Environmental Impact Assessment Review 31 (2011) 3647

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Environmental Impact Assessment Review

j o u r n a l h o m e p a g e : w w w. e l s ev i e r. c o m / l o c a t e / e i a r

An evaluation framework for effective public participation in EIA in Pakistan

Obaidullah Nadeem a,, Thomas B. Fischer b
a b

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

a r t i c l e

i n f o

a b s t r a c t
Evaluating the effectiveness of public participation in EIA related decisions is of crucial importance for developing a better understanding of overall EIA effectiveness. This paper aims to contribute to the professional debate by establishing a country specic evaluation framework for Pakistan, which, it is suggested, could also potentially be used in other developing countries. The framework is used to evaluate performance of public participation in EIA in terms of 40 attributes for four selected projects from the province of Punjab. The evaluation is based on interviews with stakeholders, review of EIA reports as well as public hearing proceedings and environmental approval conditions. The evaluation of the selected projects revealed an overall weak inuence of public participation on substantive quality of EIA and on the nal decision. Overall, EIA public participation has succeeded in providing a more egalitarian environment. Furthermore, it appears fair to say that sufcient time for submitting written comments on EIA reports as well as for raising concerns during public hearings had been given. Also, public consultation was signicantly contributing to educating participants. Despite some impediments, it is argued that public participation in EIA is gradually gaining ground in Pakistan. Recommendations to enhance EIA public participation effectiveness in Pakistan include applying a more proactive approach which should take place before EIA is conducted and before site selection for development projects is happening. 2010 Elsevier Inc. All rights reserved.

Article history: Received 20 June 2009 Received in revised form 20 January 2010 Accepted 31 January 2010 Available online 19 March 2010 Keywords: EIA Public participation Evaluation framework Pakistan

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, the objectives of involving the public need to be satised. Beierle and Cayford (2002), as well as GoP (1997a), identied objectives of public participation. These include: To provide adequate opportunities to stakeholders to raise their concerns and inuence decision making at early stages of a project To educate and increase awareness of the stakeholders about the projects and its potential environmental impacts To obtain local and traditional knowledge To reduce conicts among the participants To make informed decisions by considering possible adverse impacts and mitigation measures in the EIA report and nal 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 participation has often failed in achieving these objectives (see eg Ahmad and
Corresponding author. Tel.: + 92 42 9029203; fax: + 92 42 9250202. E-mail addresses: obaidnadeem@yahoo.com (O. Nadeem), scher@liverpool.ac.uk (T.B. Fischer). 0195-9255/$ see front matter 2010 Elsevier Inc. All rights reserved. doi:10.1016/j.eiar.2010.01.003

Wood, 2002; Glasson et al., 2005; Hartley and Wood, 2005; Paliwal, 2006; Petts, 1999; Wang et al., 2003; Wood, 2003). The reasons for this are said to include a late initiation in the EIA process, an intrinsic limitation of the participation mechanisms, a poor contribution of genuine stakeholders, as well as excessive time and cost requirements involved in participation exercises (Bisset, 2000; Hartley and Wood, 2005; Paliwal, 2006). In developed countries, whilst public participation is often said to have a moderate inuence on the project design and environmental approval conditions of EIA, it appears that to date it has not frequently succeeded in building trust in the competent authorities and proponents. This is mainly due to poor communication, poor access to information and lack of transparency of the decision making process (Beierle and Cayford, 2002; Bowler and Shepherd, 1997; Hartley and Wood, 2005; Sinclair and Diduck, 2001). These shortcomings can possibly be explained by the proponent driven nature of EIA preparation and consultation processes (Glasson et al., 2005; Wood, 2003). Generally speaking, there is some evidence that overall, benets of public participation and resulting improvement in the quality of adopted projects exceed costs (Aschemann, 2004; Glasson et al., 2005). Transparency of decision making is important, as in practice, there is a move away from an elitist model in which expert advice acts as the authoritative source for regulation to one in which citizens have a voice in framing government decisions (Frewer and Salter, 2002, p.142). Nevertheless, despite the [recent] resurgence of interest in

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public participation, no consistent method has emerged for evaluating the success of individual processes or the desirability of the many participatory methods (Bierele, 1998, p.2). An important reason may be that every participation exercise is unique in terms of objectives and socio-political context (Rowe and Frewer, 2004). Hence, the regional or country context and the objectives of participation are key determinants for effectiveness criteria. As Palerm (Palerm, 2000, p.582) suggested, empirical evidence consistently shows that best [public participation] practice is essentially country-specic. Some authors have therefore suggested that the inuence of public participation on the nal decisions related to EIA has varied between countries. Those with a good record are said to include the Netherlands and Denmark, particularly due to early public involvement and, in the former case, the existence of an independent EIA commission (Glasson et al., 2005; Van de Gronden et al., 1994; Wood, 2003). This paper aims at contributing to the literature by establishing a framework for evaluating public participation in EIA in Pakistan. Whilst public participation during EIA of development projects in Pakistan has been taking place for the last decade, to date, empirical evidence of its effectiveness and inuence on decision making has remained scant. Furthermore, the paper also reports on the results of applying the framework to four EIA case studies from Pakistan. Results may also be of interest for other developing countries with comparable contexts, including eg India, Bangladesh and Sri Lanka (Rajvanshi, 2003). Subsequently, rst the context of public participation in EIA in Pakistan is outlined. Then the methodology of the research underlying this paper is explained. The evaluation framework is set out next, the rationale for the selection of case study projects is presented and results of applying the framework to the selected EIA cases are portrayed. Results are discussed and nally, conclusions are drawn. 2. The context of public participation in EIA in Pakistan Public participation is mandatory under section 12(3) of the Pakistan Environmental Protection Act (PEPA) 1997 (GoP, 1997) and needs to take place during the competent authority review stage of EIA. Furthermore, the Pakistan Environmental Protection Agency (Review of IEE and EIA) Regulations 2000 under section 10 require that the public notice or invitation for participation to be published in an English or Urdu national newspaper and a local newspaper of general circulation in the project affected areas 30 days before the hearing (GoP, 2000). The public notice is also required to contain information on project type, location, name and address of the proponent 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 an opinion survey. EIA review is normally carried out by the competent authority in-house. Independent experts are also occasionally involved. Environmental Protection Agencies (EPAs) are legally required to make a decision and grant environmental approval within four months of the submission of the EIA report. An appeal against any decision of the Federal or Provincial Environment Protection Agencies can be made to the Federal/Provincial Environmental Tribunal within 30 days of the date of communication of the decision. The tribunal will then either endorse the approval or reject it. 3. Research methodology First an evaluation framework was developed, based on (a) review of the relevant literature, (b) legal provisions and guidelines, and (c) interviews with concerned ofcials, EIA consultants and experts. The reviewed literature mainly included scholarly articles and books on the evaluation of public participation in EIA. Legal provisions of the Pakistan Environmental Protection Act, the EIA regulations and the guidelines for public consultation (GoP, 1997a) were reviewed with

