The role of and challenges facing non-governmental organizations in the environmental impact assessment process in Punjab, Pakistan

ABSTRACT

Considering the ineffective environmental impact assessment (EIA) process and limited public participation, it is important to evaluate the role played by informal regulators like Non-Governmental Organizations (NGOs) in EIA in raising the voice of communities and promoting sustainable development. This study aims to identify the NGOs that are involved in the EIA process in Punjab. It also aims to evaluate how effectively the NGOs play their roles as watchdog, information provider and pressure group as well as discuss the challenges they face in EIA. Semi-structured interviews are used as a data collection method. Results of the study revealed that very few NGOs are involved in the EIA process. The role of NGOs as watchdog is not prominent because they are rarely involved in public participation and scoping. Only one international NGO has played a key role as an information provider. Some local NGOs functioned as pressure groups against environmentally damaging development projects. The key challenges faced by NGOs include lack of financial and technical resources and support from the state and society.

KEYWORDS:

• Challenges
• EIA
• NGOs
• Pakistan
• roles

1. Introduction

Pakistan is facing serious environmental problems despite the introduction of Environmental Impact Assessment (EIA) in 1983, a decision-making tool to achieve sustainable development. The estimated annual cost of environmental degradation to the country’s economy is over 365 billion PKR (2.3 billion USD approx. as 1 PKR = 0.0063 USD) (Government of Pakistan 2018). Thus far, the agencies responsible for EIA implementation in Pakistan have not been successful. Punjab, in particular, is facing various problems that lead to ineffective EIA. These concerns include insufficient capacity of the Environmental Protection Agency (EPA), poor public awareness and participation, low commitment of proponents, unprofessional consultants, absence of a transparency mechanism and bias/corruption in decision-making (Nadeem and Hameed 2008a, 2008b, 2010; Nadeem and Fischer 2011; Saeed et al. 2012; Shah 2013; Fischer and Nadeem 2014; Saif et al. 2015; Khan et al. 2018). Given the difficult financial situation of the country, the government is struggling to effectively implement EIA regulations and solve these complex problems alone. In developing countries such as Pakistan where enforcement is weak, informal environmental regulators complement formal regulations. Such informal regulators include the actions of citizens and non-governmental organizations (NGOs) (Li et al. 2018).

Although exceptions exist, in many developing and under-developed countries, public participation in EIA is generally not institutionalized and is thus limited (Tang et al. 2005). Limited participation in these countries may be attributed to illiteracy, limited knowledge, passive attitudes of individuals, lack of female participation, remoteness of public participation venues, poor communication and transportation facilities and limited project information (Tang et al. 2005). In countries like India, Bangladesh, Armenia, Guatemala, Kenya, and South Africa, these barriers lead to the emergence of NGOs that aim to help the communities raise their voice and participate effectively in EIA (Tang et al. 2005; Tang and Zhan 2008; Bull et al. 2010; Chi et al. 2014). NGOs in such countries are usually not consulted during the EIA process and are also not strong enough in terms of the availability of resources. They mostly operate in case of mega or donor-funded projects. In the case of developed countries where EIA systems are mature, such as the UK, USA, Canada and the Netherlands, stakeholder participation is institutionalised. Consequently, NGOs are consulted throughout the EIA process and have access to resources to play their part. We will discuss the individual examples throughout this paper according to their relevance to the context.

1.1. Role of environmental NGOs

Environmental NGOs operate in various ways. They may participate in policy-making or decision-making or lobby the environmental policymakers as reported for Poland, Hungary, Slovakia and Romania. Alternatively, they can persuade the government, the public or businesses to use environmentally friendly technologies (Borzel and Buzogany 2010; Zvijáková et al. 2014; Li et al. 2018). Social movements in various countries are known to criticize and influence the development plans of governments, including Chipko Movement in India in the 1970s and the nation-wide environmental justice movement in South Africa in the 1990s (Lund-Thomsen 2004; McDonald 2004; Pande 2018). Environmental NGOs have also been reported to enforce regulations in Iran (Moghimi and Alambeigi 2012). For instance, an NGO named BoomIran pressurized the government to stop an environmentally damaging project that would drain Anzali Lagoon on the Caspian coast. Another NGO, Mountain Environment Protection Committee, is working to protect the mountains because the government failed to enforce laws for mountain protection (Foltz 2001). In Thailand, NGOs are integrated with the central governance institutions and work parallel with the National Environmental Board to ensure community participation and environmental protection. They are also made part of the expert review committees on EIA (Janya 2007; Wells-Dang et al. 2016; Hasan et al. 2018).

1.2. Role of NGOs in the EIA process

NGOs play various roles in the EIA process. They either carry out the EIA process themselves or act as facilitators for the government. For example, NGOs in Japan have conducted various EIA studies, including a waste landfill project in Fujimae-higata, a redevelopment project in Tokyo and land reclamation on the Awase Tidal Flats in Okinawa City (Hasan et al. 2018). Similarly, in Singapore NGOs have conducted EIA studies with the government on various projects such as the National Waste Management Plan, National Nature Conservation Plan and Golf Course Development Project (Hesp 1995). In Myanmar, an NGO named BANCA carried out an EIA of Myitsone dam, and another called EcoDev conducted an EIA of a mining project in Dawei (Wells-Dang et al. 2016). In Hungary also, NGOs have been involved in conducting EIAs. For example, the Roma Civil Rights Foundation was involved in the EIA of a hazardous waste incinerator at Grace. In addition, Bedola Nature and Environmental Protection Association in Liter was involved in an EIA study of Liter Secondary Reserve Power Plant, while Air Action Group was involved in an EIA of M5 Motorway Project in Orkney (Palerm 1999; Briffett et al. 2003; Hasan et al. 2018).

Apart from conducting EIAs, NGOs in various countries such as Malaysia, Denmark, USA and Papua New Guinea, are also involved in reviewing the assessments. For instance, an NGO in Denmark named Danish Association for Conservation of Nature reviewed the EIA report prepared for a highway project from Arhus to Herning. In the USA, NGOs were involved in reviewing an EIA of an aquaculture project in the state of Maine (Hasan et al. 2018). In Papua New Guinea, an NGO reviewed the EIA report for a mining project related to polymetallic sea sulphide deposits (Durden et al. 2018).

