Environmental Impact Assessment Review 22 (2002) 163 – 179 www.elsevier.com/locate/eiar
Environmental impact assessment in Bangladesh: A critical review Salim Momtaz*,1 School of Applied Sciences, Centre for Sustainable Use of Coasts and Catchments, University of Newcastle, Ourimbah, NSW 2258, Australia Received 1 October 2001; received in revised form 1 December 2001; accepted 1 December 2001
Abstract Bangladesh initiated environmental impact assessment (EIA) guidelines in 1992 for the water sector development. The country enacted EIA legislation in 1995 and EIA rules in 1997. Today, all major donor agencies working in Bangladesh have their own EIA guidelines. This paper reveals that (a) the guidelines developed by the government and the donor agencies are stringent, however, there is less emphasis on monitoring, (b) proper implementation of EIAs are largely dependent on the requirements of the donor agencies and (c) there is a lack of coordination among the various organizations involved in environmental decision making and of adequate infrastructure to ensure proper EIA. D 2002 Elsevier Science Inc. All rights reserved. Keywords: Environmental impact assessment; Social impact assessment; National Environmental Policy Act 1969; Environmental sustainability assurance; Department of Environment; Environmental Conservation Act 1995; Environmental Conservation Rules 1997
* Tel.: +61-2-43484131; fax: +61-2-43484145. E-mail address:
[email protected] (S. Momtaz). 1 hhttp://www.ccc.newcastle.edu.au/science/srmi 0195-9255/02/$ – see front matter D 2002 Elsevier Science Inc. All rights reserved. PII: S 0 1 9 5 - 9 2 5 5 ( 0 1 ) 0 0 1 0 6 - 8
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1. Introduction Environmental impact assessment (EIA) is the process of assessing the consequences that are likely to flow from a proposed development. It is a planning and management tool for sustainable development that seeks to identify the type, magnitude and probability of environmental and social changes likely to occur as direct or indirect result of a project or policy and to design the possible mitigation procedure (Vanclay and Bronstein, 1995; Harvey, 1998; Momtaz et al., 1998; Thomas, 1998). National Environmental Policy Act 1969 is the legislative basis for EIA, which was the result of wide spread recognition in the US in the 1960s that some major environmental problems were created by the government’s actions. This legislation required that all federal agencies would consider the environmental consequences of their actions. Within a few years time, many developed and developing countries designed their EIA legislation. By 1990s, developing countries in Asia emerged at the forefront of EIA practice in the developing world (Gilpin, 1995). Today, EIA is firmly established in planning process in many of these countries. However, many authors (see, for example, Briffett, 1999) suggest that despite the existence of good EIA guidelines and legislation, environmental degradation continues to be a major concern in these countries. EIAs have not been able to provide ‘environmental sustainability assurance’ (ESA) for these countries (Sadler, 1999). For Bangladesh, it was not until 1992 that the country had its first EIA guidelines. This paper examines the evolution and present status of EIA in Bangladesh, identifies the constraints and proposes some remedies.
2. Methods I visited Bangladesh between November 2000 and February 2001, as a recipient of a ‘Rotary Grant for University Teachers.’ During this 3-month period, I visited all major organizations involved in the design of EIA procedure and implementation of EIA and had extensive discussions with relevant personnel. These organizations are Department of Environment (DOE) of the Government of Bangladesh, United Nation’s Development Program (UNDP), World Bank (WB) Dhaka Office, CARE Bangladesh, Bangladesh Centre for Advanced Studies (BCAS), and Environment and GIS Support Project for Water Sector Planning (EGIS), Ministry of Water Resources. I also collected and thoroughly examined relevant literature on EIA published by these organizations. To examine the quality of EIAs conducted in Bangladesh, a major EIA report (EGIS II, 1998) has been reviewed using the guidelines suggested by Modak and Biswas (1999).