respect to identifying the mandatory and non-mandatory requirements regarding timing and procedures of public involvement. The evaluation framework thus established was continuously rened during the course of the research as new aspects emerged during interviews with stakeholders. To investigate how the affected and interested public are consulted and to establish the extent to which their concerns are addressed in the EIA reports, as well as the nal decisions of development projects in Pakistan, a case study approach was adopted. The decision on how many cases to consider was of particular importance. Although a single case can meet most of the requirements to conrm, challenge or extend a theory as well as signicantly contribute to knowledge and theory building, it often has a high risk of misrepresentation (Yin, 2003). In order to strengthen ndings, multiple case studies were therefore undertaken, leading to more robust results (Creswell, 1994; Herriott and Firestone, 1983). Four case studies were nally selected, including two transport projects and two industrial development projects. The projects are located in the most populous province of Pakistan, namely Punjab, where more than 50% of the total EIA reports submitted to all EPAs in the country are processed and public hearings are held. Out of all EIAs conducted in Punjab, a majority of EIA reports (60%) belonged to these two development sectors. Other criteria for identifying suitable cases included: (1) projects should be of national interest, attracting the attention of a wider public; (2) some projects should be in urban and others in rural areas, representing both, urban and rural characteristics; and (3) projects should be affecting people belonging to diverse socio-economic backgrounds. Interviews with 40 stakeholders of each case study project (i.e. 160 in total) were conducted. Stakeholders belonged to different groups, including those who participated in public hearings, ie those concerned ofcials of the Environmental Protection Agency (EPA) Punjab, project proponents, EIA consultants, academics and representatives of NGOs, as well as non-participating direct affectees. The latter were selected for interviews, using stratied random sampling technique. Hearing participants were selected, using purposive sampling. The evaluation of interviewees' responses included establishing satisfaction level with the nal decision, using Yeh's Index of Satisfaction (YIS) method (Yeh, 1975). A negative sign of the satisfaction index suggests a bigger percentage of unsatised than satised stakeholders. In order to identify the extent to which stakeholders' concerns were actually incorporated in EIA reports, a ve point scale was developed, using various symbols, as follows: not mentioned mentioned discussed in detail discussed in detail and included in mitigation measures discussed in detail and included in project design There are certain limitations of this approach. Firstly, it was difcult to identify stakeholders, particularly of participants of public hearings, as their complete addresses were not mentioned in the attendance sheets. It was felt that interview questionnaires should have been distributed to the stakeholders during public hearings and later on collected. Furthermore, the questionnaire was rather lengthy and contained questions for both, hearing participants and nonparticipants. Non-participant interviewees were unable to respond to questions pertaining to methods and framework for consultation, composition and awareness of the public involved. Evaluation of these aspects is therefore only based on the responses of hearing participants. Finally, many interviewees did not see the EIA reports and were unable to comment on its overall quality. It is important to mention here that proceedings on several petitions against projects are still dealt with in the High Court. Therefore, cases cannot be named.

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4. Evaluation framework The EIA public participation practice evaluation framework includes the following main components (see also Table 1): Legal requirements (1) Effectiveness of methods used (2) and access to/quality of information (3) Timing (4) and venue of public consultation (5); time given to comment (6) Composition and awareness of the public involved (7) Methods and framework for consultation (8) Consideration of public concerns in the EIA report and incorporation of public concerns into the nal decision (9) Transparency of decision making process (10)

Components are sub-divided into criteria, allowing to establish the extent to which objectives of involving the public (see Section 1) were achieved. Some components also pertain to the stages of the EIA public participation process in order to establish how far stakeholders were enabled to participate in decision making and to identify hurdles in the participation process. The choice of each component and associated evaluation criteria are briey introduced here. The rst component is the most basic of the evaluation framework. It aims at establishing the extent to which legal requirements for involving the public and stakeholders during the EIA process were taken into account. Methods and quality of information provided pertain to the means used for informing, as well as inviting the affected and interested public. This is particularly important for many developing countries since the majority of the population here still lives in rural areas and

Table 1 Framework for evaluation of public participation in EIA in Pakistan. Nature Contextual Major component Legal requirements Questions/attributes 1. 2. 3. 4. 5. 6. 1. 2. 3. 4. 5. 1. 2. 3. 4. 5. 6. 7. 1. 2. 3. 1. 2. 3. 4. 5. 6. 7. 1. 2. 3. 4. 5. 6. Inuencing Incorporation of public concerns into the nal decision Transparency of decision making process 1. 2. 3. 1. 2. 3. 4. Did participation take place during EIA review before starting construction work of the project? Did participation take place after the legal notice period? Was the public notice for participation published in an English and Urdu national newspaper? Was the public notice for participation also published in a local newspaper of general circulation in the project affected areas? Did the public notice mention project type, its location, name and address of the proponent and the place where EIA report can be accessed? Were the stakeholders given a right to appeal against the decisions? Were directly affected communities and other potential stakeholders directly invited by writing letters/phone calls? Was the language of public notice understandable by a majority of the stakeholders? Did the public notice contain information about how stakeholders will be consulted? Did the available document contain sufcient information about the project and its impacts in a manner understandable by the stakeholders? Was the EIA report easily accessible (from a timing and location point of view) by a majority of the stakeholders? Were the timing and venue of public hearing easily accessible for the majority of the stakeholders? Were stakeholders consulted at the planning stage, i.e. before site specic decisions were made? Were stakeholders consulted during the preparation of the EIA report? Were stakeholders given sufcient time for submitting written comments on the EIA report? Were stakeholders given sufcient time to raise their concerns during the public hearing? Were stakeholders provided with adequate transport (if needed) to reach the venue of the public hearing? Were poor stakeholders provided with nancial support as compensation to the loss of wages to enable them to participate? Did the participants represent all categories of the stakeholders? Were the participants aware of environmental and socio-economic impacts of the project? Do the participants believe that the participation process signicantly increased their knowledge about the project's impacts? Do the methods adopted for consultation provide the participants with sufcient opportunity to inuence decisions? Were the project details, possible impacts and mitigation measures properly presented/explained to the participants? Did the process provide for an egalitarian environment to all the participants for expressing their concerns? Was the language of communication understandable to a majority of the participants? Was there any provision of a mediator/hearing panel during the public hearing? Did the process provide for any mechanism to validate authenticity of claims? In case of conicts, was any genuine attempt made to resolve conicts? Were adequate signicance and coverage given to environmental concerns/impacts? Were adequate signicance and coverage given to socio-economic concerns/impacts? Were adequate signicance and coverage given to physical/spatial concerns/impacts? Was adequate consideration given to the project alternatives? Were the participants/stakeholders' representatives informed about how their concerns were incorporated in the EIA report and project design? Were justications acceptable to the participants given, if adequate signicance and coverage were not given to any of the concerns raised by the participants? Were the concerns raised by the participants adequately considered/incorporated into the nal decision/ conditions of approval? Were new opportunities for trade-offs or compensation to the affectees identied/negotiated? Were the conditions of approval technically and nancially achievable? Were the participants provided with the opportunity to see minutes of the consultation proceedings/public hearing? Were the participants/stakeholders' representatives informed about how their concerns/input was used in the decision making by the proponent and the competent authority? Were justications acceptable to the participants given for not considering/incorporating their concerns into the nal decision/conditions of approval? Did the consultation process help building trust in the proponent and the competent authority?