NGOs likewise act to disseminate EIA related information and ensure public participation as reported in the USA, Thailand and African countries, including Nigeria, Angola, South Africa, Kenya, Namibia, etc. (Kakonge 2006; Okello et al. 2009; Hasan et al. 2018). In China also, NGOs improve the level of public participation in EIA (Wu et al. 2017). For instance, the Institute of Public and Environmental Affairs (IPEA), an NGO established in 2006, commits to promoting openness of information to the public and consequently ensures public participation in EIA. It develops maps indicating water contamination, air pollution and pollution enterprise in China to enhance information access to the public (Hasan et al. 2018; Li et al. 2018). NGOs should also be involved in the development of EIA legislation or policy. Such was the case in Pakistan where NGOs were invited to seminars and consultative meetings to solicit their comments prior to the approval of the Pakistan Environmental Protection Act (PEPA) 1997 (Fischer and Nadeem 2014). This practice is either completely absent in many countries such as Yemen and Georgia, or exists partially in certain countries such as Ghana, Cambodia and Myanmar (Kolhoff et al. 2013; Wells-Dang et al. 2016).

Environmental activism is generally limited in Pakistan, especially in the case of ordinary projects where people do not approach courts or contest the EPA’s decisions (Khan et al. 2018). However, in the case of mega projects, a few examples do exist in Punjab, where NGOs have sensitised and mobilised affectees to raise their voices. Lahore Ring Road, Lahore Canal Widening and a few other projects will be discussed as examples later in this paper (Nadeem and Fischer 2011; Fischer and Nadeem 2014). In Pakistan, no research has so far been conducted to evaluate the extent of the role played by NGOs in the EIA process and the challenges that they face. The present study attempts to fill this gap. We will use the criteria established by Ryu et al. (2004) (Table 1) to demonstrate the role of NGOs in the EIA process in Punjab. We will also present the challenges faced by NGOs in playing their roles. Roles and challenges will be supplemented with examples from different countries either facing the same issues or with better influence or involvement of NGOs in EIA.

Table 1. Criteria for evaluating the role of environmental NGOs in the EIA process.

S.no.	Role	Description
1.	As watchdog	Monitor the EIA process and reports Attend explanatory, monitoring, investigatory and other public meetings
2.	As an information provider	Provide environmental information based on their surveys
3.	As a pressure group	Act as a pressure group to influence other bodies and ensure that the EIA is properly conducted

Source: Ryu et al. (2004)

The province of Punjab is chosen as the study area because it is the largest province of Pakistan in terms of population and economy. Table 2 shows the comparison of population by province according to provisional summary results of the 2017 Population and Housing Census. Punjab has 7 major industrial zones and 21 small industrial zones which together account for 60% of the annual goods and services produced by the country (Government of Punjab 2018a, 2018b). Punjab has the highest contribution to the GDP of the country, i.e. 53% (Mumtaz et al. 2019). The EPA of Punjab receives the largest number of EIA cases per year amongst all the provinces. A total of 347 cases were submitted to all EPAs between the years 2000 and 2008. Of this number, 202 cases were submitted to Punjab EPA. We find a similar trend for the years 2016 and 2017 (Nadeem 2010; Khan et al. 2018). Table 3 shows a comparison of the EIA cases submitted in different EPAs of Pakistan in 2016 and 2017.

Table 2. Comparison of population by province in Pakistan.

Administrative unit	Population (million) 2017 census
Pakistan	207.77
Punjab	110.01
Khyber Pakhtunkhwa	30.52
Sindh	47.89
Baluchistan	12.34
Islamabad	2.00
FATA	5.00

Source: Government of Pakistan (2017)

Table 3. EIA cases submitted in different EPAs of Pakistan during 2016 and 2017.

	No. of cases submitted
Environmental protection agency	Year 2016	Year 2017
Punjab EPA	130	123
Baluchistan EPA	6	5
Khyber Pakhtunkhwa EPA	27	17
Federal EPA	12	5
Sindh EPA	69

Source: Khan et al. (2018)

This paper is divided into four sections. Section 1 is the introduction. Section 2 presents the methodology adopted for the study. Section 3 provides the results and discussion. Section 4 draws conclusions.

2. Methodology

The three types of environmental NGOs in Punjab are government-established NGOs, NGOs founded and run by private citizens and internationally funded NGOs. The Punjab Environmental Protection Act (Amended 2012) enjoins the EPA to ‘encourage the formation and working of non-governmental organizations, community organizations and village organizations to prevent and control pollution and promote sustainable development’ (Government of Punjab 2012). Owing to this directive and the increasingly complex environmental problems faced by Punjab, the Punjab EPA provided NGOs small grants ranging from 100,000 PKR to 300,000 PKR (approx. 620–1870 USD) in 2011–2013. The goal was for the NGOs to implement environmental improvement projects at the community level under the project ‘Community based Environmental Improvement’ sponsored by the Environment Protection Department. The grants were provided to NGOs already registered under any of the following ordinances/laws: The Trust Act 1882, The Voluntary Social Welfare Agencies Registration and Control Ordinance of 1984, The Cooperative Societies Act of 1952 and The Societies Registration Act of 1860. The project aimed to enhance public participation and awareness and improve the environment (Government of Punjab 2013). Under this project, grants were provided to about 150 environmental NGOs in Punjab (Personal communication with EPA Punjab) to implement projects in the following areas: sewage and municipal solid waste collection and disposal, supply of drinking water, tree planting campaigns, environmental awareness, and other emerging environmental issues. They were supposed to complete their projects within 4 months after receiving the funds from the EPA and submit monthly progress reports to EPA Punjab. The EPA was bound to inspect and evaluate the project during its execution up to a year after completion. Moreover, if it found that funds were not properly utilised, it would recover the amount from the NGOs (Government of Punjab 2013). During our personal communication with EPA Punjab, we were told that District Officers thoroughly evaluated the projects after their completion. The types of projects undertaken by NGOs under this programme in various districts of Punjab included installation of solar lighting system and bio-gas plants, awareness-raising and tree planting campaigns. However, the themes under which NGOs were supposed to undertake projects in this programme did not include EIA. Thus, these NGOs were not relevant for the purpose of this study.

