?

rmation about how stakeholders will be consulted?in sufficient information about the project and its impacts in a mannerrs?le (from a timing and location point of view) by a majority of the stakeholders?blic hearing easily accessible for the majority of the stakeholders?e planning stage, i.e. before site specific decisions were made?ng the preparation of the EIA report?t time for submitting written comments on the EIA report?t time to raise their concerns during the public hearing?adequate transport (if needed) to reach the venue of the public hearing?with financial support as compensation to the loss of wages to enable

categories of the stakeholders?vironmental and socio-economic impacts of the project?e participation process significantly increased their knowledge about

ultation provide the participants with sufficient opportunity to influence decisions?impacts and mitigation measures properly presented/explained to the participants?alitarian environment to all the participants for expressing their concerns?ion understandable to a majority of the participants?iator/hearing panel during the public hearing?echanism to validate authenticity of claims?ine attempt made to resolve conflicts?overage given to environmental concerns/impacts?overage given to socio-economic concerns/impacts?overage given to physical/spatial concerns/impacts?to the project alternatives?

rs' representatives informed about how their concerns were incorporatedgn?the participants given, if adequate significance and coverage were notd by the participants?articipants adequately considered/incorporated into the final decision/

-offs or compensation to the affectees identified/negotiated?echnically and financially achievable?ith the opportunity to see minutes of the consultation proceedings/public hearing?rs' representatives informed about how their concerns/input was usedponent and the competent authority?he participants given for not considering/incorporating their concernsof approval?building trust in the proponent and the competent authority?

y of legal requirements, guidelines and EIA process in Pakistan as well as interviews with


may only have limited opportunities to access that information. Thequality of information depends on the clarity of the advertisement andthe EIA report/summary and its ability to enhance the level of aware-ness of participants about environmental and other issues related tothe project (Bierele, 1998; Sinclair and Diduck, 2000).

Regarding the aspect ‘timing and venue of consultation’, it isimportant to note that whilst public consultation is mandatory inPakistan, during the competent authority review stage of EIA,“consultations must take place at a time, where no irreversible deci-sions have been taken yet” (Heiland, 2005, p.426). Timing is thereforealso evaluatedwith regards to stakeholders being able to express theiropinion. The time provided should be long enough to allow the publicto become familiar with the project so that their opinions can beproperly developed and formulated (Heiland, 2005). Furthermore,accessibility of the venue of public consultation is considered animportant element for ensuring adequate participation of eg indige-nous communities or day labourers living in remote areas (Bisset,2000, p.154).

Composition and awareness of the public involved is important, asstakeholders with different backgrounds and affiliations provideuseful insights (eg people from rural areas, women, members ofNGOs, academia, media and representatives of the concerned govern-ment departments (Bisset, 2000; Petts, 1999; Ryu et al., 2004).Awareness of socio-economic and environmental issues and a lack of“understanding regarding scale, nature and likely effects of certaintypes of development projects” are considered constraints to effectiveparticipation (Bisset, 2000, p.154).

Assessing themethods and framework for consultation should helpto identify how far the interested and affected public are enabled tomake an active and meaningful contribution to the decision makingprocess. The assessment framework used in this context includesvarious issues of consultation and communication between partici-pants, the proponent and public hearing panel members. The attitudeof those consulting the public is important (Palerm, 2000), and it issuggested that participants should be provided with an open andunrestricted environment to express their views. Public hearing isconsidered a rather weak method of consultation in providing thestakeholders with an influencing role in decisionmaking (Aschemann,2008; Bierele, 1998). It can prove to be complex, unpredictable andintimidating. There is also a possibility that public hearing get‘hijacked’ by some interested group and that the affected communitycannot participate adequately (Naim, 2004, p.5). However, dependingon the framework and the environment inwhich it is being conducted,it can provide an opportunity of two way interaction among poten-tially opposing interests and may still be perceived as being useful(Bierele, 1998). The framework therefore also includes presentation ofpotential impacts and proposed mitigation measures, understand-ability of the language of communication, degree of freedom to expressviews,mechanisms to validate authenticity of claims, and genuinenessof attempts to resolve conflicts by those conducting hearings.

Considering public concerns in EIA can help in informing thedecision making process. However, how these concerns are subse-quently considered in the final decision is the main test for overallpublic participation effectiveness (GoP, 1997a). Boyle (Boyle, 1998)argues that the importance given to certain kinds of impacts indecision making may vary, depending upon eg cultural context.Furthermore, measuring the influence of public participation on EIArelated project decisions has also been identified as a major challengeto research (Cashmore et al., 2004). Public input is not only a source ofgenerating relevant factual information into a decision makingprocess, it can also lead to “decisions that are more technicallyrigorous and satisfy a wider range of interests” (Bierele, 1998, p.7; seealso Bierele and Cayford, 2002; Glasson et al., 2005). Thus, consideringpublic (stakeholders) concerns related to environmental, socio-economic and physical/spatial impacts and project alternatives canpossibly lead to improving the substantive quality of decisions.

Transparency of the decision making process is a further compo-nent of the evaluation framework. Whilst decision making processesshould be transparent, in developing countries, transparency is fre-quently hindered by limited access to information about the project'simpacts and the related decisions (Boyle, 1998). The public should beinformed about how their concerns influenced decision making(Beierle and Cayford, 2002). As a consequence, public participationshould lead to increased public trust in competent authorities as wellas proponents. However, lack of transparency may be in the way ofbuilding that trust, and as a consequence, theremay be environmentalor media campaigns against certain projects as well as litigation(Kakonge, 1998; Rajvanshi, 2003). Transparency of a decision makingprocess depends upon how far stakeholders are provided with accessto information related to key decision making documents. Access toinformation is therefore a key indicator of transparency. In the finaldecision, an explanation should be given on how stakeholders input/concerns were considered and how the final decision was made. Thiscan help in building public trust in thosewhomake decisions andwhoexecute projects. Important documents related to the outcome of thepublic participation process are the minutes of the public consultationproceeding/public hearing and environmental approval conditions.