Methodological

Methods and quality of information

Methodological

Timing and venue of public consultation

Contextual

Composition and awareness of the public involved

Methodological

Methods and framework for consultation

Substantive

Consideration of public concerns in the EIA report

Methodological

Source: Developed by the authors based on review of literature cited in Sections 1 and 4, study of legal requirements, guidelines and EIA process in Pakistan as well as interviews with local EIA experts.

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may only have limited opportunities to access that information. The quality of information depends on the clarity of the advertisement and the EIA report/summary and its ability to enhance the level of awareness of participants about environmental and other issues related to the project (Bierele, 1998; Sinclair and Diduck, 2000). Regarding the aspect timing and venue of consultation, it is important to note that whilst public consultation is mandatory in Pakistan, during the competent authority review stage of EIA, consultations must take place at a time, where no irreversible decisions have been taken yet (Heiland, 2005, p.426). Timing is therefore also evaluated with regards to stakeholders being able to express their opinion. The time provided should be long enough to allow the public to become familiar with the project so that their opinions can be properly developed and formulated (Heiland, 2005). Furthermore, accessibility of the venue of public consultation is considered an important element for ensuring adequate participation of eg indigenous communities or day labourers living in remote areas (Bisset, 2000, p.154). Composition and awareness of the public involved is important, as stakeholders with different backgrounds and afliations provide useful insights (eg people from rural areas, women, members of NGOs, academia, media and representatives of the concerned government 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 certain types of development projects are considered constraints to effective participation (Bisset, 2000, p.154). Assessing the methods and framework for consultation should help to identify how far the interested and affected public are enabled to make an active and meaningful contribution to the decision making process. The assessment framework used in this context includes various issues of consultation and communication between participants, the proponent and public hearing panel members. The attitude of those consulting the public is important (Palerm, 2000), and it is suggested that participants should be provided with an open and unrestricted environment to express their views. Public hearing is considered a rather weak method of consultation in providing the stakeholders with an inuencing role in decision making (Aschemann, 2008; Bierele, 1998). It can prove to be complex, unpredictable and intimidating. There is also a possibility that public hearing get hijacked by some interested group and that the affected community cannot participate adequately (Naim, 2004, p.5). However, depending on the framework and the environment in which it is being conducted, it can provide an opportunity of two way interaction among potentially opposing interests and may still be perceived as being useful (Bierele, 1998). The framework therefore also includes presentation of potential impacts and proposed mitigation measures, understandability of the language of communication, degree of freedom to express views, mechanisms to validate authenticity of claims, and genuineness of attempts to resolve conicts by those conducting hearings. Considering public concerns in EIA can help in informing the decision making process. However, how these concerns are subsequently considered in the nal decision is the main test for overall public participation effectiveness (GoP, 1997a). Boyle (Boyle, 1998) argues that the importance given to certain kinds of impacts in decision making may vary, depending upon eg cultural context. Furthermore, measuring the inuence of public participation on EIA related project decisions has also been identied as a major challenge to research (Cashmore et al., 2004). Public input is not only a source of generating relevant factual information into a decision making process, it can also lead to decisions that are more technically rigorous and satisfy a wider range of interests (Bierele, 1998, p.7; see also Bierele and Cayford, 2002; Glasson et al., 2005). Thus, considering public (stakeholders) concerns related to environmental, socioeconomic and physical/spatial impacts and project alternatives can possibly lead to improving the substantive quality of decisions.

Transparency of the decision making process is a further component of the evaluation framework. Whilst decision making processes should be transparent, in developing countries, transparency is frequently hindered by limited access to information about the project's impacts and the related decisions (Boyle, 1998). The public should be informed about how their concerns inuenced decision making (Beierle and Cayford, 2002). As a consequence, public participation should lead to increased public trust in competent authorities as well as proponents. However, lack of transparency may be in the way of building that trust, and as a consequence, there may be environmental or media campaigns against certain projects as well as litigation (Kakonge, 1998; Rajvanshi, 2003). Transparency of a decision making process depends upon how far stakeholders are provided with access to information related to key decision making documents. Access to information is therefore a key indicator of transparency. In the nal decision, an explanation should be given on how stakeholders input/ concerns were considered and how the nal decision was made. This can help in building public trust in those who make decisions and who execute projects. Important documents related to the outcome of the public participation process are the minutes of the public consultation proceeding/public hearing and environmental approval conditions. 5. Case studies As indicated in Section 3, the four case studies include two road developments and two industry establishments in the Punjab Province. Keeping in mind the constraint of staying anonymous, a brief 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 120 m and a total length of nearly 100 km is planned, which would cover an area of about 3000 acres. Most of the area covered consists of rich agricultural land, bisecting several villages. The estimated cost of the proposed project is about US $ 304 Million (1 US $ = 84 PKR). The road would contain several bridges, yovers, vehicular and pedestrian underpasses as well as drainage culverts. Public hearing was held within 75 days of the submission of the EIA report. Environmental approval was granted within 4 months. 5.2. Case study B: widening of a road The existing carriageway width ranges from 8 to 22 m and is located next to a canal. The project is about widening a 14 km long stretch of road by 7.5 m. Overall, the width of used land will be about 100 m. The widening will result in the cutting of about 2000 trees. The estimated cost of this project is US $ 9.5 Million (1 US $ = 84 PKR). The public hearing for this project was held after 60 days of the submission of the EIA report and the environmental approval was granted within 6 months. 5.3. Case study C: establishment of an industrial estate The new industrial estate (already under construction) is supposed to cover 1600 acres of agricultural land. The total number of industrial plots is supposed to be around 600 to 700, ranging from 0.5 to 5 acres in size. The industrial estate is located in the midst of six villages directly affecting nearly 10,000 people. The estimated cost of this project is US $ 47.62 Million (1 US $ = 84 PKR). A variety of medium to large manufacturing industries, including textiles, paper, beverages, pharmaceuticals, electrical appliances, mechanical equipment and others are proposed to be established. The public hearing for this project was held within 5 months of the submission of the EIA report and the environmental approval was granted after a further period of 18 months. Some excessive delays occurred mainly due to