We found no record of registered environmental NGOs working specifically on EIA, which is the scope of the present study. In the first step, through web search, we found name and evidence of one NGO involved in EIA in Punjab and interviewed them. Further, snowball sampling technique as also used by Dillon et al. (2018), where one interviewee referred us to another (Banerjee and Chaudhury 2010), was used to identify other NGOs. This snowball sampling accompanied by extensive web search including sources such as websites, blogs, press releases and judicial decisions, etc. and also by going through public hearing records and meetings with EPA officials helped us identify 171 NGOs throughout Pakistan with environment as sole or one of the areas in their scope of work. The different sectors of environment in which they are playing their role include but are not limited to natural resource management, drinking water supply, sanitation and hygiene, emergency preparedness and response, flood relief, tree plantation, environmental education/awareness and environmental impact assessment.

In the second step, the scope of work, activities and projects undertaken by these NGOs were thoroughly explored and out of these 171 NGOs, 28 were found to be involved in EIA either directly or indirectly out of which 13 were based in Punjab. For NGO selection, our criteria was that they should be involved in the EIA process through any of the following ways: as conductors of EIA, as reviewers of EIA, as facilitators of EIA, as pressure group or civil society activists or as stakeholders in EIA legislation or policy-making or in any other way.

In the third step, we carried out interviews of the 13 Punjab-based NGOs to identify their role and challenges in the EIA process. Some of the NGOs were found to be currently involved in EIA either directly or indirectly and some claimed that they were involved until few years back but not anymore. The reasons for those not being involved any more will be discussed in the results section. The interviewees also referred us to seven more environmental NGOs in Punjab which were also interviewed but were not found to be involved in EIA. Thus, the total number of NGOs interviewed were 20 (including 15 local, 3 national and 2 international). The results of the interviews gave interesting insights on how NGOs directly or indirectly involve in EIA, why some NGOs were involved in EIA in some way in the past but then stopped doing so and also why some of them do not get involved ever. The NGOs interviewed were spread in various cities of Punjab province such as Lahore, Rawalpindi, Muzaffargarh, Lodhran, Multan, Sargodha, Layyah, Mianwali, Kot Addu and also federal, i.e. Islamabad-based NGOs involved in EIA in Punjab and other provinces. We interviewed a total number of 30 respondents. Table 4 presents a brief on the NGOs interviewed and number of respondents from each NGO. The article also presents examples of three additional NGOs that were not interviewed but were identified though desk studies to be involved in EIA in Punjab. These were based in Jhelum, Lahore and an Islamabad-based NGO carrying out EIA related projects in Kasur and Attock districts of Punjab.

Table 4. Brief description of the NGOs interviewed.

S. no.	Organisation name	City	Local/national/international	Year of establishment	Scope of work	No. of people interviewed	Involved/not involved
1.	Lahore Conservation Society (LCS)	Lahore	Local	1984	Heritage conservation and environmental protection	3	Involved
2.	SIMORGH	Lahore	Local	1985	Women resource publication and environmental protection	2	Involved
3.	Park Bachao Tehreek	Lahore	Local	Not a registered organisation. It was a movement that started in 2012	Environmental conservation	2	Involved
4.	National Cleaner Production Center-Foundation (NCPC-F)	Rawalpindi	National	1999	Cleaner production and environmental protection	2	Involved
5.	World Wide Fund for Nature (WWF)	Lahore	International	1970	Environmental conservation	2	Involved
6.	International Union for Conservation of Nature (IUCN)	Islamabad	International	1985	Nature conservation	3	Involved
7.	Awami Development Organization	Layyah	Local	1996	Social welfare	1	Involved
8.	Ghazi Barotha Taraqiati Idara: GBTI	Islamabad, Attock	National	1995	Community welfare: resettlement and compensation	2	Involved
9.	Green Circle Organization	Lahore	National	1990	Food security and environment	1	Involved
10.	Ufaq Development Organization	Multan	Local	2002	Social welfare and environment	1	Involved
11.	Zafar Memorial Foundation Mianwali	Mianwali	Local	2000	Social welfare and environment	1	Involved
12.	Majlis- e- Tahaffuz- e- Maholiat	Sargodha	Local	1996	Environmental protection	1	Involved
13.	Pakistan Green Task Force	Rawalpindi/Islamabad	Local	1998	Environmental conservation and protection	2	Involved
14.	SabzAas	Lahore	Local	2014	Tree plantation and environmental sustainability	1	Not involved
15.	Al-Shajar	Lahore	Local	2015	Environmental conservation	1	Not involved
16.	Afforestation Lahore	Lahore	Local	2019	Tree plantation	1	Not involved
17.	SANJH-Society for the advancement of nature, justice and health	Muzaffargarh	Local	1975	Social welfare and environment	1	Not involved
18.	Lodhran Pilot Project	Lodhran	Local	1999	Community welfare and sustainable development	1	Not involved
19.	Jaago Welfare Society	Kot Addu	Local	2003	Social welfare and environment	1	Not involved
20.	Doaba Foundation	Multan	Local	1987	Social welfare, community development and environment	1	Not involved

Following Fagan and Sircar (2010), the present study employed semi-structured interviews as a data collection method. Interviews with the representatives of 18 NGOs were carried out over the phone and with the representatives of two NGOs in person in two phases, i.e. between October 2018 – December 2018 and in October 2019. We conducted the interviews in an opportunistic manner; specifically, we followed no particular order but relied on the availability of the interviewee.

The interview questions basically revolved around the following themes: the role played by NGOs in the EIA process in terms of public consultation or participation, environmental research or information sharing and direct or indirect actions/protests; challenges in terms of resources, support from society or government and difficulties in mobilising the public and reasons for not participating. Interview questions have been added as supplementary material to this paper. The interview questions were modified to suit the needs of each interviewee rather than using the same questions for each individual. All interviews lasted for 30 min to 1 h. The interviewer informed the respondents about the study objectives before the interviews commenced. The interviews were transcribed to maintain a record of the original statements of the interviewees. Following Kågström (2016) analysis of the interviews was done by reading the transcripts repeatedly and marking the quotes of interest. Relevant data from transcripts was categorized into themes explaining the role of NGOs in the EIA process and the challenges they faced.