5. Case studies

As indicated in Section 3, the four case studies include two roaddevelopments and two industry establishments in the PunjabProvince. Keeping in mind the constraint of staying anonymous, abrief introduction to the case studies is presented below.

5.1. Case study A: construction of a motorway

A 6 lane freeway with a right of way of 120m and a total length ofnearly 100km is planned, which would cover an area of about3000 acres. Most of the area covered consists of rich agricultural land,bisecting several villages. The estimated cost of the proposed projectis about US $ 304 Million (1 US $=84 PKR). The road would containseveral bridges, flyovers, vehicular and pedestrian underpasses aswell as drainage culverts. Public hearing was held within 75days ofthe submission of the EIA report. Environmental approval was grantedwithin 4 months.

5.2. Case study B: widening of a road

The existing carriageway width ranges from 8 to 22m and islocated next to a canal. The project is about widening a 14km longstretch of road by 7.5m. Overall, the width of used land will be about100m. The widening will result in the cutting of about 2000 trees. Theestimated cost of this project is US $ 9.5 Million (1 US $=84 PKR). Thepublic hearing for this project was held after 60days of the submissionof the EIA report and the environmental approval was granted within6 months.

5.3. Case study C: establishment of an industrial estate

The new industrial estate (already under construction) is sup-posed to cover 1600 acres of agricultural land. The total number ofindustrial plots is supposed to be around 600 to 700, ranging from 0.5to 5 acres in size. The industrial estate is located in the midst of sixvillages directly affecting nearly 10,000 people. The estimated cost ofthis project is US $ 47.62 Million (1 US $=84 PKR). A variety ofmedium to large manufacturing industries, including textiles, paper,beverages, pharmaceuticals, electrical appliances, mechanical equip-ment and others are proposed to be established. The public hearing forthis project was held within 5 months of the submission of the EIAreport and the environmental approval was granted after a furtherperiod of 18 months. Some excessive delays occurred mainly due to


the initial rejection of its EIA report and the competent authority'srequest to the proponent to submit a revised version.

5.4. Case study D: construction of a cement factory

This cement factory project consists of a regular Portland CementPlant with a production capacity of about 6000 tons per day. Theinitial cost estimate of this project was US $ 77.38 Million (1 US $=84PKR). The factory is supposed to be located in an environmentallysensitive and predominantly agricultural area next to a village of 6000inhabitants. Three other villages comprising a population of about21000 are also located within a 2 km radius of the planned factory.Including office buildings, the factory is spread over about 400 acres.The plant is based on a dry processing method and uses clay andlimestone as raw materials. These are available in abundance in andaround the factory area. Coal is being used as fuel.

6. Evaluation of results and discussion

This section is divided into eleven sub-sections. Each of thesections presents an evaluation of the results, highlighting the extentto which the public participation effectiveness criteria, as given inTable 1, were met. One of the sections also discusses stakeholders'satisfaction with the final decision.

6.1. Meeting the legal requirements of the country (1)

According to section 12(1) of the PEPA 1997, construction andoperation of a project requiring EIA legally cannot be started before anEIA is submitted and approved. For the two road sector projects, theEIA reports were submitted before the construction work, ie hearingswere held at the mandatory stage. For the two industrial projects, theEIA reports were submitted after the start of the construction work.The issue of acquisition of land is not dealt with in the PEPA 1997. Thisis important because once land is acquired, the possibility of con-sidering alternative sites for a project is rather remote. Overall, legalrequirements were fulfilled and invitations for public hearings for allfour projects were published in English and in Urdu (ie the nationallanguage) newspapers 30days before the date of the hearing.

None of the stakeholder groups/NGOs filed an appeal to theEnvironmental Tribunal against the environmental approvals grantedtoanyof the case studyprojects.However, a jointpublic interestpetitionhad been filed to the concerned High Court by several NGOs against theenvironmental approval of the road widening project. Similarly,affectees of the industrial estate and cement factory projects also filedpetitions to the High Court, mainly not against adverse impacts butagainst fraudulent acquisition of land.While industrial projects are nowin operation, decisions on all these petitions are still awaited.

6.2. Effectiveness of the methods used for informing/invitingstakeholders (2)

Most of the interviewees (between 63% and 100% for the fourcases) did not come to know about the public hearings throughnewspapers. Reasons for this included publishing of notices in news-papers that did not have a wide circulation in those areas affected bythe projects. Also, people missed seeing notices that were publishedalong numerous other tender notices. Furthermore, many villagers donot read newspapers regularly. Those who participated were eitherdirectly invited by the Environment Protection Agency (EPA) as offi-cials of the concerned government agencies or came to know about itthrough colleagues/friends/neighbours.

Review of the case files revealed that letters inviting writtencomments and participation in public hearings were sent to between20 and 33 potential stakeholders of each case study, mainly includingsecretaries of concerned government departments, heads of environ-

mental education institutions, andmayors of the affected districts andrepresentatives of some NGOs. A large proportion (90%) of inter-viewees in each case suggested that making announcements throughmosque speakers, advertising in local cable networks and informinglocal community representatives could also be effective methods ofinviting stakeholders from rural areas in Punjab Province in particularand from urban areas in general.