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the initial rejection of its EIA report and the competent authority's request 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 Cement Plant with a production capacity of about 6000 tons per day. The initial cost estimate of this project was US $ 77.38 Million (1 US $ = 84 PKR). The factory is supposed to be located in an environmentally sensitive and predominantly agricultural area next to a village of 6000 inhabitants. Three other villages comprising a population of about 21000 are also located within a 2 km radius of the planned factory. Including ofce buildings, the factory is spread over about 400 acres. The plant is based on a dry processing method and uses clay and limestone as raw materials. These are available in abundance in and around 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 the sections presents an evaluation of the results, highlighting the extent to which the public participation effectiveness criteria, as given in Table 1, were met. One of the sections also discusses stakeholders' satisfaction with the nal decision. 6.1. Meeting the legal requirements of the country (1) According to section 12(1) of the PEPA 1997, construction and operation of a project requiring EIA legally cannot be started before an EIA is submitted and approved. For the two road sector projects, the EIA reports were submitted before the construction work, ie hearings were held at the mandatory stage. For the two industrial projects, the EIA reports were submitted after the start of the construction work. The issue of acquisition of land is not dealt with in the PEPA 1997. This is important because once land is acquired, the possibility of considering alternative sites for a project is rather remote. Overall, legal requirements were fullled and invitations for public hearings for all four projects were published in English and in Urdu (ie the national language) newspapers 30 days before the date of the hearing. None of the stakeholder groups/NGOs led an appeal to the Environmental Tribunal against the environmental approvals granted to any of the case study projects. However, a joint public interest petition had been led to the concerned High Court by several NGOs against the environmental approval of the road widening project. Similarly, affectees of the industrial estate and cement factory projects also led petitions to the High Court, mainly not against adverse impacts but against fraudulent acquisition of land. While industrial projects are now in operation, decisions on all these petitions are still awaited. 6.2. Effectiveness of the methods used for informing/inviting stakeholders (2) Most of the interviewees (between 63% and 100% for the four cases) did not come to know about the public hearings through newspapers. Reasons for this included publishing of notices in newspapers that did not have a wide circulation in those areas affected by the projects. Also, people missed seeing notices that were published along numerous other tender notices. Furthermore, many villagers do not read newspapers regularly. Those who participated were either directly invited by the Environment Protection Agency (EPA) as ofcials of the concerned government agencies or came to know about it through colleagues/friends/neighbours. Review of the case les revealed that letters inviting written comments and participation in public hearings were sent to between 20 and 33 potential stakeholders of each case study, mainly including secretaries of concerned government departments, heads of environ-

mental education institutions, and mayors of the affected districts and representatives of some NGOs. A large proportion (90%) of interviewees in each case suggested that making announcements through mosque speakers, advertising in local cable networks and informing local community representatives could also be effective methods of inviting stakeholders from rural areas in Punjab Province in particular and 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 the municipalities where the project sites were located, (b) in ofces of the Punjab EPA, as well as (c) with proponents, once invitations for submitting written comments on the reports were published in newspapers. These reports could only be seen during ofce hours. Photocopying was not allowed. Despite a wide circulation of the EIA reports (particularly of the motorway and the cement factory projects), about 70% interviewees stated that location and timing of making EIA reports available were not convenient to them. Many did not even know about the EIA reports. About a quarter of the interviewees had managed to gain access to the EIA report through their personal contacts. However, a majority of them found that EIA reports and non-technical summaries did not clearly identify and predict impacts and mitigation measures. They considered the Environmental Management Plan (EMP), provided in the EIAs, as vague. Furthermore, the EMP did not clearly allocate responsibility for its execution. Generally speaking, interviewees did not believe in the correctness of the information provided. The interviewees were also asked to suggest appropriate locations where an EIA report should be placed. Suggestions mainly included; nearby Union Council Ofces or Tehsil Municipal Administration (TMA) Ofces as well as the website of the EPA. Some suggested that a non-technical summary should be circulated 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 after completion of the project design, but before the acquisition of land. Thus, it can be argued that there were possibilities to modify the project design and proposed route. Both industrial projects were at the construction stage when the EIA studies and hearings were held, indicating no or only very small possibilities for changing the project design or the location, but there was some hope that mitigation measures may be adopted. 90% of the interviewees suggested that stakeholders should be consulted not only at the EIA review stage, but also during EIA preparation. It shows that people are still hopeful that consultation could lead to incorporation of their concerns into the decisions. Very few (about 10%) were of the view that such consultation 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 an impediment to public participation. Out of all four case study projects, the public hearing venue for the motorway project was most inappropriate, as it was very difcult and expensive to reach by those directly affected, ie those living in remote villages along a 100 km span of road. Public hearing for the road widening project was held in a rst class hotel. This was located near the project site and was highly accessible to a majority (90%) of the stakeholders, particularly those from directly affected communities. The public hearing for the industrial estate project was held in a four star hotel located in the heart of the city, whereas directly affected poor villagers were living some 50 km away from the city centre. For the cement factory project, despite a sizable percentage of interviewees (37%) stating that it was difcult and expensive to reach,

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the attendance of participants in the public hearing held at the meeting hall of the concerned District Council, shows that in this case, it was not a barrier. This was mainly because the affected communities had received information about its date and venue through their leaders and had strong concerns over loss of livelihood and environmental impacts. Enabling poor people to participate in public hearings is of great importance. This may include nancial and transport provisions. However, the majority of interviewees of all four projects stated that they were willing to participate without such provisions. An overwhelming majority (74% to 88%) also suggested that hearings should better be held at some big public place near the project site or at a nearby Union Council/Tehsil Municipal Administration (TMA) ofce. 6.6. Adequacy of time given for written comments and raising concerns (6) With the exception of a few, most interviewees (83% to 97%) of the case study projects felt that four weeks for submitting written comments on the EIA reports was sufcient. When asked whether they were able to understand a voluminous technical report and give comments, low literacy interviewees responded that they would have asked somebody else (who was well educated) to read and write comments for them. This actually happened in the cases of the cement factory and road widening projects, as the community leaders and NGO representatives got hold of a copy of the EIA report and submitted written comments on behalf of the affectees regarding their concerns over potential environmental and socio-economic impacts of the project. A majority of the public hearings participants (ie between 75% and 83%) felt that the time given for raising concerns on both, the motorway and road widening as well as for industrial estate projects was sufcient. Hearing participants of the cement factory project were of the view that they were not given sufcient time to raise their concerns. In the latter case, the proponent, consultant and EPA ofcials wanted to nish the hearing as early as possible, presumably due to a fear of a serious clash. Direct affectees were furious and wanted 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 project was attended by all categories of stakeholders, including direct affectees, environmentalists/