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3. Evolution of EIA in Bangladesh 3.1. Legislative and institutional framework Legislative bases for EIA in Bangladesh are the Environmental Conservation Act 1995 (ECA ’95) and the Environmental Conservation Rules 1997 (ECR ’97). DOE, under the Ministry of Environment and Forest, is the regulatory body responsible for enforcing the ECA ’95 and ECR ’97 (BCAS, 1999). During the decades of 1970 and 1980, the government of Bangladesh, with a view to alleviating poverty and resolving the country’s unemployment problem, resorted to many industrial and agricultural development projects. Much of these development activities took place without paying any attention to their environmental consequences. As a result, the country suffered from environmental degradation in many areas. One burning example is the large-scale contamination of groundwater by arsenic. However, there is a recent realization that development could not be sustained if due consideration was not given to environmental protection. Consequently, the government of Bangladesh, with the view of providing for the conservation and improvement of environmental quality and controlling and mitigating pollution in the environment, enacted the ECA ’95, which became effective on June 1, 1995. Section 12 of this Act stipulates that ‘‘No industrial unit or project shall be established or undertaken without obtaining environmental clearance from the Director General, DOE, in the manner prescribed by the rules’’ (DOE, 1997, p. 1). Clause (2) (f) of Section 20 requires that rules be made to ‘‘evaluate, review the EIA of various projects and activities, and procedures be established for approval’’ (BCAS, 1999, p. 43). To meet these requirements, ECR ’97 was promulgated. Although it is the responsibility of the proponent to conduct an EIA of development proposal, the responsibility to review EIAs for the purpose of issuing Environmental Clearance Certificate (ECC) rests on DOE (DOE, 1997). Industrial projects have been divided into four categories — Green, Amber A, Amber B and Red (DOE, 1997), according to the environmental significance and location of proposed industry. Category Green projects do not require initial environmental examination (IEE) and EIA. A no objection certificate from the local authority is adequate for a project that fall into the Green category. On the other extreme of the range are the Red category projects, which require both IEE and EIA. This normative screening process enables DOE and proponents to determine which steps to follow in the environmental clearance process (Fig. 1). It may be mentioned here that special emphasis is placed on site selection for industries with significant potential for environmental impacts, and the proponents are required to consider alternative sites keeping in view the criteria put forward by the DOE (DOE, 1997).
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Fig. 1. Steps involved in environmental clearance from DOE. (Source: DOE, 1997, p. 7).
The important stages in the development of a EIA study according to EIA Guidelines for Industries prepared by DOE (DOE, 1997) are:
Screening/scoping. Identification of significant environmental issues and how these will be resolved. Adequacy of mitigative measures and the Environmental Management Plan.
Fig. 1 shows the various phases in environmental clearance, and Fig. 2 illustrates the place of EIA in project cycle. The steps in EIA recommended
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Fig. 2. Project planning, its implementation and DOE’s EIA process. (Source: DOE, 1997, p. 8).
by DOE are similar to those mentioned in all major literature as follows: baseline study (similar to scoping); impact identification; impact prediction; impact evaluation; mitigation measures; monitoring programs; special studies, if applicable, like risk assessment, resettlement and rehabilitation study, etc.; and documentation and communication (DOE, 1997). 3.2. Environmental geographic information systems (EGIS) EGIS (a project under the Ministry of Water Resources, Government of Bangladesh) looks after the conduct of the government’s EIA of projects in the water sector. In 1991, this organization (the then Flood Action Plan or FAP) developed 26 components in flood action plan, the sixteenth component of which was environmental study of FAP. This organization developed a set of guidelines for EIA of the water sector development. The guidelines were basically based on donor guidelines, e.g., WB and Asian Development Bank (ADB).
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One important aspect of the procedure (Fig. 3) is that it places significant emphasis on community participation. It was realized that water infrastructure projects would have significant consequences on the local communities, and it was important that the latter played active role in decision making and the implementation of projects. An attempt was made to develop formula to quantify impacts through the use of weighted matrix method. FAP’s draft guidelines were bitterly criticized as being a textbook exercise, i.e., taken from donor agencies; not adapted to suit local conditions. Western style community consultation was proposed, which would be difficult to adopt in rural areas of Bangladesh where most people were illiterate and did not have enough awareness of environmental impacts to make meaningful contribution through participation. In addition, questions were raised about the use of mathematical formula to quantify impacts. The
Fig. 3. Procedural steps in FAP’s EIA. (Source: FAP, 1992, p. 18).