3. Results and discussion

In this section, we present the role played by NGOs in the EIA process in Punjab and the challenges they face in doing so. The original voice of interviewees is presented in this section in inverted commas.

3.1. Role of NGOs in the EIA process of Punjab

3.1.1. As a watchdog

As a watchdog, NGOs are expected to monitor the EIA process and reports and attend explanatory, monitoring, investigatory and other public meetings (Ryu et al. 2004). The EIA process has four steps in which NGOs can play their role as a watchdog: scoping, IEE/EIA report reviews, public hearings and EIA follow-up.

Formal scoping is rarely carried out by consultants/proponents in Punjab. It is normally done by the consultants in their own office without any public consultation (Fischer 2014). However, in recent years, some scoping workshops have been conducted mainly for mega projects that involve international funding. For instance, in 2018, a series of national scoping workshops were conducted for the Environmental and Social Impact Assessment of the 1,814 km long Turkmenistan-Afghanistan-Pakistan-Iran (TAPI) Gas Pipeline Project. This project was funded by the Asian Development Bank in four cities, that is, Karachi, Quetta, Islamabad and Lahore. Another scoping workshop was conducted in 2018 for the Environmental and Social Impact Assessment of the 800 km long North South Gas Pipeline Project funded by Russia. In such workshops, public and NGOs are invited and the proceedings are video recorded to present as an evidence to the funding agency (Fischer 2014). Representatives from WWF and IUCN told us the following:

‘Although rarely, sometimes we are invited to attend the scoping workshops to give our inputs. Since scoping is done at an early stage of the project, there are better chances that our inputs/concerns are addressed as opposed to public hearing which is done at a much later stage in the process’.

The situation is similar in many other developing countries, e.g. in Egypt, NGOs are only consulted in case of donor funded projects because public consultation is not a mandatory requirement in the legislation (Ahmad and Wood 2002; Badr 2009; Badr et al. 2011). In the Maldives, scoping is carried out between consultants and developers, ministries or government departments without the involvement of civil society (Zubair et al. 2011). In China, project proponents used to avoid face-to-face communications with NGOs to prevent any opportunity for public opposition. However, the situation is improving now (Brombal et al. 2017; Wu et al. 2017).

NGOs are rarely involved in scoping in Punjab because public participation at this step is not a mandatory requirement in Punjab’s environmental protection laws. According to Regulation 10 of the IEE/EIA Regulations 2000, public participation is mandatory at the EIA review stage and not at earlier stages, such as screening and scoping or even at later stages like follow-up (Government of Punjab 2000). The EPA’s guidelines for public consultation, however, suggest that all the stakeholders should be involved whilst determining the screening and scoping (Government of Pakistan 1997). In developed countries, such as the USA, the Netherlands, Canada, and the UK, public and concerned agencies are involved during screening and scoping (Fischer 2014). In Flanders and Russia also, NGOs are involved at the scoping stage of the EIA process (Gulakov and Vanclay 2019: Runhaar et al. 2019).

The second step of EIA in which NGOs can be involved is report reviews. Involvement of NGOs in report reviews is an uncommon practice in Punjab. The only NGO that claimed to have been involved in this step is the WWF. According to a representative from WWF,

‘In case of projects involving major impacts, the EPA invites us to review the reports. However, our comments are rarely addressed because if the EPA has decided to clear a project, it will do so no matter what we recommend’.

In China, the number of environmental NGOs aimed at enhancing public involvement in the EIA and promoting sustainable development is growing and NGOs are known to comment on the EIA reports (Tang and Zhan 2008; Wu et al. 2017). NGOs in Ethiopia have also been involved in commenting on reports (Asfaw et al. 2017).

The third step where NGOs can get involved is a public hearing. NGOs in Punjab do not attend public hearing meetings regularly. Even when they do attend, their participation is either not very active or their concerns are not given due attention by the proponents or consultants. According to a representative from Ufaq Development Organization,

‘We do participate in public hearings but rarely because our concerns are not addressed’

The reluctance of NGOs to get involved in public hearings has also been reported for Bosnia. Fagan and Sircar (2010) explain why some organisations hesitate to participate actively in public hearings. They feel that if they oppose a project for being environmentally damaging but it promises economic gains to the public, then the public will think of them as opponents of development in their area. Thus, they are reluctant to take an unpopular stance. NGOs in Finland are also blamed for being too idealistic and spreading false information about the environmental effects of projects (Saarikoski 2000).

Representatives from LCS, Park Bachao and SIMORGH shared:

‘Proponents bring their own people in public hearings who speak really loud in order to suppress our voices.’

‘Sometimes we attend public hearing meetings and give written recommendations to the proponent and consultant. Once the public hearing is over nothing happens and our mere presence is counted as support to the project. So we think it’s better to not participate.’

This case is the same in China, where the influence of NGOs in public hearing is limited. NGOs hesitate to take any action in favour of environmental protection to avoid confrontation with authorities. They feel it safe in only playing their role in public education and awareness (Wu et al. 2017). This was also mentioned by a representative from Doaba Foundation,

‘We work as an ally of government and avoid activities such as protests etc’.

A representative from Ufaq Development Organization mentioned that,

‘We cannot go against state activities so we avoid raising our voice’

The influence of national and international NGOs on EIA decisions is non-existent in Brazil as well (Glasson and Salvador 2000). However, NGOs do influence the EIA process in some way in certain countries. For example, in the UK, NGOs such as Friends of the Earth and the Council for the Protection of Rural England have developed training manuals and courses on ways to incorporate community participation in the EIA Hasan et al. 2018.

