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Management
of the NCS Implementation Process
4.8
The processes employed for NCS implementation have been complex, even
convoluted. There has been no clear ‘road map’ and responsibilities for
implementation. This is not a surprise, for the issues involve many sectors
and many institutions within society. But in the end there are two key
elements affecting whether travel along the road leads to a destination
or a dead-end. The first is ownership of the strategy. The second is effective
leadership. Only if these two conditions are met can there be hope that
the presence of other prerequisites such as access to financial resources,
technical expertise, effective coordination and communication, and efficient
administration will be effectively utilized.
Within
Government Ownership and Leadership for the NCS
4.9
A strategy owned by everyone may in reality be owned by no one unless
there is across-the-board leadership, effectively expressed. The concern
with the NCS is the limited degree to which ownership actually has been
solidly planted within the national government. The original mechanism,
dependent upon the leadership of several ministers, and the active involvement
of the Prime Minister/Chief Executive as chair of PEPC, has faltered.
PEPC, as an apex body, has a legal mandate to formulate environmental
policy and also to monitor it through PEPA. It was to provide the guidance
on NCS progress. But it has not met regularly enough and seems to have
relegated control of the NCS to the NCS Unit.
4.10
The NCS Unit within MELGRD was to act as a focal point for coordination,
catalyzing action and monitoring the strategy. It is seen as the principal
agent in the management of the NCS implementation process. It appears
to have long forgotten its mandate and its position within the Ministry
is weak. Externally, little that is positive is said about the NCS Unit.
Halfway through, it was also asked to coordinate and monitor EPRCP, which
diluted its focus on NCS considerably. The Joint Secretary, who serves
as Head of the NCS Unit, is also looking after administration, and the
Unit suffers from lack of professional support. There have been five Joint
Secretaries in eight years—negating any kind of the essential long-term
focus required for a successful NCS implementation approach. The Unit
today stands as a weak tier in the NCS implementation process.
4.11
The Environmental Section in the federal Planning and Development Division
and in the provincial P&D departments have not contributed as much
as desired to the NCS implementation process. Stakeholders, including
government departments (federal and provincial), view these as blocking
progress. All Environmental Sections suffer from staff inadequacy and
professionalism, and frequent transfers. The National Planning Commission
is a logical enough body to play an important integrative role in ensuring
that the three key elements of environment, economy and social matters
are brought together in an integrated way. This has not happened through
this mechanism, again, a situation where leadership and ownership have
lapsed.
4.12
The federal and provincial EPAs have all been engaged in the NCS implementation
process. The provincial EPAs suffer from staff shortages and competence
issues, and lack of a consistent linkage with a department. The PEPA,
however, seems to have engaged itself more as a ‘technical arm’ of MELGRD
than an implementation arm of PEPC. Despite these constraints, PEPA has
been able to prepare:
- A review of IIE
and EIA regulations (1998)
- Pollution charges
for industry (calculation and collection rates 1998)
- Environmental sample
rules (1999)
- Provincial sustainable
development fund utilization and procedure rules (1998)
- Regulations for
certification of environmental laboratories for NEQS (1998)
- Industry self-monitoring
and reporting rules for NEQS (1998)
- Hazardous substances
rules (1998); and
- Draft implementing
regulations for PEPA.
Thus,
for at least one of the fourteen core areas of NCS (i.e., pollution control),
the MELGRD has been able to make significant managerial progress in the
past few years. It is important to note, however, that the larger management
challenge lies ahead in making this system for pollution control actually
become functional in terms of affecting outcomes.
4.13
These observations on management cannot be directly extrapolated to NCS
implementation at provincial levels, since there is such variability in
terms of the different stages of implementation and commitment. The general
problem of ownership exists in all cases, however. And, where effective
leadership and support for a provincial strategy exists, progress is made.
Where it is lacking, progress has been extremely limited. In virtually
every province and special region there is a serious gap in the link with
national government on management of both environmental protection and
NCS implementation.