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criticisms were well taken, and revised guidelines were experimentally applied to four different cases in four regions, namely, the Sylhet and Tangail districts and two other places in the coastal region. These were all concerned with the development of water infrastructure, such as embankments, regulators, sluice gates, etc. EIA’s main emphasis was on biophysical environment but, generally, impacts on four areas were considered — land resources, water resources, biological and socioeconomic. Many modifications were made to the draft through trial and error process. After a number of workshops and the adoption of DOE’s suggestions, the final version was published in 1992 (FAP, 1992). A number of weaknesses still remained in the guidelines, for example, legal aspects of project impacts were not considered. Although in all cases, initial environmental evaluation was to be conducted before EIA, there were no separate guidelines for IEE. However, DOE (1997) has clearly outlined the IEE process, which is likely to fill this gap. In February 2001 (the field work period), EGIS was in the process of reviewing its EIA guidelines with a view to eliminating the weaknesses still remained. A revised and improved version is expected in late 2001. 3.2.1. Review of a major EIA and SIA conducted by EGIS To get a feel for the quality of EIA in Bangladesh, a brief review of the Environmental and Social Impact Assessment of Khulna – Jessore Drainage Rehabilitation Project (KJDRP) (EGIS II, 1998) has been conducted here (Fig. 4). The KJDRP is located in the southwestern part of Bangladesh and comprises parts of both Khulna and Jessore districts. The total project area is 127,800 ha with an estimated population of 1.1 million in 1997 (EGIS II, 1998). It comprises numerous tidal rivers and creeks, which provide a drainage network to a system of embanked hydrological units or polders in which the in- and outflow of water can be controlled through regulators. The construction of embankments in the sixties greatly reduced the tidal volumes entering and leaving the project area during the tidal cycles. This resulted in gradual siltation of the drainage networks. About 20% of the land had been taken out of agricultural production, and many households had to migrate to other places. In 1995, the Government of Bangladesh (GOB), with financial support from the ADB, initiated the KJDRP to find permanent relief to the suffering of the local people. In 1997, EGIS was appointed by the Ministry of Water Resources for an independent environmental and social impact assessment study of two technical alternatives: a regulator at either Shibnagar or Madhukhali. The assessment team was a balanced one, consisting of local and international experts with backgrounds in water resource planning, agronomy, sociology, economics, ecology, fisheries, biology and GIS. Local communities were extensively consulted through rapid rural appraisal, workshops and
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Fig. 4. Review of a major EIA and SIA conducted by EGIS.
group discussions in the development of the preferred option to ensure the acceptability of the project. Review of the EIA report for this project (Fig. 4)
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reveals that it satisfies most of the review criteria developed by Modak and Biswas (1999). This sophisticated and highly technical study was conducted for 3 months and was supported by a number of international and national agencies. It would be interesting to know how much money was spent on this study and how the project was to be implemented and monitored. 3.3. CARE Bangladesh, Local Government Engineering Department (LGED) and the United States Agency for International Development (USAID) The Ministry of Relief and Rehabilitation initiated the Food for Work Program in 1975. This program employed landless people in earthen road construction in rural areas in exchange for food. It became a major works program at a later stage (Integrated Food For Work Program, IFFW) employing 500,000 people in rural areas during slack season (Nakashima and Khan, 1994). CARE Bangladesh played a supervisory role in this USAID funded project. In 1990, a programmatic environmental assessment (PEA) was conducted to assess the success of IFFW. A social soundness analysis was also conducted. These two studies revealed that, on the one hand, the programs negatively impacted upon the Bangladesh environment through damaging wetland ecosystems, flooding, loss of agricultural land and declining numbers of fish species. On the other hand, they contributed towards polarization of power and resources and inequality in rural areas. Benefits of FFWP were not only undermined by this but also the outcomes were inconsistent with the country’s sustainable development goals (Khan and Fitzcharles, 1998). Against this background, CARE took initiative to improve the sustainability of its projects. An environmental review is incorporated in the early planning process. In 1991, CARE founded an Environmental Management Unit and formalized the Environmental Action Plan. The plan required that every road construction plan must undergo IEE, which would allow the identification of projects that would require EIA. In 1994, CARE Bangladesh and USAID joined the Ministry of Local Government and Rural Development (LGRD) to start the next phase of the FFWP -Integrated Food For Development Program (IFFD). LGED performed the administrative arm for the Ministry of LGRD. Environmental concerns are very well incorporated in the IFFD environmental policy which says: (a) every road under the program will require IEE before the work can be authorized — at this stage, roads requiring full EIA are identified; (b) roads passing through unprotected forest areas must obtain a ‘no objection certificate’ from the concerned authority before any work proceeds; (c) for road rehabilitation in forested areas, no trees can be removed without the permission of the owners; and (d) no new roads are to be constructed. The existing route densities in most rural areas are found to
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Fig. 5. The IFFD environmental work cycle.