In addition to the above-mentioned steps, NGOs can also play their role in EIA follow-up. EIA follow-up is almost non-existent in Punjab which is one of the reasons for weak EIA effectiveness (Nadeem and Hameed 2010; Khan et al. 2018). According to a representative from Green Circle Organization,

‘I think NOC is only a formality in Punjab’

NGOs in Punjab were not found to play this role because they feel that this will not have any positive outcome. According to representatives of LCS, Park Bachao and NCPC-F:

‘EPA is not concerned about compliance monitoring and enforcement in Punjab, so we think our actions will also not have any outcome. Our concerns will simply be ignored’

3.1.2. As an information provider

One of the roles of NGOs in EIA is to provide environmental information including data on environmental laws and policies, flora/fauna, climate and socio-economic conditions of the area where the project is being proposed, based on their baseline surveys. This case is also the same in India, where environmental NGOs enhance the capacity of communities by increasing their awareness and consciousness through information regarding environmental laws and policies (Ryu et al. 2004; Paliwal 2006). Similarly, the National EIA Association of Bangladesh was established in late 1997 and has since been involved in multiple EIA related activities such as EIA trainings, seminars, publishing brochures, training manuals and EIA newsletters. This NGO has also assisted the government in developing of the EIA, formulating the code of conduct for EIA professionals and liaising between policymakers and professionals (Ahammed and Harvey 2004).

Consultants in Punjab can contact NGOs to receive data for baseline environmental studies including but not limited to, Geographic Information System maps, wind data, climate models and so on. Three NGOs, namely, NCPC-F, IUCN and WWF were found to play this role. Representatives from WWF and NCPC told us,

‘Consultants used to contact us for EIA related data a few years ago. However, this is not the case anymore because with the advancement of information technology everything is already available on internet’.

NGOs are sometimes contacted by consultants whilst carrying out social surveys for the EIA study, which includes discussing project acceptability and concerns of stakeholders. However, NGOs like LCS and Park Bachao mentioned that they were not satisfied with this consultation. According to a representative from LCS,

‘It is merely an eyewash because the social survey is not given due importance in the EIA process by the consultants.’

The International Union for Conservation of Nature has the most distinguished programme for environmental research and education, policy formulation, public awareness, and training. It was also involved in the formulation of the National Conservation Strategy (Aftab 1994). Under a joint initiative of the Government of Pakistan and IUCN, and supported by financial aid from the Embassy of the Kingdom of the Netherlands, a four and a half year National Impact Assessment Programme (NIAP) was carried out between 2009 and 2014. EIA mapping exercise was conducted throughout the country which included a series of workshops in which more than 150 EIA experts from various educational institutions, Federal and Provincial EPAs, the Higher Education Commission and, other public and private sector organisations were involved. This programme intended mainly to strengthen the EIA process in Pakistan and introduce a Strategic Environmental Assessment to contribute towards sustainable development. Its outcomes included the development of an EIA Handbook for Pakistan and an EIA Curriculum for higher education institutions in Pakistan. This programme also developed an accreditation system for EIA consultants that has not been implemented to date.

Another NGO named LEAD Pakistan also plays its role in terms of education and capacity development of stakeholders. As part of this, with the funding of Asian Development Bank, LEAD carried out a project titled ‘Assessing and developing capacity to improve participatory environmental management in selected (Kasur and Abbottabad) districts of Pakistan’. Main objectives of the project were to raise awareness and facilitate the vulnerable groups in getting access to information on environmental issues and access to participation in decision-making.

International NGOs such as WWF and IUCN also serve to provide information to local NGOs, e.g. SIMORGH and LCS whilst they take up cases in the courts. These NGOs do not generally possess ample environmental knowledge. According to a representative from WWF,

‘We provide them with environment specific knowledge and documents like relevant acts and so forth’.

3.1.3. As a pressure group

The role of NGOs as a pressure group is to influence other bodies and ensure that the EIA is properly conducted. Their role can also extend to protecting the interests of citizens. This situation has been reported for countries such as Kenya, Tanzania and Rwanda (Ryu et al. 2004; Marara et al. 2011). However, this role is public dependent because, unless a public incident occurs, NGOs find it difficult to get involved, as has been reported for China (Wu et al. 2017). In case of Punjab, this is a relatively prominent role that NGOs have played in the EIA process. In the following paragraphs, we mention some examples discussed by the NGOs during interviews and through literature review where the projects started either without any EIA or public concerns were not incorporated rightly in them and NGOs took a stand to protect the environment.

In 1991, United Welfare Association Lahore filed a writ petition in Lahore High Court against Lahore Development Authority (LDA) and owner of asphalt plants on the basis that they are posing health hazards to residents of Lahore and should be relocated. As a result, the DG LDA at that time ordered the plants to be relocated.

In 1994, West Pakistan Salt Mines Labour Union, Khewra, Jhelum filed a petition in Supreme Court against the Industries and Mineral Development, Punjab on grounds that Punjab Coal Mine Company’s coal mining activities in upstream areas were contaminating the water of the catchment area. The Supreme Court ordered such measures to be taken by the company to avoid contamination of water bodies.

In 2004, the Eastern Wing of the Lahore High Court (LHC) building was demolished overnight for expansion. The LHC building is an artefact from the colonial era and is listed as a protected building. Thus, no construction was legally allowed within the 400-yard vicinity. At this point, the majority of renowned architects in the region gathered for protests and demonstrations. The LCS played a pivotal and leading role in the protests. Along with other protestors, it gathered relevant data and sent these to the President of Pakistan who then ordered the LHC registrar to suspend the work and hold an inquiry. After 3 months, a suo moto notice by the Chief Justice of the Supreme Court led to the decision that all the debris should be used to reconstruct the building and restore it to its original conditions.

In 2006, the Punjab government decided to widen the Canal Bank Road Lahore from Thokar Niaz Baig to Jallo Park, a major environmental setback to the city. In this project, a 200-acre green belt had to be cut to construct the road. At this stage, LCS, whose original scope was heritage, widened its scope to the environment. To save the trees, LCS started a movement known as Darakht Bachao Tehreek (Save the Trees Movement) which was supported by other NGOs named SIMORGH, Green Circle Organisation and also some other environmental activists. Later, the name was changed to Lahore Bachao Tehreek (Save Lahore Movement). Demonstrations and protests by the environmental activists led the Chief Justice of the Supreme Court of Pakistan to take the suo moto notice. In 2011, after multiple hearings, the court directed the Punjab government and the EPA ‘to ensure that minimum damage is caused to the greenbelt and every tree that is cut is replaced by four trees of the height of 6–7 feet, and this replacement when commenced and completed should be notified through press releases for information of general public and the copies of that should be sent to the Registrar of the apex court’ (Fischer and Nadeem 2014). The Supreme Court's judgement declared the Canal to be an Urban Heritage Park and public trust. The Canal Heritage Act was also passed by the Punjab Assembly in 2013.