6.3. Access and quality of information (3)

EIA reports for all projects were placed in (a) public libraries of themunicipalities where the project sites were located, (b) in offices ofthe Punjab EPA, as well as (c) with proponents, once invitations forsubmitting written comments on the reports were published innewspapers. These reports could only be seen during office hours.Photocopying was not allowed. Despite a wide circulation of the EIAreports (particularly of the motorway and the cement factoryprojects), about 70% interviewees stated that location and timing ofmaking EIA reports available were not convenient to them. Many didnot even know about the EIA reports.

About aquarter of the intervieweeshadmanaged to gain access to theEIA report through their personal contacts. However, a majority of themfound that EIA reports and non-technical summaries did not clearlyidentify and predict impacts and mitigation measures. They consideredthe Environmental Management Plan (EMP), provided in the EIAs, asvague. Furthermore, the EMP did not clearly allocate responsibility for itsexecution. Generally speaking, interviewees did not believe in thecorrectness of the information provided. The interviewees were alsoasked to suggest appropriate locations where an EIA report should beplaced. Suggestions mainly included; nearby Union Council Offices orTehsil Municipal Administration (TMA) Offices as well as the website ofthe EPA. Some suggested that a non-technical summary should becirculated among key stakeholders or be published in newspapers.

6.4. Suitability of consultation timing (4)

Public hearings for the road sector case studies were held aftercompletion of the project design, but before the acquisition of land.Thus, it can be argued that there were possibilities to modify theproject design and proposed route. Both industrial projects were atthe construction stage when the EIA studies and hearings were held,indicating no or only very small possibilities for changing the projectdesign or the location, but there was some hope that mitigationmeasures may be adopted. 90% of the interviewees suggested thatstakeholders should be consulted not only at the EIA review stage, butalso during EIA preparation. It shows that people are still hopeful thatconsultation could lead to incorporation of their concerns into thedecisions. Very few (about 10%) were of the view that such consulta-tion was either of no need or of no use.

6.5. Accessibility of public hearing venue (5)

An inappropriate venue of a public hearing is considered animpediment to public participation. Out of all four case study projects,the public hearing venue for the motorway project was most inappro-priate, as it was very difficult and expensive to reach by those directlyaffected, ie those living in remote villages along a 100km span of road.Public hearing for the road widening project was held in a first classhotel. This was located near the project site and was highly accessibleto a majority (90%) of the stakeholders, particularly those fromdirectly affected communities.

The public hearing for the industrial estate project was held in afour star hotel located in the heart of the city, whereas directlyaffected poor villagers were living some 50km away from the citycentre. For the cement factory project, despite a sizable percentage ofinterviewees (37%) stating that it was difficult and expensive to reach,


the attendance of participants in the public hearing held at themeeting hall of the concerned District Council, shows that in this case,it was not a barrier. This was mainly because the affected commu-nities had received information about its date and venue through theirleaders and had strong concerns over loss of livelihood and environ-mental impacts.

Enabling poor people to participate in public hearings is of greatimportance. This may include financial and transport provisions.However, the majority of interviewees of all four projects stated thatthey were willing to participate without such provisions. An over-whelming majority (74% to 88%) also suggested that hearings shouldbetter be held at some big public place near the project site or at anearby Union Council/Tehsil Municipal Administration (TMA) office.

6.6. Adequacy of time given for written comments and raisingconcerns (6)

With the exception of a few, most interviewees (83% to 97%) of thecase study projects felt that four weeks for submitting writtencomments on the EIA reports was sufficient. When asked whetherthey were able to understand a voluminous technical report and givecomments, low literacy interviewees responded that they would haveasked somebody else (who was well educated) to read and writecomments for them. This actually happened in the cases of the cementfactory and road widening projects, as the community leaders andNGO representatives got hold of a copy of the EIA report andsubmitted written comments on behalf of the affectees regardingtheir concerns over potential environmental and socio-economicimpacts of the project.

A majority of the public hearings participants (ie between 75% and83%) felt that the time given for raising concerns on both, themotorway and road widening as well as for industrial estate projectswas sufficient. Hearing participants of the cement factory project wereof the view that they were not given sufficient time to raise theirconcerns. In the latter case, the proponent, consultant and EPAofficials wanted to finish the hearing as early as possible, presumablydue to a fear of a serious clash. Direct affectees were furious andwanted the project not to be allowed in the anticipated location.

6.7. Composition and awareness of the public involved (7)

The public hearing for the cement factory projectwas attended by allcategories of stakeholders, includingdirect affectees, environmentalists/

Table 2Public concerns and their consideration in the EIA report and final decision for case study A

Environmental impacts In EIAreport

In finaldecision

Socio-economic impacts

Cumulative impacts not considered x Weakening of social tiesInadequate prediction of futurestate of environment

x Decrease in agriculturalproducts and increase in cost

Location of asphalt plants andservice workshops

√ Loss of houses/other structure

Impact on water regime andrisk of flooding

√ Blockage of existing paths

Air and noise pollution duringconstruction

√ Irregular division of land

Loss of rich agricultural land x Increase in theftsImpacts on flora and fauna ● √ Improper location of pedestria

bridgesArrangement for disposal ofwastewater and solid waste

√ Low payment for thecompensation of land costAbsence of resettlement actioDisplacement of 2500 labouredue to alignment

○ only mentioned ● discussed in detail discussed in detail and included in mitigation mdiscussed in detail and included in project design not mentioned x not considered √

Source: Based on review of EIA report, public hearing proceedings, interviews with the stakehmotorway.