be sufficient, but many roads need rehabilitation such as earth filling, structure construction and maintenance. The IFFD environmental work cycle is shown in Fig. 5. The salient features of the policy are that road improvements cannot go ahead without considering their negative and positive environmental consequences, and the policy also considers no development option — an important but neglected area in EIA — by deciding not to construct any new roads. Local communities are widely consulted using a range of methods, i.e.,
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questionnaire survey, public meetings, leaflets, etc. for information gathering and feedback. 3.4. WB and its environmental strategy WB has been a development partner of Bangladesh for a long time. It has developed its own EIA procedures for projects funded by it. Since 1989, bank staff are required to screen all proposed new investment projects with respect to their potential environmental impacts and to classify them accordingly. For this purpose, projects are classified in three categories: 1. Category A: Projects that are likely to have significant long-term impacts. A full assessment is required. 2. Category B: Projects that are likely to create site-specific impacts and would not affect human population and environmentally sensitive areas. A partial environmental assessment is required. 3. Category C: A project that is unlikely to have impacts on society and environment. EA is not required for such projects (The World Bank, 1997). WB has effectively incorporated EIA into project cycle (see Fig. 6). EIAs are conducted by the organizations that are implementing projects. However, WB has an environmental section that examines EIAs for approval. WB stringently follows its regional environmental strategies and guidelines in funding projects (The World Bank, 2000). For this reason, this organization is often perceived as being an organization, which is putting unnecessary hurdle in the smooth implementation of development projects in Bangladesh. WB conducted its first EA review in 1993, which covered the period from October 1989 until June, 1992 (The World Bank, 1993). In 1997 WB conducted the 2nd review of its environmental assessment experience in WB funded projects worldwide (The World Bank, 1997). It revealed that (a) the EA process was operative and produced results, (b) performance could still improve in a number of areas, such as, more attention in scoping, site alternatives were not adequate, mitigation and monitoring and management plans were insufficiently developed by the borrowers and (c) early experience gave rise to new issues in regard to resource needs for EA, training needs within the Bank and consideration of sectoral and regional EAs. 3.5. Asian Development Bank (ADB) ADB has been a major development partner in Bangladesh since her independence in 1971. In 1999, it provided four loans amounting to US$332 million and approved 15 technical assistance grants totaling US$10.9 million (ADB, 2001). It had a major involvement in the construction of the Jamuna
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Fig. 6. WB’s environmental assessment and the project cycle.
Bridge — the largest infrastructure project in the history of Bangladesh. ADB has recently developed a new environment operational strategy (EOS) for Bangladesh in order to address the major environmental problems.
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Like WB projects, ADB projects are also classified into Category A (significant impacts), Category B (some impacts) and Category C (no impacts). In addition to IEE and EIA, an initial social impact assessment is required for every development project in order to identify their consequences on people (ADB, 2001).