Similarly, affectees of the Lahore Ring Road project caused a section of the proposed project traversing through the Gulshan-e-Ravi housing scheme to be withdrawn. The Communication and Works Department of the Punjab government asked its consultants to design an alternative route of the section to avoid Gulshan-e-Ravi (Fischer and Nadeem 2014.)

Another prime example of protests and social activism is the movement by the locals of a town in Lahore to safeguard the parks and trees. In 2012, the Model Town Society's administration planned to convert three parks in the society into commercial areas. The residents of the society raised a protest that transformed into a full-fledged Save the Park Movement (Park Bachao Tehreek) as other NGOs, such as LCS and activists joined in. The case was taken to the EPA. After multiple hearings in EPA with no outcome, activists of the movement met the then Minister of Environment of Punjab who evaluated the case and issued a stay order.

Another example occurred in 2015, where the LCS filed a petition in the LHC against the ‘Signal free Corridor Project’ proposed and initiated by the Lahore Development Authority (LDA). The project was intended to redesign and remodel 7 km of existing roads from Qurtuba Chowk to Liberty Market Main Chowk, converting these into a high speed and signal free expressway. The petition was filed on the grounds that the construction was illegally initiated without approval from the EPA Punjab. LHC ordered LDA to stop the construction work and restore the roads to their original condition.

In 2015, the public and NGOs such as LCS and Park Bachao Tehreek protested the construction of an ‘Elevated Expressway from Gulberg to Motorway’ in Lahore. They stated that the land was illegally acquired from the people and that EIA approval was not granted before construction was started. Multiple petitions were also filed in the LHC following which LHC issued a stay order.

Similarly, in 2016, following a petition filed by LCS, the LHC ordered halting the construction works on ‘Lahore Orange Line Metro Train Project’ which was proposed by the government of Punjab. The train line was passing very close to several heritage sites in the city. Furthermore, an NOC for construction was obtained after the start of the construction. The project faced severe opposition from the public and NGOs.

Pakistan Green Task Force narrated that they protested against the cutting of trees for Metro Bus Project from Rawalpindi to Peshawar Mor in Islamabad. Another NGO named Ghazi Barotha Taraqiati Idara mentioned that they are working on the rights of poor and affected communities in district Attock of Punjab province due to the construction of Ghazi Barotha dam. The organization facilitates people in issues such as resettlement and compensation packages, etc.

The transgressive role of the public and NGOs in the EIA process has also been observed elsewhere. For instance, in Australia, the public used court action when they were dissatisfied by the assessment process for site selection of a nuclear waste disposal project. Furthermore, NGOs challenged the courts against attempts by the federal government to limit public participation in the EIA of a Red Chris mine project in British Columbia (O’Faircheallaigh 2010).

In Lao PDR, international NGOs drum up public to stand for or against a proposed activity and push for better planning and assessment. One example is the case of two hydropower projects, Theun-Hinboun and Nam Theun 2 (Wayakone and Makoto 2012).

NGOs and locals played an important role in approaching courts in Turkey against ‘Alakir Small Hydropower Plants’ whose construction started without the conduct of an environmental assessment. The court ordered the project to be suspended (Karakitapoglu 2015).

Environmental NGOs and activists in Armenia fight for transparency in decision-making because they believe the environmental authorities grant environmental approvals without appropriate public hearings. One example is the Toghut Mining case which was granted consent for construction by the Republic of Armenia (RA). NGOs alleged that the consent was in violation of the RA EIA law and thus approached the courts (Atoyan 2016).

In 2012, NGOs in Guatemala opposed a gold mine extraction project because of the environmental consequences of mining. People were not informed of the project prior to the allocation of an exploitation license by the Ministry of Energy and Mining. Following aggressive activism for 3 years including protests and court actions, the Guatemalan court ordered the construction activities to cease (Aguilar-Støen and Hirsch 2017).

In Slovakia, NGOs mobilised against an environmental permit issued for the development of a wind park with 88 wind turbines in Volovja reber (Rodela et al. 2017).

In the past few years, various lawmakers and organisations in Brazil proposed changes to impact assessment regulations and environmental licensing. Following these proposals, the Chamber of Deputies and the Senate presented reform bills for the EIA. Civil society organisations are concerned about the lack of public participation and transparency in the reform proposals. A civil society organisation named Instituto Socioambiental stood up against this lack of transparency and gathered signatures from 136 organisation who protest the bill (Fonseca et al. 2017).

An NGO in China found that a sewage treatment plant located 1 km upstream of a water supply facility was not meeting quality standards. They also found that the EIA report for the treatment plant was severely flawed. They took up the issue and informed journalists and representatives of Political Consultative Conferences. (Dai and Spires 2018).

3.2. Challenges faced by NGOs

The role played by NGOs in the EIA process of Punjab as watchdog and information provider is not particularly encouraging as discussed in Section 3.1. Moreover, their role as a pressure group is mainly limited only to one major city, i.e. Lahore. This may be because the government in power in Punjab for two consecutive terms from 2008 to 2013 and then from 2013 to 2018 focussed on the development of relatively developed districts of Punjab with Lahore getting the highest share of development expenditures per capita (Naveed and Khan 2018). As a result, major development projects were concentrated in Lahore and consequently NGO activism remained highest here. According to representatives from Lodhran Pilot Project and SANJH based in Lodhran and Muzaffargarh, respectively, both of which are small cities,

‘This is a small area with no major development projects so we focus on activities like awareness campaigns, seminars and tree plantations’

Also, some NGOs were formed after major events like floods or earthquakes in poor areas and then closed soon after. For example, according to a representative from JAAGO in Kot Addu,

‘We started this NGO after floods in 2010 but closed soon after’

Limited role of NGOs can be attributed to some more reasons that will be discussed in this section.