NGOs, officials of concerned government departments and academics.Nonetheless, representation of academics and environmentalists/NGOparticipants was very thin, based on the fact that the hearing venuewaslocated in a municipality far away from where they are based.

The public hearing for the roadwidening project was also attendedby all categories of stakeholders, but some 42% of the interviewees feltthat it was not fully representing those affected or interested,particularly as non-car owner road users and canal swimmers werenot present. Regarding the hearings for motorway and industrialestate projects, an important category of stakeholders i.e. thosedirectly affected, could not participate mainly due to no informationabout the event and the remote location of hearing venues. Some ofthe interviewees also considered public hearings as a formality orwere not interested to participate.

The majority (between 70% and 80%) of hearing participants of thethree case studies (all except the cement factory project), were wellaware of potential environmental and socio-economic impacts of therespective projects. The highest level of awareness was found amongthe hearing participants of the road widening and motorway projects,possibly because they were highly educated professionals, includingenvironmental experts, lawyers, architects, academics, representa-tives of NGOs and government departments. The awareness level ofthe cement factory hearing participants, who were less well educatedand coming from local villages, was found to be comparatively low.

Finally, when asked whether participation in the hearing hadhelped to increase their knowledge about potential impacts of theprojects, about 50% of the interviewees of all four cases whoparticipated in hearings realized that their knowledge about potentialimpacts had significantly increased as compared to what they knewabout the projects before attending the public hearings. This was alsoconfirmed through the highly technical and precise nature of concernsraised by the stakeholders during interviews for this study (seeTables 2–5). The rest of the participating interviewees felt that theirknowledge had increased to a lesser extent.

6.8. Effectiveness of methods and framework for consultation (8)

During the public hearings for the case studies, potential impactsof the projects and proposed mitigation measures were not ade-quately explained to the stakeholders. Many interviewees pointed outthat proponents tried to conceal potential impacts even in caseswhere construction of projects was going on. This suggests that both,EIA consultants and proponents were either lacking in knowledge

, construction of a motorway.

In EIAreport

In finaldecision

Physical/spatial impacts,alternatives and others

In EIAreport

In finaldecision

√ No need of new motorway ● x○ x Inadequate consideration

of alternative routes○ x

s ● x Built motorway along the canal n/a

√ Consequential change in land use ○ u/a

○ x Inappropriate hearing venue x

n/a Lack of responsibilities in EMP √n ○ √ Alien attitude of survey team n/a

√ Evidence of commitment forshifting of infrastructure

√

n plan n/ars √

easures.considered.olders and final decision/environmental approval for the case study A, construction of a

Table 3Public concerns and their consideration in the EIA report and final decision for the case study B, widening of a road.


In finaldecision

Socio-economic impacts In EIAreport

In finaldecision


In EIAreport

In Finaldecision

Emissions of toxins due to lossof 30,000 trees

x Safety of pedestrians andcyclists at risk

√ No need of the project ● x

Loss of 24 feet wide and 14 kms.long green verge

x Loss of heritage of thecity/urban forest

x Inadequate considerationof project alternatives

○ x

Destruction of biodiversity ● √ Disturbance to educationaland health institutions

x No criteria for selectionof consultant

x

2 to 3 degrees increase intemperature of the vicinity

○ x Accidents and loss of life dueto high speed

x Inaccurate counting of treesto be cut

√

Air and noise pollution duringconstruction

● √ No safety of workers andpublic during construction

○ √ Stakeholders not consultedduring EIA

● x

Risk of chest and other diseases x Reduction of green spacesfor public use

○ x Overall deficient EIA report ● x

Contamination of surface water √ Change in surrounding res. landuse to commercial

○ x

Soil erosion and silting of canal √Hazardous handling and disposalof waste

x

Destruction of indigenous fauna(46 species)

○ x

○ only mentioned ● discussed in detail discussed in detail and included in mitigation measures.discussed in detail and included in project design not mentioned x not considered √ considered.

Source: Based on review of EIA report, public hearing proceedings, interviews with the stakeholders and final decision/environmental approval for the case study B, widening of aroad.


about potential impacts or were deliberately ignoring them to avoidpossible delays in getting environmental approval.

However, it is encouraging to note that the communicationlanguage used during hearings was understood by the majority ofparticipants (80%–98%), at least for three of the case studies. EIAswere mainly explained in Urdu (ie the national language), and attimes by the local languages of the projects' direct affectees. In thecase of the cement factory project, 35% of the hearing participantswere not able to understand the communication language. Similarly,interview data and observations by the first author of this papershows that participants were provided with an egalitarian environ-ment to express their views. The public hearing for the cement factoryproject proved to be the only poor example. Here, participatinginterviewees felt very intimidated and pressurized due to thepresence of police at the hearing venue.

Table 4Public concerns and their consideration in the EIA report and final decision for the case stu


In finaldecision

Socio-economic im

Lack of baseline environment data ● √ Inflow of industriaEnvironmental impacts due toindustrial emissions

x Extrajudicial land a

Risk of diseases √ Blockage of accessvillages and gravey

No indication of source of energy ○ √ Inadequate compeof land

No information on groundwater consumption

√ No colony for induworkers

No provision of buffer zone around theindustrial estate

x Decrease in fodder

Inadequate arrangements for waste disposal √ Low job provisionLoss of agricultural land & trees ○ xBlockage of domestic sewer √Need of continuous environmental monitoring ○ √No information on maintenance of ground water √Redundant technology of effluenttreatment plant

√

Non-technical and illogical mitigation measures ● √

○ only mentioned ● discussed in detail discussed in detail and included in mitigation mdiscussed in detail and included in project design not mentioned x not considered √

Source: Based on review of EIA report, public hearing proceedings, interviews with the stakehan industrial estate.