4. Discussion and recommendations 4.1. Major issues in the application of EIA in Bangladesh (1) Scoping is an important phase in conducting EIA. It is the stage when geographic region and issues to be considered in an EIA are determined. At the initial stage of EIA application in Bangladesh, the scoping stage was not clear to the individuals and groups involved in the conduct of EIA. The understanding was that all components/sectors examined in major projects should also be taken into consideration in smaller projects. However, later, it was clarified that only components relevant to the project should be considered in the scoping phase. For example, if public health is not an issue for a road construction project, then no time should be spent on examining that issue. Scoping is now well placed in all IEE and EIA. (2) It is difficult or impossible to quantify many impacts in many cases, especially in the assessment of social impacts, although without quantification, the extent of magnitude cannot be properly explained or made credible. As a result, the practitioners used scales, such as high impact (scores 8, 9 or 10), medium impact (4, 5 or 7), low impact (1, 2 or 3) and 0 for no impact (FAP, 1992). In addition, multicriteria analysis and matrix methods in the evaluation of impacts were used (EGIS II, 1998). USAID also devised a method of scoring impacts. The impacts are measured on a seven-point scale ranging from 1, 2 and 3 representing low, moderate or high negative impacts, respectively, 0 representing no impact to + 1, + 2 and + 3 representing low, moderate and high positive impacts, respectively (Khan and Fitzcharles, 1998). Although these methods of quantification can be used subjectively, the officials are instructed to take special care to estimate the degree of impacts in comparison with the present situation. Magnitudes of the impact are generally determined by multidisciplinary teams using these scales, which are clarified in the reports. Use of these techniques increased the credibility of results derived from EIA. (3) There have been debates in developed countries as to the responsibility of EIA (Thomas, 1998). It has been observed that benefits of EIA conducted by proponents outweigh the arguments in favour of independent bodies conducting EIA. This is due to the fact that proponents are in the best position to conduct EIA in the most effective manner. They have all the relevant information regarding the project, which places them in an advantageous position to identify and assess potential impacts with better confidence. In Bangladesh, however, there is a strong opinion in favour of independent bodies to conduct EIA. The general
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perception is that EIAs are conducted only because they are required by the government legislation and donor agencies, not to ensure sustainability of projects or to develop better management plans. In many cases, EIA is seen by proponents as an impediment to the implementation of development projects. It is regarded as a tool to justify projects rather than using it as a means to derive best decision. (4) DOE is the authority that observes the implementation of ECA ’95 and ECR ’97. It is the approval authority for development projects. However, there is a lack of skilled EIA and SIA professionals within this department to make meaningful judgement on EIAs conducted to acquire ECC. Lack of implementative capacity — ability to conduct proper EIA and ability to implement mitigation measures — has been identified by WB as the biggest constraint to effective EAs (Goodland and Mercier, 1999). (5) There is a lack of coordination among the agencies involved in EIA. There is no standard EIA procedure to be observed by all practitioners. The presence of donor agencies as organizations parallel to the DOE in project approval may lead to the creation of dual standard in EIA quality. In addition, there is no mechanism in place to ensure monitoring of project impacts to identify and rectify impacts that were not picked up by the EIA. (6) Developers or proponents hire consultants to conduct EIA of development projects that they are proposing. Their intention is to get an EIA done that would highlight the benefits and justify the proposal in order to obtain environmental clearance from the DOE or from the donor agencies for the purpose of fund clearance. It is therefore the job of the consultants to satisfy the proponent’s requirements rather than carrying out objective EIAs to ensure environmental and social soundness of projects. In addition, there are no codes of conduct by which the activities of the consultants are governed. (7) Recent development in the EIA arena is the emphasis on strategic environmental assessment (SEA) or policy level assessment (Petts, 1999). That means that rather than conducting project level impact assessment, it is more advantageous to conduct EIA at the policy development level. This will provide the decision makers with more time to consider environmental consequences at an early stage. SEA would also allow the consideration of cumulative impacts of various projects (Canter, 1999). There is a need for SEA in a country like Bangladesh where major development programs are being implemented by a number of local and international agencies. 4.2. Recommendations (1) ECA ’95 and ECR ’97 are milestones for the country in its efforts to create sustainable society where there would be a balance between development and environmental protection. However, enforcement of legislation is not an easy task in a country where corruption is all pervasive. It is important that NGOs and donor agencies play a major role in monitoring the conduct of EIA in collaboration with DOE.