3.2.1. Lack of resources, awareness and scientific knowledge

The EIA process requires technical and legal knowledge along with administrative capacity. Having more significant involvement in the EIA process is natural for well-established organisations with many staff and large budget (Fagan and Sircar 2010). NGOs that have policy-related work as done by IUCN in Pakistan require a large budget because they need more sophistication in terms of administration. NGOs that have a low budget often have a more direct role, for example, through protests and demonstrations (Fagan and Sircar 2010). Local or national NGOs/movements such as LCS, Park Bachao Tehreek, Majlis-e-Tahaffuz-e-Maholiat, SIMORGH, etc. lack proper funding sources and operate on personal financial inputs of the founders/members. Representative from LCS told us,

‘LCS has no fixed funding source. We spend from our own pocket and we do not even have a bank account’.

In China and the Maldives also, NGOs lack human and financial capacities to play their role in standing up for regulatory changes or facilitating public participation and are thus typically involved only in small activities, such as conducting awareness sessions in schools (Zuhair and Kurian 2016).

International NGOs in Pakistan (e.g. WWF and IUCN) do get funding from international sources, but the amount they receive is for specific projects. Hence, their involvement in demonstrations, protests, and pursuing cases in the courts is strenuous because everything requires funds. According to a representative from WWF,

‘When you are receiving funds from international sources, you have to work on the agenda set by them.’

Different stakeholders use different forms of arguments in the EIA process, for example, consultants use scientific or technical arguments; EIA authorities use bureaucratic or technical arguments, while local organizations use social arguments. EIA is a technical process. Thus, the social arguments of environmental NGOs are marginalised in the EIA processes by the technical ones. Furthermore, these NGOs have a limited budget and thus cannot hire a consultant to read the technical documents for them and thus they cannot serve as a bridge between the public and the developer, as has been reported for Bosnia (Fagan and Sircar 2010). This was also reported by certain NGOs in Punjab during our survey. These NGOs do not know the exact procedure and time-lines they need to submit and raise their concerns to the government. Consequently, they cannot effectively play their role in the process. NGOs that are not specifically environment-based lack environment-specific knowledge. Hence, they face complications in pursuing cases in courts. Representatives from SIMORGH and LCS mentioned,

‘We do not have an environment background. One of the challenges that we face is to contact environmentalists who are willing to stand with us’.

In Ghana and the Maldives, NGOs complain that the information revealed by the authorities is either too technical or incomplete, and that they are not involved in decision-making. Initiatives are merely presented to them rather than discussed with them (de Jong et al. 2012) This problem is well addressed in developed countries such as Canada, the UK and Brazil. In Canada, NGOs are provided funds to carry out their own technical analysis and EIA studies. As a result, their arguments are technically stronger to back up their cases (Saarikoski 2000). In the UK, NGOs have access to physical resources for EIA implementation such as the central environmental database, the central database for EIA reports, a regular newsletter or EIA status reports published by environmental agencies (Glasson and Salvador 2000).

3.2.2. Lack of support from society

Pakistani society is hesitant to participate in social surveys for fear that their voice may be broadcasted to government authorities in a negative sense and their identity disclosed. Therefore, they remain silent on issues. In addition, people are not willing to participate unless they themselves personally benefit from it. They are more interested in their materialistic well-being rather than in the environment, as has also been reported for China (Tang and Zhan 2008).

According to a representative from LCS,

‘It is really difficult to mobilize people. They are more interested in taking a stand and raising their voices on projects that can provide them with some monetary benefits, such as projects that involve resettlement, including like compensation payments and so on’

People are also not aware of their rights. According to a representative from Pakistan Green Task Force,

‘One of the key challenge that we face while playing our role as activists is that public is not aware of their rights to a safe environment.’

NGOs also face the issue of social acceptance. Locals are sceptical of their motives because they focus more on global issues compared to local ones during focus group meetings. According to representative from SIMORGH,

‘People are also reluctant to support us because they doubt our motives and feel that we are against development in their area’.

In Yemen for example, NGOs have a negative image because they are known to work for private rather than public interests (Goddard et al. 2010; van Loon et al. 2010; Hasan et al. 2018; Hege and Demailly 2018; Sharmin et al. 2018; Zinia and McShane 2018).

Additionally, public concerns are generally ignored in the EIA process in Pakistan including Punjab particularly in case of government projects. After a few projects, such as road widening, an industrial estate, a motorway and a cement factory project, the public lost their trust in the government. Their concerns were not addressed and they felt the decision-making process was not transparent (Nadeem and Fischer 2011).

Representatives from Pakistan Green Task Force, Ufaq Development Organization, Majlis-e-Tahaffuz-e-Maholiat, Awami Development Organization and Zafar Memorial Foundation mentioned that,

‘We used to approach environmental protection departments or tribunals few years back regarding pollution from industries or brick kilns or other compliance issues but then stopped doing it owing to the fact that our concerns are never addressed. The exercise used to be futile’

Similarly, in Indonesia, a study of 18 proposed projects showed the distrust of the public because their objections were not heard. They considered EIA merely as an eyewash procedure which ultimately leads them to reject the proposals. EIA transparency has also been questioned in Iran (Kolhoff et al. 2016; Khosravi et al. 2019).

NGOs and activists in Punjab have two classes, the elites and the middle class. Normally, these two classes operate in their own circles and work on their own issues of interest. Hence, their effectiveness is limited. Another reason for the lack of support by middle-class society is that local/national NGOs are founded and run by political or social elites who belong to a different class than locals. One of the representatives from SIMORGH mentioned the following:

‘When activists from elite background come to the demonstrations all dressed up in fancy clothes and shoes, there naturally comes a barrier between them and the affectees who belong to the middle or lower middle class. You know, you have to be a part of them in order to gain their trust’

3.2.3. Role of government in the involvement of NGOs in EIA process

Involvement of NGOs in the EIA process helps ensure accountability (Hasan et al. 2018). Government and project proponents can play a major role in ensuring the involvement of NGOs in the EIA process. For example, in Brazil, the government incorporated 15 NGOs in their National Council of the Environment through the enactment of a law in 1951 (Glasson and Salvador 2000). Similar measures were also reported for Mexico and Columbia (Hasan et al. 2018). EPA Punjab, Pakistan, also established environmental NGOs but they were not specifically EIA based.