NGOs, ofcials of concerned government departments and academics. Nonetheless, representation of academics and environmentalists/NGO participants was very thin, based on the fact that the hearing venue was located in a municipality far away from where they are based. The public hearing for the road widening project was also attended by all categories of stakeholders, but some 42% of the interviewees felt that it was not fully representing those affected or interested, particularly as non-car owner road users and canal swimmers were not present. Regarding the hearings for motorway and industrial estate projects, an important category of stakeholders i.e. those directly affected, could not participate mainly due to no information about the event and the remote location of hearing venues. Some of the interviewees also considered public hearings as a formality or were not interested to participate. The majority (between 70% and 80%) of hearing participants of the three case studies (all except the cement factory project), were well aware of potential environmental and socio-economic impacts of the respective projects. The highest level of awareness was found among the hearing participants of the road widening and motorway projects, possibly because they were highly educated professionals, including environmental experts, lawyers, architects, academics, representatives of NGOs and government departments. The awareness level of the cement factory hearing participants, who were less well educated and coming from local villages, was found to be comparatively low. Finally, when asked whether participation in the hearing had helped to increase their knowledge about potential impacts of the projects, about 50% of the interviewees of all four cases who participated in hearings realized that their knowledge about potential impacts had signicantly increased as compared to what they knew about the projects before attending the public hearings. This was also conrmed through the highly technical and precise nature of concerns raised by the stakeholders during interviews for this study (see Tables 25). The rest of the participating interviewees felt that their knowledge 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 impacts of the projects and proposed mitigation measures were not adequately explained to the stakeholders. Many interviewees pointed out that proponents tried to conceal potential impacts even in cases where construction of projects was going on. This suggests that both, EIA consultants and proponents were either lacking in knowledge

Table 2 Public concerns and their consideration in the EIA report and nal decision for case study A, construction of a motorway. Environmental impacts Cumulative impacts not considered Inadequate prediction of future state of environment Location of asphalt plants and service workshops Impact on water regime and risk of ooding Air and noise pollution during construction Loss of rich agricultural land Impacts on ora and fauna Arrangement for disposal of wastewater and solid waste In EIA report In nal decision x x x Socio-economic impacts Weakening of social ties Decrease in agricultural products and increase in cost Loss of houses/other structures Blockage of existing paths Irregular division of land Increase in thefts Improper location of pedestrian bridges Low payment for the compensation of land cost Absence of resettlement action plan Displacement of 2500 labourers due to alignment In EIA report In nal decision x x x n/a n/a Physical/spatial impacts, alternatives and others No need of new motorway Inadequate consideration of alternative routes Built motorway along the canal Consequential change in land use Inappropriate hearing venue Lack of responsibilities in EMP Alien attitude of survey team Evidence of commitment for shifting of infrastructure In EIA report In nal decision x x n/a u/a x n/a

discussed in detail and included in mitigation measures. only mentioned discussed in detail 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 nal decision/environmental approval for the case study A, construction of a motorway.

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Table 3 Public concerns and their consideration in the EIA report and nal decision for the case study B, widening of a road. Environmental impacts Emissions of toxins due to loss of 30,000 trees Loss of 24 feet wide and 14 kms. long green verge Destruction of biodiversity 2 to 3 degrees increase in temperature of the vicinity Air and noise pollution during construction Risk of chest and other diseases Contamination of surface water Soil erosion and silting of canal Hazardous handling and disposal of waste Destruction of indigenous fauna (46 species) In EIA report In nal decision x x x x x x Socio-economic impacts Safety of pedestrians and cyclists at risk Loss of heritage of the city/urban forest Disturbance to educational and health institutions Accidents and loss of life due to high speed No safety of workers and public during construction Reduction of green spaces for public use Change in surrounding res. land use to commercial In EIA report In nal decision x x x x x Physical/spatial impacts, alternatives and others No need of the project Inadequate consideration of project alternatives No criteria for selection of consultant Inaccurate counting of trees to be cut Stakeholders not consulted during EIA Overall decient EIA report In EIA report In Final decision x x x x x

discussed in detail and included in mitigation measures. only mentioned discussed in detail 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 nal decision/environmental approval for the case study B, widening of a road.

about potential impacts or were deliberately ignoring them to avoid possible delays in getting environmental approval. However, it is encouraging to note that the communication language used during hearings was understood by the majority of participants (80%98%), at least for three of the case studies. EIAs were mainly explained in Urdu (ie the national language), and at times by the local languages of the projects' direct affectees. In the case of the cement factory project, 35% of the hearing participants were not able to understand the communication language. Similarly, interview data and observations by the rst author of this paper shows that participants were provided with an egalitarian environment to express their views. The public hearing for the cement factory project proved to be the only poor example. Here, participating interviewees felt very intimidated and pressurized due to the presence of police at the hearing venue.

There was no independent mediator or hearing panel for the case study projects. Except for the hearing of the motorway and the industrial estate projects, no genuine attempt was made to resolve the conicts among the participants. Validation of the authenticity of claims in the Punjab EPA was done by its in-house committee of ofcials for most of the cases, on the basis of apparent logic and proponents' justications. There was no independent committee or any panel of experts for this purpose. 6.9. Extent of considering public concerns in the EIA reports and nal decisions (9) It is important to mention here that various measures for tradeoffs and compensation had been suggested, either in the EIA reports or in the conditions of the environmental approval in all four cases.