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(2) A number of agencies are involved in environmental assessment. They have developed their own guidelines. In most cases, these are good guidelines. Despite the rigorous application of guidelines, it is apparent that there is no coordination among these agencies; and there are no standardized guidelines. A set of guidelines should be developed for all sectors that would help avoid duplication and establish links between organizations. It is important to note that in order for EIAs to be effective, guidelines should pay due attention to the local social, economic and political setting. Monitoring is a major ongoing phase in EIA process, and it is important that emphasis is placed on monitoring postproject impacts. (3) Independent bodies should review the EIAs prepared by independent consultants. This will ensure the quality of EIAs. It may be noted here that despite the stringent regulations, some Western countries (for example, Australian state of Western Australia) have established bodies — independent of the government and the proponents — to review EIAs for approval purposes (Conacher and Conacher, 2000). DOE should develop codes of conduct for the consultants. (4) Although community participation is enshrined in legislation and in the guidelines of EIA, often, it is neglected and starts at a later stage of project development, rather than early, only to meet legislative requirements (Petts, 1999). Community participation and consultation should be incorporated at every stage of project development. Consultation with local people and their representation in project development process will ensure better decision making. Through community consultation and incorporation of local knowledge in project development, it is possible to gain trust of the local communities. This will facilitate smooth implementation of projects. In the EIAs conducted by CARE and EGIS, community participation has been ensured through RRA and participatory rural appraisal (PRA) in the entire project cycle. DOE has also placed adequate emphasis on public participation (DOE, 1997). One of its EIA review criteria is to see if the concerns expressed by community are genuine and if the project EIA has addressed these concerns adequately. However, ensuring effective community participation in the EIAs conducted by consulting firms for private developers will remain a contentious issue. (5) It is time that DOE considers developing SEA and regional impact assessment (RIA) guidelines. SEA and RIA would enable the identification of regional level impacts of policies and the adoption of a holistic approach to environmental planning. The Bangladesh government is embarking on a number of multifaceted projects, such as housing for low income earners, sending the villagers back to their villages who migrated to big cities. These programs will embrace many aspects of rural life and have a potential to affect biophysical system at regional level. It is therefore imperative that the government becomes fully aware of the environmental and sustainability issues associated with a particular policy, program or plan (PPP) (Therivel and Brown, 1999) in order to avoid, minimize or mitigate the likely consequences. A parallel initiative should be taken in the area of skills development in EIA. This should be done in collaboration with the donor
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agencies (e.g., CARE, WB) that are already running EIA training programs and workshops as part of their capacity strengthening initiative. (6) Questions may be raised whether costly EIA exercises like the one reviewed earlier in this paper is viable and pragmatic in a poor country like Bangladesh. There is a need to develop simplified EIA procedures that would be consistent with the availability of resources within the country. Dependence on donor agencies to meet the cost of EIA undermines the whole idea of using EIA as a tool for sustainable development. Some authors (for example, Wood, 1995; Briffett, 1999) have identified that the biggest constraint to effective EIA in developing countries is the lack of political will. This statement does not hold good for Bangladesh, as the politicians have already spoken in favour of EIA by passing EIA legislation. Institutional capacity and inadequate resources are probably the major constraints that prevent proper implementation of EIA. Moreover, having relevant legislation is not enough unless the political willingness is bolstered by a thorough understanding of the relationship between EIA and environmental sustainability assurance.
5. Conclusion Bangladesh is on the right path in its effort to develop environmental guidelines and adopt EIA in decision-making process. DOE has the potential to play a significant role in guiding the nation towards environmental sustainability. However, to be more effective, this organization requires more resources to hire skilled manpower to enforce the implementation of ECA ’95 and ECR ’97. International donor agencies and NGOs are making significant contributions to the application of EIA at project level. A coordinated effort between all agencies involved would enable the country to pursue the path of sustainable development through the development and application of strategic assessment.
Acknowledgments I thank the Rotary Foundation of Rotary International, Newcastle District, Australia, which funded this study under the Rotary Grant for University Teachers. I am grateful to the two unknown reviewers for their constructive comments on an earlier draft of this article.
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