There was no independent mediator or hearing panel for the casestudy projects. Except for the hearing of the motorway and theindustrial estate projects, no genuine attemptwasmade to resolve theconflicts among the participants. Validation of the authenticity ofclaims in the Punjab EPA was done by its in-house committee ofofficials for most of the cases, on the basis of apparent logic andproponents' justifications. There was no independent committee orany panel of experts for this purpose.

6.9. Extent of considering public concerns in the EIA reports and finaldecisions (9)

It is important to mention here that various measures for trade-offs and compensation had been suggested, either in the EIA reportsor in the conditions of the environmental approval in all four cases.

dy C, establishment of an industrial estate.

pacts In EIAreport

In finaldecision


In EIAreport

In finaldecision

l workers ○ x Alternative sites not considered ○ xcquisition x Location of the estate against

the City's Master Planx

to otherards

○ x Absence of plan to deal withemergency situation

√

nsation ● √ Lack of zoning in industrialestate

√

strial x No consultation during EIApreparation

● x

for animals x Overall deficient EIA report √

to locals ○ √

easures.considered.olders and final decision/environmental approval for the case study C, establishment of

Table 5Public concerns and their consideration in the EIA report and final decision for the case study D, construction of a cement factory.


In finaldecision

Socio-economic impacts In EIAreport

In finaldecision


In EIAreport

In finaldecision

Risk of skin allergy, asthma andobnoxious smell

○ x Blockage of established pathsand access to agri fields

x Alternative sites not considered x

Decrease in yield of agri land dueto air pollution

x Low provision of jobs to localresidents

○ √ Start of construction work priorapproval of plan and EIA

x

Inadequate measures to store rawmaterial/kiln dust

√ No resettlement of residents ofvillage opposite to factory

√ Unreliable data in the EIA report x

No arrangement for treatment of wastewater ○ √ Social impacts and loss of privacydue to alien visitors

x No evidence for quality ofplant machinery

○ √

Soil destabilizing and loss of natural beauty x Loss of grazing fields leasedfor quarry operation

x EIA done just for plantnot for project

x

Lowering of water table ○ x Road accidents due to heavy traffic xIndustrial wastewater polluting historical sites x Adverse impacts on tourism xLoss of fertile agricultural land x Inadequate compensation for

loss of land○ x

Loss of local biodiversity & medicinal plants x Cracks/weakening of buildingsdue to blasting

x

Noise pollution/blasting of hills for rawmaterial ○ x Death rate of cattle increased xContamination of community water ponds ○ x

○ only mentioned ● discussed in detail discussed in detail and included in mitigation measures.discussed in detail and included in project design not mentioned x not considered √ considered.

Source: Based on review of EIA report, public hearing proceedings, interviews with the stakeholders and final decision/environmental approval for the case study D, construction of acement factory.


However, those seem to be imposed and not negotiated through aconscious effort. Tables 2–5 summarise the concerns raised by thestakeholders with regard to the case study projects and the extentto which those were considered in their respective EIA reportsby the proponents and in the final decisions/environmental ap-provals by the EPA. The next four sub-sections provide for anexplanation of the outcome of each case study project in theseregards. Stakeholders' satisfaction levels with the final decisions arepresented next.

6.9.1. Motorway EIAComparatively speaking, the EIA and final decision/environmental

approval for this project proved better in considering stakeholders'concerns than the other three projects. A systematic review showsthat five out of eight concerns mainly relating to environmentalimpacts expected to arise during the construction phase were con-sidered in the EIA report and the final decision (Table 2). Hydrologicalstudies were conducted to thoroughly investigate possible floodingand impacts on water regimes. As a result, the project design includes86 water course culverts and 108 drainage culverts.

Regarding potential socio-economic impacts, 10 different con-cerns were raised mainly related to social ties, access to villages/agricultural land parcels on the other side of the motorway, irregulardivision or loss of agricultural land and compensation (Table 2). TheEIA report indicates that US $ 81.48 million have been allocated tocompensate for the loss of agricultural land, trees and other assets.Whilst irregular division of land has been avoided, some inter-viewees were still dissatisfied. Other than overhead bridges andflyovers, 35 vehicular underpasses and 37 pedestrian bridges havebeen included in the road design for ensuring access to both sides ofthe motorway.

Some of the alternative routes suggested by the stakeholders werealready mentioned in the EIA report. However, no physical/spatialimpacts of land use change and a decrease in agricultural productswere considered because benefits of the project were given moreimportance than possible negative spatial impacts. Similarly, aresettlement action plan was not seen to be necessary, because theproject was funded by the Punjab Government. Such plan is normallyonly required by international donor agencies.

Overall, EIA decision making led to granting environmentalapproval with 20 conditions. Out of those, 8 were specific and 12

were general in nature. Except for the condition to submit a separateEIA for a section of the proposedmotorway, linking it with a big city ofthe province, the remainder were nothing more than standardoperating procedures to avoid adverse environmental impacts duringconstruction and operation phases of amajor road. Perhaps this is whythe project proponent stated that all conditions were technically andfinancially achievable.

6.9.2. Road widening EIAWhilst only three out of nine concerns that related to environ-

mental impacts were considered in the EIA report of this project, theenvironmental approval posed an additional condition, namely toavoid soil erosion and silting of the canal (Table 3).Measures to controlair and noise pollution, traffic problems and contamination of surfaceand groundwater were also suggested.