Table 4 Public concerns and their consideration in the EIA report and nal decision for the case study C, establishment of an industrial estate. Environmental impacts Lack of baseline environment data Environmental impacts due to industrial emissions Risk of diseases No indication of source of energy No information on ground water consumption No provision of buffer zone around the industrial estate Inadequate arrangements for waste disposal Loss of agricultural land & trees Blockage of domestic sewer Need of continuous environmental monitoring No information on maintenance of ground water Redundant technology of efuent treatment plant Non-technical and illogical mitigation measures In EIA report In nal decision x x x Socio-economic impacts Inow of industrial workers Extrajudicial land acquisition Blockage of access to other villages and graveyards Inadequate compensation of land No colony for industrial workers Decrease in fodder for animals Low job provision to locals In EIA report In nal decision x x x x x Physical/spatial impacts, alternatives and others Alternative sites not considered Location of the estate against the City's Master Plan Absence of plan to deal with emergency situation Lack of zoning in industrial estate No consultation during EIA preparation Overall decient EIA report In EIA report In nal decision x x x

discussed in detail and included in mitigation measures. only mentioned discussed in detail 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 nal decision/environmental approval for the case study C, establishment of an industrial estate.

O. Nadeem, T.B. Fischer / Environmental Impact Assessment Review 31 (2011) 3647 Table 5 Public concerns and their consideration in the EIA report and nal decision for the case study D, construction of a cement factory. Environmental impacts Risk of skin allergy, asthma and obnoxious smell Decrease in yield of agri land due to air pollution Inadequate measures to store raw material/kiln dust No arrangement for treatment of wastewater Soil destabilizing and loss of natural beauty Lowering of water table Industrial wastewater polluting historical sites Loss of fertile agricultural land Loss of local biodiversity & medicinal plants Noise pollution/blasting of hills for raw material Contamination of community water ponds In EIA In nal Socio-economic impacts report decision x x x x x x x x x In EIA In nal Physical/spatial impacts, report decision alternatives and others x x x x x x x x Alternative sites not considered Start of construction work prior approval of plan and EIA Unreliable data in the EIA report No evidence for quality of plant machinery EIA done just for plant not for project

43

In EIA In nal report decision x x x x

Blockage of established paths and access to agri elds Low provision of jobs to local residents No resettlement of residents of village opposite to factory Social impacts and loss of privacy due to alien visitors Loss of grazing elds leased for quarry operation Road accidents due to heavy trafc Adverse impacts on tourism Inadequate compensation for loss of land Cracks/weakening of buildings due to blasting Death rate of cattle increased

discussed in detail and included in mitigation measures. only mentioned discussed in detail 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 nal decision/environmental approval for the case study D, construction of a cement factory.

However, those seem to be imposed and not negotiated through a conscious effort. Tables 25 summarise the concerns raised by the stakeholders with regard to the case study projects and the extent to which those were considered in their respective EIA reports by the proponents and in the nal decisions/environmental approvals by the EPA. The next four sub-sections provide for an explanation of the outcome of each case study project in these regards. Stakeholders' satisfaction levels with the nal decisions are presented next. 6.9.1. Motorway EIA Comparatively speaking, the EIA and nal decision/environmental approval for this project proved better in considering stakeholders' concerns than the other three projects. A systematic review shows that ve out of eight concerns mainly relating to environmental impacts expected to arise during the construction phase were considered in the EIA report and the nal decision (Table 2). Hydrological studies were conducted to thoroughly investigate possible ooding and impacts on water regimes. As a result, the project design includes 86 water course culverts and 108 drainage culverts. Regarding potential socio-economic impacts, 10 different concerns were raised mainly related to social ties, access to villages/ agricultural land parcels on the other side of the motorway, irregular division or loss of agricultural land and compensation (Table 2). The EIA report indicates that US $ 81.48 million have been allocated to compensate for the loss of agricultural land, trees and other assets. Whilst irregular division of land has been avoided, some interviewees were still dissatised. Other than overhead bridges and yovers, 35 vehicular underpasses and 37 pedestrian bridges have been included in the road design for ensuring access to both sides of the motorway. Some of the alternative routes suggested by the stakeholders were already mentioned in the EIA report. However, no physical/spatial impacts of land use change and a decrease in agricultural products were considered because benets of the project were given more importance than possible negative spatial impacts. Similarly, a resettlement action plan was not seen to be necessary, because the project was funded by the Punjab Government. Such plan is normally only required by international donor agencies. Overall, EIA decision making led to granting environmental approval with 20 conditions. Out of those, 8 were specic and 12

were general in nature. Except for the condition to submit a separate EIA for a section of the proposed motorway, linking it with a big city of the province, the remainder were nothing more than standard operating procedures to avoid adverse environmental impacts during construction and operation phases of a major road. Perhaps this is why the project proponent stated that all conditions were technically and nancially achievable. 6.9.2. Road widening EIA Whilst only three out of nine concerns that related to environmental impacts were considered in the EIA report of this project, the environmental approval posed an additional condition, namely to avoid soil erosion and silting of the canal (Table 3). Measures to control air and noise pollution, trafc problems and contamination of surface and groundwater were also suggested. Regarding socio-economic concerns, only the safety of pedestrians and cyclists was considered through the relocation of pedestrian bridges. The environmental approval also mentioned this condition along with ensuring the safety of workers and pedestrians during the construction phase. The dispute over the number of trees to be cut was attempted to be resolved by joint counting of the EIA consultant and the representative of an active NGO. Possible spatial impacts of permanent changes of land use from green to grey and from brown to blue could not get attention of the proponent or the EPA at the time of the decision on the EIA. Recently, the concerned building and development 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 those were just discussed in the EIA. There does not appear to be any genuine attempt to consider those alternatives. The nal decision regarding environmental approval for this project was subject to 19 conditions. Eight conditions were project specic and the rest were of a general nature pertaining to environmental protection during construction and operation phases of the project. Specic conditions were quite different from the routine. For instance, construction of a new road and ve yovers/underpasses at various junctions with roads located at the middle and end points of road widening sections. These projects were already included in the future plan of the proponent for overall improvement of trafc ow in the central and other parts of the city. Other specic conditions for this project were important, especially as the proponent was advised to

