An EIA Must Assess More Than Concrete

Development is necessary. Cities need roads, public transport, housing and infrastructure. But development cannot mean treating every piece of green space as vacant land waiting to be converted.

An environmental assessment that ignores biodiversity is not a meaningful assessment of the environment.

The recent controversy surrounding the conversion of part of Lahore’s historic Nasir Bagh into a parking plaza illustrates the problem. Nasir Bagh was not simply a collection of trees. It was an urban ecosystem.

The Lahore City Biodiversity Action Plan records 43 tree species at Nasir Bagh, including Neem, Ficus, Banyan, Arjun, Peepal, Mango, Jamun and Mulberry. Its fauna includes sparrows, parrots, mynas, owls, doves, kites, pigeons, squirrels, bats, garden lizards, butterflies, ants and bees. The Action Plan specifically recognises that these organisms provide ecosystem services including pollination, pest control, carbon sequestration and mitigation of Lahore’s urban heat-island effect.

That is precisely what environmental assessment is supposed to identify.

Under Pakistan’s environmental protection framework, an adverse environmental effect expressly includes damage to biodiversity, while the definition of environment includes living organisms, ecosystems and ecological relationships. Punjab’s IEE/EIA framework is therefore not conceptually limited to air, water and pollution. Environmental assessment is intended to establish baseline conditions, identify impacts and provide mitigation measures before development proceeds.

The question, therefore, is whether these requirements are being applied with sufficient attention to biodiversity.

An IEE should not become a procedural formality through which an ecologically valuable site is approved for development without properly assessing the ecosystem that already exists there.

A mature tree is not simply timber that can be transplanted. Its roots interact with soil. Its canopy regulates temperature. Its flowers and fruit provide food. Birds nest in it. Insects depend upon it. Fungi and microorganisms live around it. Removing it can therefore affect an entire ecological network.

The same principle applies to ponds, wetlands, grasslands and patches of mature vegetation.

Lahore’s biodiversity is already under pressure. The city’s Biodiversity Action Plan records 140 woody plant species across surveyed parks and gardens, including 81 native species and five invasive species. Nasir Bagh’s 43 recorded tree species demonstrate that even an intensely urbanised location can retain significant biological diversity.

There has also been documented concern over declining or increasingly rare urban bird populations. Species such as the House Sparrow have declined in many South Asian urban environments, while historical and local records identify birds including the Wire-tailed Swallow, Oriental White-eye, Long-tailed Shrike, Rufous Treepie, Plain Prinia and Indian Cliff Swallow as rare or very rare in Lahore. We should not casually describe these species as extinct; the more scientifically defensible concern is population decline, habitat loss and local disappearance from suitable areas.

And that distinction matters.

A species does not have to become globally extinct before its disappearance from our city becomes an environmental warning.

Punjab should therefore strengthen the biodiversity component of every IEE and EIA involving parks, forests, wetlands, water bodies, mature tree stands, ecological corridors and other environmentally significant areas.

A proper Biodiversity Impact Assessment should establish what species and habitats exist before construction; identify breeding, nesting and feeding sites; assess impacts on native vegetation, pollinators, birds and other wildlife; examine water and soil systems; and consider cumulative impacts from surrounding development.

Most importantly, the hierarchy should be:

Avoid. Minimise. Restore. Compensate.

Avoid destruction where an alternative exists. Minimise unavoidable damage. Restore what can genuinely be restored. Compensation should be the last resort, not the first answer.

This is particularly important in Lahore, where individual development projects may appear environmentally manageable when viewed separately, while decades of incremental construction collectively produce enormous ecological loss.

The Environment Protection Department itself is responsible for reviewing IEE/EIA reports, issuing environmental approvals and monitoring compliance with their conditions. The legal machinery therefore exists. What is required is stronger ecological scrutiny within that machinery.

The Nasir Bagh experience should teach us an important lesson.

The question should never be merely: How many trees were removed or transplanted?

The question should be:

What ecosystem existed here, which species depended upon it, what ecological services did it provide, and what will be lost when it is replaced by concrete?

Lahore cannot compensate for the destruction of functioning ecosystems simply by planting ornamental saplings elsewhere.

A newly planted tree is not equivalent to a mature tree. A landscaped garden is not necessarily equivalent to a biodiverse habitat. And a parking plaza cannot be considered environmentally sustainable merely because its environmental approval has been obtained.

Punjab needs development. But it also needs biodiversity.

Our EIAs and IEEs must finally recognise that these are not competing interests. Protecting biodiversity is part of protecting the environment on which development itself ultimately depends.

If we continue to assess only what is easiest to count, we will lose what is hardest to replace.