Sometimes, proponents are not in favour of a transparent EIA process as has been reported for Japan (Ryu et al. 2004). Proponents in Punjab, Pakistan, are rarely involved or interested in the EIA process. Their sole interest is NOC so that their projects are not halted. Proponents may gain greater trust from NGOs and similarly, NGOs may play a better role in the EIA process if the process is made more open, transparent, honest and less complex on the part of proponents in terms of providing NGOs with the information they need. International NGOs do not get directly involved in protests or demonstrations. As stated by a representative from IUCN,

‘We do not directly get involved in protests and remain on the back foot because we do not want to take an unpopular stance because of our decent ties with the government’.

A representative from Pakistan Green Task Force mentioned that,

‘We can go to EPA if we want to, like we used to do in the past but we prefer staying on back foot’

Similarly representatives from Al-Shajar, Afforestation and SabzAas Lahore told us,

'We are only concerned with peaceful activities like tree plantations or awareness sessions’

In China, NGOs prefer getting involved in activities such as garbage collection, tree planting or public awareness. However, they are hesitant to play a leading role in protests in consideration of the long-term sustainability of their organisations (Wu et al. 2017).

Citizen’s involvement in EIA largely depends upon the political structure of the government. For example, in the case of authoritarian governments as in China and Taiwan; public involvement is limited (Kolhoff et al. 2016; Rebelo and Guerreiro 2017). In Yemen, the political context does not allow NGOs to participate in the EIA process (van Loon et al. 2010). Democracy has not been established in Pakistan because it has been led by the military for decades. Even the elected leadership has used the public and financial services for their self-interests (Lund-Thomsen 2004). Hence, public participation and independence of print media has always been limited (Lund-Thomsen 2004).

A representative from Ufaq Development Organization mentioned that,

‘People are unaware and afraid to take stand against major projects. Also, government itself does not want them to be aware because then civil society will stand against their rights and it might pose difficulties for them’

Stakeholders in government-owned projects in Bangladesh also have no influence in the decision-making process. Local information collection, information dissemination and trust-building with the community are limited. The projects are pre-decided to be executed no matter how adverse the impacts may be on the people and the environment. This action puts a question mark on the transparency of and public influence on the process (Hasan et al. 2018). Furthermore, in Punjab, government-owned projects either proceed without EIA or it is carried out after the completion of the project. Thus, the involvement and influence of the public and NGOs through social surveys or public hearings are limited. NGOs are rarely contacted even when social surveys are carried out (Saif et al. 2015; Khan et al. 2018). In more democratic societies, the formation of social groups is favoured and the EIA process is participation-oriented (Purnama 2003; Tang et al. 2005; Hasan et al. 2018). If the judiciary and media are independent and accountability mechanisms exist in an EIA system, then NGOs can represent the public and fulfil their task as watchdogs (Kolhoff et al. 2018). In Malaysia and Thailand, NGOs and the government work together to ensure effective public participation. In Malaysia, NGOs are listed as members of the reviewing panel and they are invited by the government to help ensure public participation (Hasan et al. 2018).

3.2.4. Timing of involvement of NGOs in the EIA process

Influence of public participation in the EIA decision-making is weak in Pakistan (Nadeem and Fischer 2011). The role of NGOs in the EIA process of Punjab is compromised because they enter the process very late. They enter at the time of public hearing when the EIA study has been completed and submitted to EPA and a confirmation of completeness of reports has been issued as discussed earlier. According to representatives from Park Bachao and LCS,

‘By the time we get to know of projects, that is at the public hearing stage, everything is already finalised and it is not easy to alter the project location or design’

NGOs must start making efforts at an early stage of the EIA process so that their concerns may be addressed. The same is the case with Japan where local and national environmental NGOs cooperate and network with one another in the EIA process. (Ryu et al. 2004).

4. Conclusion

In this study, we focused on the role played by NGOs in the EIA process of Punjab, Pakistan and the challenges they face in the process. NGOs in Punjab have a long way to go before they are considered, and they must act as a key stakeholder of the EIA process. Out of the 20 NGOs interviewed, 13 had a certain role in the EIA process of Punjab currently or in the past. NGOs’ role as a watchdog is not very encouraging because they are not consulted during public consultations/hearings. Furthermore, they themselves are reluctant to participate because their concerns are never addressed. As an information provider, only a couple of NGOs, namely IUCN and LEAD have played a key role in terms of EIA research and education in Pakistan with major role being played by IUCN. IUCN facilitated the implementation of an internationally funded programme along with the Pakistani government to prepare a national handbook of EIA in Pakistan. They also designed a tertiary-level EIA course curriculum and prepared a guiding document for EIA consultants’ accreditation. NGOs played a relatively prominent role as a pressure group, where NGOs such as LCS, SIMORGH, Park Bachao Tehreek, Green Circle Organization, Pakistan Green Task Force and a couple of activists have stood against environmentally damaging development projects. However, this role is mainly limited to Lahore or Rawalpindi. Major challenges faced by NGOs include limited financial and technical resources and support from the government and civil society. Their participation in various steps of the EIA process should be institutionalized starting from scoping and through the follow-up as well. They should be provided with incentives to ensure their participation in public hearings and also should be given the confidence that their concerns will be heard and taken into account in the final decision-making. The government needs to set some good examples to gain their trust. Capacity development of NGOs is important to improve environmental performance (Kolhoff et al. 2018). They should be provided with financial and technical resources and trainings, etc. and for this purpose, our government should learn from international experiences. For instance, in the results section, we mentioned the examples of Malaysia, Thailand and Brazil where NGOs are members of review panels and part of National Council for Environment, respectively. This way they will be in a better position to play their role. According to Buesgen (2008) strong cooperation between the state and civil society can help counter balance the unchecked interests of the corporate sector and promote sustainable development. Strengthening the role of NGOs in EIA not only in Punjab but across Pakistan will ensure better transparency and accountability in decision-making and will make the EIA process more effective. Thereby helping the country achieve its sustainable development goals.

Disclosure statement

No potential conflict of interest was reported by the authors.