NCS
Ownership and Leadership Outside of Government
IUCN-Pakistan
4.14
IUCN-P has been the most important contributor outside government assisting
in the implementation of NCS. Leadership has been strong and many would
say that IUCN-P owns the process more than government at this point. It
has successfully filled many functional gaps in NCS implementation and
has acted as a link between the government, private sector, NGOs and donors.
Indeed the 1993 Action Plan calls for IUCN-P to lead in coordinating the
actions of NGOs in support of the NCS.
4.15
While IUCN-P has earned a paramount place in the NCS implementation process,
it has done so with the recognition that it is in a long-term support
relationship. An early CIDA review recommended a main role of “facilitation
in four key areas—institutions, economic and legal incentives, awareness
raising and the support of a select number of field projects.” Ultimately
the NCS will be most successful if it is firmly embedded in key government
management processes and decision-making. IUCN-P can help in this process,
but it is government that actually internalizes results.
4.16
IUCN-P has assisted the government and other stakeholders, nationally
and within the provinces and special areas by sitting directly with government
staff. It has helped via the development of significant pilot projects.
IUCN-P has played an active role in institutional development and capacity
building. And, through PEP, it has been a partner in what is quite a unique
approach to build a results-based management approach. Needless to say
IUCN-P has been constrained in its own effectiveness by the limitations
on ownership and priority accorded the NCS within government.
4.17
IUCN-P has grown considerably over the years as a consequence of its involvement
with the NCS. This growth has come about not only in financial terms,
presence throughout Pakistan, and in project implementation capacity,
but also in terms of its ability to manage activities to the point where
results in terms of outcomes and impacts can be demonstrated. IUCN-P is
at a point where it can now play a very important role with government
in cost-effective capacity development and management support. To do so,
however, will require the prerequisite leadership and ownership issues
to be resolved within government. And it should be recognized that IUCN-P,
for all its strengths, has expanded rapidly and faces its own internal
managerial and capacity-building needs. Thus, for it to continue to play
an expanding support and implementation role, it will need further inputs—major
financial resources, limited technical advisory and managerial inputs,
and the continuing flow of outstanding and highly motivated recruits to
its staff.
Sustainable Development
Policy Institute (SDPI)
4.18
SDPI is a credible organization in conducting quality research on environment,
SD, and core areas of the NCS, and has contributed to some training efforts.
It has rendered policy advice to MELGRD, including the 1993-98 Plan of
Action. SDPI has established its credentials as a respected institution
to render advice and support to the government, and has opened space for
policy dialogue between the government, NGOs and other institutions. Up
to the present time, it has not taken a particularly active role in addressing
issues related to the management of policy formulation and implementation,
or other aspects of detailed managerial issues affecting the NCS. As an
independent institution still maturing, SDPI may wish to look at its future
role in terms of the kind of advice that it might provide government on
management matters. Throughout the world, independent environment and
development organizations are recognizing that the problem is not so much
one of non-recognition of environment and SD issues, but of finding effective
administrative and management approaches.
Other
Civil Society and Private Sector Organizations
4.19
Various civil society bodies, including professional environmental and
developmental organizations and local organizations have utilized the
NCS program areas for their own capacity development and implementation
of projects (see examples in Chapter 3, “Potential Success Stories.”)
These are about ownership and leadership. Sometimes the NCS has served
almost as an “invisible hand” or a valuable point of reference
or justification; in other cases, for example in the NWFP FFEJ, the NCS
and the SPCS are very central. Overall, the role of the NGOs and civil
society in management of NCS implementation is very significant, particularly
given that many entered the arena late and still have limited expertise.
Stakeholders have noted that the NCS offers more ‘space’ for NGO inputs
than other national processes.
4.20
It is unfortunate that the natural advantages of the private sector in
providing efficient management interventions, rapid decision-making, cost-effective
target achievement, and linkages for rapid technology transfer via multinational
connections appear not to be finding their way into the NCS management
process. The main exceptions are the ETPI and some work of Pakistani engineering
and consulting firms.
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