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constitute an EMP implementation committee, making all potential stakeholders members. 6.9.3. Industrial estate EIA The EIA report of the industrial estate project was rejected by hearing participants and the concerned EPA, based on a lack of information on several components of baseline conditions and potential impacts. The Federal EPA also took note of the inadequacy of the EIA report and suggested substantive improvements. The proponent prepared a new EIA report considering most of the concerns related to environmental impacts, but potential socio-economic impacts remained poorly addressed. Eight out of thirteen concerns relating to environmental impacts were considered in the revised EIA report. Most of the concerns were incorporated in the nal decision/conditions of approval (Table 4). Concerns pertaining to socio-economic and physical impacts and the project's location being very close to residential settlements were not considered. The reason, as pointed out by some of the interviewees was that, on the choice of industrialists, a highly accessible fertile land on the outskirt of a major city was forcefully occupied by declaring it partially barren. While the EIA report was being revised, the EPA could not stop construction activities at the project site due to very high political patronage for the project. This implies that alternative sites were not given due consideration. The decision of environmental approval for the construction phase contained 11 conditions. Only 4 conditions were project specic and 7 were of a general nature. Specic conditions mainly suggested making arrangements for treating wastewater and environment friendly management of solid waste of individual units and ensuring installation of air pollution abatement equipment etc. Concerned ofcials of the proponent agency stated that all of the conditions were technically and nancially achievable, though some are very expensive. However, they stressed that we have to do it. 6.9.4. Cement factory EIA Many concerns regarding possible environmental and socioeconomic impacts of the project were raised during the public hearing. But neither the EIA report nor the nal decision/environmental approval gave adequate consideration to those concerns (Table 5). The report stated that there will be no adverse impact on the population and environment around it because of environmental management measures. Gaseous emissions of CO, SO2, NOx and PM10 and noise levels will remain within the National Environmental Quality Standards of Pakistan. Similar to the case of industrial estate, land required for the factory was procured at present location and construction activities continued prior to EIA approval and even without planning permission. The letter conveying the decision of EPA on this project was unique as it looked more like a No Objection Certicate (NOC) than an environmental approval. It mainly stated that as the concerned District Government did not declare negative areas for industries which is its legal responsibility, the concerned EPA had no objection on the construction of the cement factory at its proposed site. In the approval letter there were no general or specic conditions, as imposed in the approval of the other three cases. Rather, the proponent was directed to submitting documentary evidence to substantiate the type and quality of machinery and a plan to address resettlement issues which may arise due to project activities. The proponent was further directed to discharge his liabilities under the Pakistan Environmental Protection Act 1997 and rules/regulations framed thereunder. 6.10. Stakeholders' satisfaction with the nal decision Overall, the results point towards some dissatisfaction with the nal decision taken in all case studies. This is indicated by the negative index of satisfaction in Table 6. 75% of the interviewees of the cement

factory project were not satised due to concerns regarding an inappropriate location of the factory neither being considered in the EIA report nor the nal decision. Despite the environmentally fragile nature of the project area and loss of livelihood of hundreds of families and some associated severe social and health impacts on 27000 people, the EPA granted environmental approval. The main reason appears to be the government's priority of economic development through promotion of industrial activities. 69% of the interviewees of the industrial estate project did not agree with the nal decision of allowing this project at its current location. The satisfaction level of those interviewees who had participated in the public hearing was comparatively higher than that of the non-participants. However, most of the participants were environmentalists or interested stakeholders who did not belong to the directly affected communities. 91% of those interviewees not participating in the public hearing, but belonging to the directly affected communities were not satised with the nal decision. These people were all facing environmental and socio-economic impacts of the project along with loss of land. Also, they were not aware of the conditions of environmental approval/mitigation measures. Regarding the road projects, about half of the interviewees were dissatised and did not accept the environmental approval of these projects by the EPA. They were of the view that both projects were unnecessary and that they will bear more environmental costs than resulting in economic benets. Interviewees of the motorway project complained that alternative routes and widening of the existing highway link were not given adequate consideration. Almost all of the hearing participants interviewed suggested that instead of widening the canal road by cutting thousands of mature trees and thus destroying an urban forest, the government should provide efcient and sufcient public transport and improve alternative roads. Moreover, for both road projects, hearing participants felt that their concerns had no impact on the nal decisions. This was the case because the conditions of environmental approval and suggested mitigation measures were not conveyed to the stakeholders, indicating a lack of communication among the decision makers and the affected and interested public. Slightly less than half of the interviewees who were satised with the decision of granting environmental approval to the motorway and road widening projects believed that these would ultimately prove benecial in terms of better accessibility and a rise in property values. Furthermore, they thought that these projects would bear more transport benets than adverse environmental impacts.
Table 6 Stakeholders' satisfaction with the nal decision. Project name Level of satisfaction Nature of involvement/ participation NonHearing participant participant (percentage) (percentage) Satisfactory Acceptable Unsatisfactory Total Road Satisfactory widening Acceptable Unsatisfactory Total Industrial Satisfactory estate Acceptable Unsatisfactory Total Cement Satisfactory factory Acceptable Unsatisfactory Total Motorway 8 17 75 100 0 9 91 100 17 25 58 100 13 0 88 100 22 13 65 100 18 55 27 100 9 0 91 100 11 5 84 100 Satisfaction Overall satisfaction index (percentage)

17 14 69 100 9 32 59 100 11 9 80 100 11 3 86 100

0.52

0.50

0.69

0.75

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

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6.11. Transparency of the decision making process (10) Interviewees of all four case studies stated that they were not provided with the opportunity to see any minutes of public hearings. Interviews of concerned ofcials from the EPA conrmed that people were not provided access to see the minutes of public hearings, which is considered condential. However, in 2007, the Federal EPA started posting proceedings and photographs of public hearings for EIAs of projects in its jurisdiction on its website (see http://www.environment. gov.pk/). It is the responsibility of the concerned EPA to consider public concerns while making decisions. The majority of the interviewees were not aware of how their input was used. Also, they did not know what the nal decision or the conditions of approval were. The ofcial point of view is that informing and satisfying every stakeholder would lead to no project being approved. Rather, every effort should be made to ensure that public concerns are incorporated in project designs and conditions of approval. Anybody visiting the EPA ofce for this purpose would be verbally informed about how the stakeholders' concerns were considered and how some of the concerns were incorporated in the conditions of approval (nal decision). Theoretically, public consultation and participation that take place during the preparation and review of an EIA report should lead to building trust in government institutions and proponents (Beierle and Cayford, 2002; Hartley and Wood, 2005; Petts, 1999). However, evidence from the case studies suggests that involving the public in EIA related decision making had failed in fostering trust in government institutions and in project proponents, mainly because concerns were largely ignored and the decision making process remained intransparent. Nevertheless, some participants felt that consultation was partially helping in building trust in the competent authority and in proponents. These particularly included the motorway and industrial estate projects interviewees. 7. Conclusions and recommendations Public participation is an important part of EIA. It has elevated EIA from a mere technical exercise for the conservation of natural resources to a political tool of environmental planning and management. However, EIA practice around the globe suggests that the overall inuence of public participation on EIA related decisions is still weak, particularly in developing countries. It is comparatively more effective and transparent where it is mandatory/initiated early in the EIA process (during scoping) and where review is done by independent experts. Furthermore, there is a need to consistently evaluate the performance and effectiveness of public participation in EIA, keeping in view the country context in which it operates. Such evaluation can possibly help to identify deciencies of current practice and measures to improve effectiveness. For this purpose, an evaluation framework was developed for Pakistan. This paper has demonstrated that by using the evaluation framework (Table 1), effectiveness of public participation and its inuence on EIA related decisions can be assessed. The framework evaluated 40 attributes of public participation in EIA of four selected projects from the province of Punjab, Pakistan, including a motorway scheme, a road widening scheme, an industrial estate and a cement factory. Main ndings include:

It is pertinent to note that in both cases, the public hearings were held in a fair and non-aggressive manner. Whilst direct affectees did not attend, NGOs and environmentalists appear to have represented them well. In addition, the proponents of both projects had employed qualied environmentalists. Overall, it is found that the type of project is not directly related to participation effectiveness or with the inuence of public participation in decision making. Overall, projects have demonstrated a weak inuence of public participation on the substantive quality of the EIA and the nal decision. The main reason is a failure to involve stakeholders early in the EIA process and adequately addressing concerns before irreversible decisions regarding the project site and its procurement are made. There was lack of communication as well as access to information between the EPA and stakeholders. This was identied by interviewees as a cause for a lack of transparency in the decision making process and also trust in the EPA and the proponents. Regarding stakeholders' roles during public hearings, technical experts and NGOs appear to be able to inuence outcomes of public hearings more positively than direct affectees, mainly due to often non-technical and sentimental objections of the latter. Thus, contrary to some suggestions in the literature that the wider the general public takes part the better it could be argued that good representation by a third party may actually be preferable. The research underlying this paper identied a direct relationship between the presence of qualied environmentalists and positive outcomes of the project in terms of an improved EIA report and better nal decision, at least from a public's point of view. Overall, the EIA public participation process in the country can be said to have achieved the establishment of a more egalitarian environment and sufcient time for submitting written comments on EIA reports and raising concerns during public hearings. More importantly, public consultation was signicantly contributing to educating the participants, thus fullling one of its objectives. This was also explained by a high level of awareness about a project's potential impacts and mitigation measures among the hearing participants. Whilst the literature suggests that there is often a general apathy and lack of willingness to participate in EIA, both, in developing and developed countries, the public in Punjab province appear to be highly willing to contribute. There is therefore a great potential for an active public involvement in EIA of projects. It can thus be concluded that public participation in EIA is gaining grounds in Pakistan.

The EIA public participation of the motorway project performed better compared with the other three projects. Since affected communities were consulted before the project design was nalized during EIA, many public concerns were incorporated. On the other hand, the industrial estate establishment project was positively perceived despite holding public consultations only after the site was selected and construction activities had started. This is mainly because its EIA report was revised and most of the mitigation measures suggested by the hearing participants were incorporated.

The results of this research suggest that public participation should be held before detailed EIA studies, since in the case study projects, particularly for industrial establishments, key decisions regarding site selection and their procurement along with detailed project design were already made. Most of the concerns by the stakeholders were related to an inappropriate location of the projects. Practically speaking, once the site is procured and construction work is started, it is extremely difcult to relocate the project as a result of EIA. Involving the concerned public before and during EIA studies can accrue signicant benets as compared to those of public hearing at the EIA review stage. Specic measures for improving the public participation process and practice in Punjab and the overall EIA system in Pakistan are subsequently recommended. 1. Legal provisions for public consultation and participation should be strengthened by making it mandatory before site selection and EIA studies 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 it to a wider public during review, an initial environmental examination (IEE) report should be presented to the concerned Municipal

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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, academics and concerned ofcials, as suggested in Fig. 1. The IEE, being a preliminary assessment of potential environmental impacts, as suggested in the GoP (1983) and the PEPA (GoP, 1997), will help identify the need of a detailed EIA and issues to be included (scoping). This will allow a comprehensive coverage of signicant environmental and socio-economic impacts of proposed projects and 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 guidelines for scoping, the wider public preferably belonging to direct affectees must be consulted during EIA studies and their concerns are to be incorporated. There will be no need of a 2nd hearing, if the initial hearing reports and video recording of consultations done at the EIA preparation stages are presented during the EIA review, provided it is done by a panel/committee comprising independent experts, representatives of direct affectees and EPA ofcials. The review panel may summon a post EIA hearing, if it is deemed necessary, keeping in view the sensitive nature of a project or if it potentially involves massive displacement of people. 2. To get the maximum public input and lessen potential opposition to a project, the information provided in the executive summary and the EIA report must be comprehensive and comprehensible to the stakeholders. It is recommended that the executive summary should be written in non-technical language with an Urdu translation. Furthermore, it is suggested that every chapter of the EIA report should also include its non-technical summary and an Urdu translation of the summary. There is also a need to develop EIA review criteria with a clear grading system, similarly to the hierarchical review framework suggested by Lee and Colley (1992). 3. The environment is a specialized profession and only few professionals currently involved in EIA do not possess the required expertise. No one can understand the importance of EIA better than a qualied environmental planner. Therefore, it is necessary

that the proponent organization should be required to employ at least one qualied environmental planner/manager (depending upon the project size) to coordinate the EIA process. 4. EIA reports should be placed at the TMA ofces or at the Union Council (UC) Ofce where the project is located within the jurisdiction of one UC, and a PDF (portable document format) version at the website of EPA, in addition to current practice of placing it in the libraries for public review. In addition to the legal requirement of publishing the notice/invitation in newspapers for submitting written comments and participation in hearings, representatives of real stakeholders should be directly invited. 5. To improve communication between the EPA and stakeholders, dissemination of minutes of consultation proceedings as well as the nal decision, the internet and notice boards at the TMA, EPA along with the ofces of concerned agencies should be used. Also, decisions need to be directly conveyed to representatives of stakeholders from all categories.

Acknowledgments This paper is based on the Ph.D. research thesis on public participation in EIA of development projects in Punjab, Pakistan by Obaidullah Nadeem. He worked on a part of this research as a fellow at the Department of Civic Design, the University of Liverpool, UK. Thanks to the University of Engineering & Technology, Lahore and the Higher Education Commission of Pakistan for providing the funding and necessary support for this purpose. Research facilities and cooperation extended by the Department of Civic Design, the University of Liverpool and the views of Dr. Urmila Jha Thakur are also acknowledged. Special thanks to Dr. Rizwan Hameed, professor at the Department of City and Regional Planning, UET, Lahore, for his in-depth and useful comments as an internal supervisor of the Ph.D. research. We would also like to thank EPA ofcials and all the interviewees of the case study projects for giving their valuable time.

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