This report aims to evaluate the effectiveness of Environmental Impact Assessment (EIA) processes of Bangladesh through a case study on EIA of “Integrated Water Management Project on Gungiajuri Haor Area” proposed by Bangladesh Water Development Board (BWDB). The EIA report on this project was prepared by Center for Environmental and Geographic information services (CEGIS) which is a renowned environmental consulting farm of Bangladesh. The report of CEGIS include both EIA and Social Impact Assessment (SIA) but my evaluation will be focused on the EIA part of the original report. This report will include a brief discussion on the background of proposed project, the process followed during the EIA process and regulatory requirement specific to this project, brief discussion on the content of EIA report, importance of EIA report in decision-making and critical evaluation of the EIA report and the process it followed. This report will also evaluate how this EIA report and process measure against the internationally accepted best practices of EIA.
Background of the project:
“Haor” is a special kind of wetland unique to Bangladesh because of its unique hydrological and ecological characteristics. They are bowl shaped floodplain depressions situated mainly in the North-Eastern part of Bangladesh (Nowreen et al. 2015). Haor is the major source of rice production in Bangladesh and a source of livelihood of people living in adjacent areas of haor (Alam, Quayum & Islam 2010). Haor has a rich variety of biodiversity comprising of both aquatic and terrestrial ecosystems and provides many important ecosystem services of environmental, economic and cultural nature (Islam 2010). Both natural and human induced changes can adversely affect the overall condition of wetland ecosystem (Haque & Basak 2017). Early flood and flash flood is a major problem of hoar area and it causes severe damage to crop production specially the production of rice (Khan, Mia & Hossain 2012).
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To mitigate the effects of early flood and flash flood on Gungiajuri Haor area, Bangladesh Water Development Board (BWDB) proposed the Gungiajuri Haor project, which is FCDI (Flood Control, Drainage and irrigation) in nature (Appendix-1). Main objectives of the project includes protecting the project area early flood and flash flood, provide drainage and irrigation facilities to project area to increase the cropping intensity of project area (BWDB project document). Main activities under the project include:
Construction of new embankments around the haor;
Upgrading the existing embankments to full flood control level;
Construction of bituminous roads and bridges to increase the connectivity of haor;
Construction of drainage sluices and rehabilitation of existing drainage sluices;
Construction of rubber dam;
Installation of pumping station for drainage and irrigation;
Re-excavation of haor, beel and connecting rivers.
Construction of inlet and outlet structures.
Figure 1: Map of proposed project area (Source: Mukteruzzaman, Sadik & Ullah 2012)
Possible impact of the project:
Proposed project includes different forms of structural intervention in environmentally and ecologically important haor area. Department of Bangladesh Haor and Wetlands Development (DBHWD) report on the impact of structural interventions on haor ecosystem found significant negative impact on haor ecology, fisheries resources, flora and fauna. FCDI project in Gungiajuri Haor will decrese the overall fish production and fish diversity. It will also degrade the state of haor ecosystem (Mukteruzzaman, Sadik & Ullah 2012). Construction of embankment can alter the inundation frequency of floodplain wetlands, which will adversely affect the hydrological and ecological paradigm of wetland system (Talukdar & Pal 2017). Road construction will also have negative impact on biodiversity, as it will contribute to habitat fragmentation and increase in human exploitation of resources (Findlay & Bourdages 2000). Zamberletti et al. (2018) also illustrated the importance of connectivity of wetland and negative impact of habitat fragmentation of different species. But this project will have positive impact on agriculture by increasing cropping intensity of the area. It will also lead to overall economic development of the adjacent community (Mukteruzzaman, Sadik & Ullah 2012). So, the impact of the project encompasses both positive and negative impact but degree of those effects will be determined by EIA process.