Regarding socio-economic concerns, only the safety of pedestriansand cyclists was considered through the relocation of pedestrianbridges. The environmental approval also mentioned this conditionalong with ensuring the safety of workers and pedestrians during theconstruction phase. The dispute over the number of trees to be cutwas attempted to be resolved by joint counting of the EIA consultantand the representative of an active NGO. Possible spatial impacts ofpermanent changes of land use from green to grey and from brown toblue could not get attention of the proponent or the EPA at the time ofthe decision on the EIA. Recently, the concerned building anddevelopment control agency has banned further commercialization(change of land use from residential to commercial) along this road.Project alternatives were also proposed by the stakeholders, but thosewere just discussed in the EIA. There does not appear to be anygenuine attempt to consider those alternatives.

The final decision regarding environmental approval for thisproject was subject to 19 conditions. Eight conditions were projectspecific and the rest were of a general nature pertaining to environ-mental protection during construction and operation phases of theproject. Specific conditions were quite different from the routine. Forinstance, construction of a new road and five flyovers/underpasses atvarious junctions with roads located at the middle and end points ofroad widening sections. These projects were already included in thefuture plan of the proponent for overall improvement of traffic flow inthe central and other parts of the city. Other specific conditions for thisproject were important, especially as the proponent was advised to

Table 6Stakeholders' satisfaction with the final decision.

Projectname

Level ofsatisfaction

Nature of involvement/participation

Overallsatisfaction(percentage)

Satisfactionindex

Hearingparticipant(percentage)

Non-participant(percentage)

Motorway Satisfactory 8 22 17 −0.52Acceptable 17 13 14Unsatisfactory 75 65 69Total 100 100 100

Roadwidening

Satisfactory 0 18 9 −0.50Acceptable 9 55 32Unsatisfactory 91 27 59Total 100 100 100

Industrialestate


Cementfactory


Source: Interviews with the stakeholders of case study projects, 2008.


constitute an EMP implementation committee, making all potentialstakeholders members.

6.9.3. Industrial estate EIAThe EIA report of the industrial estate project was rejected by

hearing participants and the concerned EPA, based on a lack of infor-mation on several components of baseline conditions and potentialimpacts. The Federal EPA also took note of the inadequacy of the EIAreport and suggested substantive improvements. The proponentprepared a new EIA report considering most of the concerns relatedto environmental impacts, but potential socio-economic impactsremained poorly addressed.

Eight out of thirteen concerns relating to environmental impactswere considered in the revised EIA report. Most of the concerns wereincorporated in the final decision/conditions of approval (Table 4).Concerns pertaining to socio-economic and physical impacts and theproject's location being very close to residential settlements were notconsidered. The reason, as pointed out by some of the intervieweeswas that, on the choice of industrialists, a highly accessible fertile landon the outskirt of a major city was forcefully occupied by declaring itpartially barren.While the EIA report was being revised, the EPA couldnot stop construction activities at the project site due to very highpolitical patronage for the project. This implies that alternative siteswere not given due consideration.

The decision of environmental approval for the construction phasecontained 11 conditions. Only 4 conditions were project specific and 7were of a general nature. Specific conditions mainly suggested makingarrangements for treating wastewater and environment friendly man-agement of solid waste of individual units and ensuring installationof air pollution abatement equipment etc. Concerned officials of theproponent agency stated that all of the conditions were technically andfinancially achievable, though some are very expensive. However, theystressed that “we have to do it”.

6.9.4. Cement factory EIAMany concerns regarding possible environmental and socio-

economic impacts of the projectwere raised during the public hearing.But neither the EIA report nor the final decision/environmentalapproval gave adequate consideration to those concerns (Table 5).The report stated that “there will be no adverse impact on the popu-lation and environment around it because of environmental manage-ment measures”. Gaseous emissions of CO, SO2, NOx and PM10 andnoise levels will remain within the National Environmental QualityStandards of Pakistan. Similar to the case of industrial estate, landrequired for the factory was procured at present location andconstruction activities continued prior to EIA approval and evenwithout planning permission.

The letter conveying the decision of EPA on this project was uniqueas it looked more like a “No Objection Certificate” (NOC) than anenvironmental approval. Itmainly stated that as the concernedDistrictGovernment did not declare negative areas for industries which is itslegal responsibility, the concerned EPA had no objection on theconstruction of the cement factory at its proposed site. In the approvalletter there were no general or specific conditions, as imposed in theapproval of the other three cases. Rather, the proponent was directedto submitting documentary evidence to substantiate the type andquality of machinery and a plan to address resettlement issues whichmay arise due to project activities. The proponent was further directedto discharge his liabilities under the Pakistan Environmental Protec-tion Act 1997 and rules/regulations framed thereunder.

6.10. Stakeholders' satisfaction with the final decision

Overall, the results point towards some dissatisfaction with thefinal decision taken in all case studies. This is indicated by the negativeindex of satisfaction in Table 6. 75% of the interviewees of the cement

factory project were not satisfied due to concerns regarding aninappropriate location of the factory neither being considered in theEIA report nor the final decision. Despite the environmentally fragilenature of the project area and loss of livelihood of hundreds of familiesand some associated severe social and health impacts on 27000people, the EPA granted environmental approval. The main reasonappears to be the government's priority of economic developmentthrough promotion of industrial activities.

69% of the interviewees of the industrial estate project did notagree with the final decision of allowing this project at its currentlocation. The satisfaction level of those interviewees who had partici-pated in the public hearing was comparatively higher than that of thenon-participants. However, most of the participants were environ-mentalists or interested stakeholders who did not belong to thedirectly affected communities. 91% of those interviewees not partici-pating in the public hearing, but belonging to the directly affectedcommunities were not satisfied with the final decision. These peoplewere all facing environmental and socio-economic impacts of theproject along with loss of land. Also, they were not aware of theconditions of environmental approval/mitigation measures.

