Environmental Impact Assessment in Bangladesh: A Critical Review
Environmental Impact Assessment in Bangladesh: A Critical Review
Environmental Impact Assessment in Bangladesh: A Critical Review
Abstract
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164 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179
1. Introduction
2. Methods
Fig. 1. Steps involved in environmental clearance from DOE. (Source: DOE, 1997, p. 7).
Screening/scoping.
Identification of significant environmental issues and how these will
be resolved.
Adequacy of mitigative measures and the Environmental Management Plan.
Fig. 2. Project planning, its implementation and DOE’s EIA process. (Source: DOE, 1997, p. 8).
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.
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 sustain-
ability 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 Devel-
opment (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 envir-
onmental 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
172 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179
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 experi-
ence gave rise to new issues in regard to resource needs for EA, training
needs within the Bank and consideration of sectoral and regional EAs.
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).
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 implemen-
tative 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 develop-
ment 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 develop-
ment 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.
S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 177
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
Acknowledgments
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