Regarding the road projects, about half of the interviewees weredissatisfied and did not accept the environmental approval of theseprojects by the EPA. They were of the view that both projects wereunnecessary and that they will bear more environmental costs thanresulting in economic benefits. Interviewees of the motorway projectcomplained that alternative routes and widening of the existinghighway link were not given adequate consideration. Almost all of thehearing participants interviewed suggested that instead of wideningthe canal road by cutting thousands of mature trees and thusdestroying an urban forest, the government should provide efficientand sufficient public transport and improve alternative roads.

Moreover, for both road projects, hearing participants felt thattheir concerns had no impact on the final decisions. This was the casebecause the conditions of environmental approval and suggestedmitigation measures were not conveyed to the stakeholders, indi-cating a lack of communication among the decision makers and theaffected and interested public. Slightly less than half of the inter-viewees who were satisfied with the decision of granting environ-mental approval to themotorway and roadwidening projects believedthat these would ultimately prove beneficial in terms of betteraccessibility and a rise in property values. Furthermore, they thoughtthat these projects would bear more transport benefits than adverseenvironmental impacts.


6.11. Transparency of the decision making process (10)

Interviewees of all four case studies stated that they were notprovided with the opportunity to see any minutes of public hearings.Interviews of concerned officials from the EPA confirmed that peoplewere not provided access to see theminutes of public hearings,which isconsidered confidential. However, in 2007, the Federal EPA startedposting proceedings and photographs of public hearings for EIAs ofprojects in its jurisdiction on its website (see http://www.environment.gov.pk/).

It is the responsibility of the concerned EPA to consider publicconcerns while making decisions. The majority of the intervieweeswere not aware of how their input was used. Also, they did not knowwhat the final decision or the conditions of approval were. The officialpoint of view is that informing and satisfying every stakeholder wouldlead to no project being approved. Rather, every effort should bemadeto ensure that public concerns are incorporated in project designs andconditions of approval. Anybody visiting the EPA office for this purposewould be verbally informed about how the stakeholders' concernswere considered and how some of the concerns were incorporated inthe conditions of approval (final decision).

Theoretically, public consultation and participation that take placeduring the preparation and review of an EIA report should lead tobuilding trust in government institutions and proponents (Beierle andCayford, 2002; Hartley and Wood, 2005; Petts, 1999). However,evidence from the case studies suggests that involving the public inEIA related decision making had failed in fostering trust in govern-ment institutions and in project proponents, mainly because concernswere largely ignored and the decision making process remainedintransparent. Nevertheless, some participants felt that consultationwas partially helping in building trust in the competent authority andin proponents. These particularly included the motorway and indus-trial estate projects interviewees.

7. Conclusions and recommendations

Public participation is an important part of EIA. It has elevatedEIA from a mere technical exercise for the conservation of naturalresources to a political tool of environmental planning and manage-ment. However, EIA practice around the globe suggests that theoverall influence of public participation on EIA related decisions is stillweak, particularly in developing countries. It is comparatively moreeffective and transparent where it is mandatory/initiated early in theEIA process (during scoping) and where review is done by indepen-dent experts. Furthermore, there is a need to consistently evaluate theperformance and effectiveness of public participation in EIA, keepingin view the country context in which it operates. Such evaluation canpossibly help to identify deficiencies of current practice and measuresto improve effectiveness. For this purpose, an evaluation frameworkwas developed for Pakistan. This paper has demonstrated thatby using the evaluation framework (Table 1), effectiveness of publicparticipation and its influence on EIA related decisions can beassessed. The framework evaluated 40 attributes of public participa-tion in EIA of four selected projects from the province of Punjab,Pakistan, including a motorway scheme, a road widening scheme, anindustrial estate and a cement factory. Main findings include:

■ The EIA public participation of the motorway project performedbetter compared with the other three projects. Since affected com-munities were consulted before the project design was finalizedduring EIA, many public concerns were incorporated. On the otherhand, the industrial estate establishment project was positivelyperceived despite holding public consultations only after the sitewas selected and construction activities had started. This is mainlybecause its EIA report was revised and most of the mitigationmeasures suggested by the hearing participantswere incorporated.

It is pertinent to note that in both cases, the public hearings wereheld in a fair andnon-aggressivemanner.Whilst direct affectees didnot attend, NGOs and environmentalists appear to have repre-sented them well. In addition, the proponents of both projects hademployed qualified environmentalists. Overall, it is found that thetype of project is not directly related to participation effectivenessor with the influence of public participation in decision making.

■ Overall, projects have demonstrated a weak influence of publicparticipation on the substantive quality of the EIA and the finaldecision. The main reason is a failure to involve stakeholders earlyin the EIA process and adequately addressing concerns beforeirreversible decisions regarding the project site and its procure-ment are made.

■ There was lack of communication as well as access to informationbetween the EPA and stakeholders. This was identified by inter-viewees as a cause for a lack of transparency in the decisionmakingprocess and also trust in the EPA and the proponents.

■ Regarding stakeholders' roles during public hearings, technicalexperts and NGOs appear to be able to influence outcomes of publichearings more positively than direct affectees, mainly due to oftennon-technical and ‘sentimental’ objections of the latter. Thus,contrary to some suggestions in the literature that ‘the wider thegeneral public takes part the better’ it could be argued that goodrepresentation by a third party may actually be preferable.

■ The research underlying this paper identified a direct relationshipbetween the presence of qualified environmentalists and positiveoutcomes of the project in terms of an improved EIA report andbetter final decision, at least from a public's point of view.

■ Overall, the EIA public participation process in the country can besaid to have achieved the establishment of a more egalitarianenvironment and sufficient time for submitting written commentson EIA reports and raising concerns during public hearings. Moreimportantly, public consultation was significantly contributing toeducating the participants, thus fulfilling one of its objectives. Thiswas also explained by a high level of awareness about a project'spotential impacts and mitigation measures among the hearingparticipants.

■ Whilst the literature suggests that there is often a general apathyand lack of willingness to participate in EIA, both, in developingand developed countries, the public in Punjab province appear tobe highly willing to contribute. There is therefore a great potentialfor an active public involvement in EIA of projects. It can thus beconcluded that public participation in EIA is gaining grounds inPakistan.

The results of this research suggest that public participation shouldbe held before detailed EIA studies, since in the case study projects,particularly for industrial establishments, key decisions regarding siteselection and their procurementalongwithdetailedproject designwerealreadymade. Most of the concerns by the stakeholders were related toan inappropriate location of the projects. Practically speaking, once thesite is procured and constructionwork is started, it is extremely difficultto relocate the project as a result of EIA. Involving the concerned publicbefore and during EIA studies can accrue significant benefits ascompared to those of public hearing at the EIA review stage. Specificmeasures for improving the public participation process and practicein Punjab and the overall EIA system in Pakistan are subsequentlyrecommended.

1. Legal provisions for public consultation and participation should bestrengthened by making it mandatory before site selection and EIAstudies instead of conducting it during the EIA review stage,as required under section 12(1) of the 1997 PEPA. Furthermore,instead of conducting a detailed EIA at the outset and presenting itto a ‘wider public’ during review, an initial environmental examina-tion (IEE) report should be presented to the concerned Municipal

http://www.environment.gov.pk/

http://www.environment.gov.pk/

Fig. 1. Proactive public participation based EIA model suggested for Pakistan.Source: Authors own construct based on analysis of public participation in EIA of development projects in Punjab, Pakistan.


Administration (TMA) in the presence of representatives (both,elected and nominated) of the direct affectees, NGOs, academicsand concerned officials, as suggested in Fig. 1. The IEE, being apreliminary assessment of potential environmental impacts, assuggested in the GoP (1983) and the PEPA (GoP, 1997), will helpidentify the need of a detailed EIA and issues to be included(scoping). This will allow a comprehensive coverage of significantenvironmental and socio-economic impacts of proposed projectsand their EIAs.Land use planning lies within the control of the TMA under the
Punjab Local Government Ordinance 2001 (Abid and Haider,2001). After getting approval of alternative sites and guidelinesfor scoping, the wider public preferably belonging to directaffectees must be consulted during EIA studies and their concernsare to be incorporated. Therewill be no need of a 2nd hearing, if theinitial hearing reports and video recording of consultations done atthe EIA preparation stages are presented during the EIA review,provided it is done by a panel/committee comprising independentexperts, representatives of direct affectees and EPA officials. Thereview panel may summon a post EIA hearing, if it is deemednecessary, keeping in view the sensitive nature of a project or if itpotentially involves massive displacement of people.
2. To get the maximum public input and lessen potential oppositionto a project, the information provided in the executive summaryand the EIA report must be comprehensive and comprehensible tothe stakeholders. It is recommended that the executive summaryshould be written in non-technical language with an Urdu trans-lation. Furthermore, it is suggested that every chapter of the EIAreport should also include its non-technical summary and an Urdutranslation of the summary. There is also a need to develop EIAreview criteria with a clear grading system, similarly to the hier-archical review framework suggested by Lee and Colley (1992).

3. The environment is a specialized profession and only fewprofessionals currently involved in EIA do not possess the requiredexpertise. No one can understand the importance of EIA betterthan a qualified environmental planner. Therefore, it is necessary

that the proponent organization should be required to employ atleast one qualified environmental planner/manager (dependingupon the project size) to coordinate the EIA process.

4. EIA reports should be placed at the TMA offices or at the UnionCouncil (UC) Office where the project is located within the juris-diction of one UC, and a PDF (portable document format) versionat the website of EPA, in addition to current practice of placing it inthe libraries for public review. In addition to the legal requirementof publishing the notice/invitation in newspapers for submittingwritten comments and participation in hearings, representativesof real stakeholders should be directly invited.

5. To improve communication between the EPA and stakeholders,dissemination of minutes of consultation proceedings as well asthe final decision, the internet and notice boards at the TMA, EPAalong with the offices of concerned agencies should be used.Also, decisions need to be directly conveyed to representatives ofstakeholders from all categories.

Acknowledgments

This paper is based on the Ph.D. research thesis on publicparticipation in EIA of development projects in Punjab, Pakistan byObaidullah Nadeem. He worked on a part of this research as a fellowat the Department of Civic Design, the University of Liverpool, UK.Thanks to the University of Engineering & Technology, Lahore andthe Higher Education Commission of Pakistan for providing thefunding and necessary support for this purpose. Research facilitiesand cooperation extended by the Department of Civic Design, theUniversity of Liverpool and the views of Dr. Urmila Jha Thakur arealso acknowledged. Special thanks to Dr. Rizwan Hameed, professorat the Department of City and Regional Planning, UET, Lahore, for hisin-depth and useful comments as an internal supervisor of the Ph.D.research. We would also like to thank EPA officials and all theinterviewees of the case study projects for giving their valuabletime.


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an evaluation framework for effective public participation in eia in pakistan

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