Regulatory context of the EIA process:
According to The Environmental Conservation Act (1995, Amended in 2000 & 2002) of Bangladesh, every development project must obtain environmental clearance from Department of Environment (DoE) of Bangladesh. Process of obtaining environmental clearance is stipulated in Environmental Conservation Rules (1997). Environmental Conservation Rules (1997) provides four categories of projects namely: Green, Orange-A, Orange-B and Red with specific processes to obtain environmental clearance. Scoping requirement for projects is also defined in the environmental clearance process although project may have additional scoping requirement based on sectoral criteria. Sometimes scoping requirement is also adjusted in accordance with requirement of different international aid organization such as World Bank, ADB etc. but for proposed project it was not adjusted as it was implemented by Government of Bangladesh (GoB) funding. The proposed project falls under red category because it includes construction/reconstruction of flood embankment, which means it needs EIA report for environmental clearance. As this project is a water sector project, it needs to be in accordance with National Water Policy 1999 of Bangladesh and Bangladesh Water Act 2013. According to Bangladesh Water Act 2013, Water Resources Planning Organization (WARPO) act as a clearing house for all water sector projects of Bangladesh. WARPO checks the relevance of the proposed project with National Water Policy 1999, Bangladesh Water Act 2013 as well as other legislation related to water sector projects such as “The protection and Conservation of Fish Rules (1985)”. After obtaining environmental clearance report and WARPO clearance report, project implementing authority must submit project document to Ministry of Planning for evaluation. Minister of Planning takes decision on the project based on national medium and long-term plans like five-year plan, Bangladesh perspective plan 2021 and Bangladesh Delta plan 2100 (Circular on project approval process, Bangladesh).
EIA process of Gungiajuri Haor project:
EIA study of Gungiajuri Haor project was done by Center for Environmental and Geographic Information Services (CEGIS). CEGIS used the feasibility study document done on the proposed project as guide for the EIA process. EIA was conducted following the methodology of EIA guideline prepared by FAP 16 project (FAP 1992). Methods of EIA included following steps:
- Baseline study of the current resources of Gungiajuri Haor.
- Field exploration and study.
- Public consultation meeting.
- Assessment of impacts.
- Environmental Management Plan (EMP)
1. Baseline study of the current resources of Gungiajuri Haor:
Baseline study of the resources of gungiajuri haor was done during the EIA process. Baseline study included study on current water resources of area including both ground and surface water. Study also included the quality of surface water and ground water. During the baseline study, drainage pattern of the project area was identified with the major inlet and outlet of the project area.
Land type and land characteristics was identified including the distribution of different land types and land characteristics.
Major crops of the area were identified including the estimation of crop produced without the project scenario. Irrigation coverage of the area was measured.
Fisheries resources of the area was identified including both the culture and capture sector. Estimation of total fish production was done including the distribution of these production across different sectors.
Eight plant communities and common migratory bird communities was identified.
Household survey was done to identify community living adjacent to haor area. (Appendix-1)
2. Field exploration and study:
During the filed exploration stage, major data was collected by field study on important environmental and social component for both baseline study and impact assessment. This data was analyzed to find the impact of the project on various aspect of environment.
3. Public consultation meeting
CEGIS conducted several public consultation meetings (PCMs) with local community. Local representative to parliament, peoples of project implementation agency and representative from different agencies working in water resource sector of Bangladesh was present in the PCMs. Options of the projects was discussed in the meeting and several recommendations was concluded from the meeting. Some of these recommendations was incorporated in the Environmental Management Plan (EMP). (Appendix-1)
4. Assessment of impacts:
4.1 Impact on water resources
The project will protect the project area from flood, improve the drainage facility, surface water irrigation, decrease sedimentation rate and improve drainage facility, which will result in overall improvement of water resources of the area.
4.2 Impact on agriculture resources
The project will increase the cropping intensity, rice production area, rice production, decrease rice production damage and overall irrigation coverage of the area. So, the project will have overall positive impact on agriculture of the project area.
4.3 Impact on fisheries resources
The project will improve khal habitat quality with improved connectivity, culture fish area will increase which will result in increase in culture fish production. The project will decrease flood land area and degrade habitat quality of catch fish. Catch fish diversity will decrease with loss in catch fish production. The project will adversely affect both lateral and longitudinal migration of fish. Although river habitat quality will remain unchanged, the project will result in overall degradation in fish diversity and loss in fish production.
4.4 Impact on ecology
The project will decrease almost half of the seasonal water bodies. The project will adversely affect the breeding of wildlife and migration of birds. The project may cause extinction of some presently endangered fish species, turtles and amphibians of the area. Overall, project will cause significant damage to haor ecosystem and biodiversity of the area.
5. Environmental Management Plan (EMP):
EMP of the project will cover the three phases of the project which are:
- Pre-construction phase
- Construction phase
- Post construction phase
1. Pre-construction phase
Landowners needs to be compensated for their acquired land. Labor and storage facilities should be constructed at the site and landowners affected by this construction should be given prior notice. Project should avoid farming area and vegetation of clearance as much as possible. In cases where disruption of farming is not possible to avoid, farmers needs to be compensated for their crops. Floating plants needs to be planted in embankments.
2. Construction phase
Construction activities should avoid natural drainage slopes and waterways. People should be given advance notice of any possible disruption. People from project area should get priority as laborer. During big construction or dredging activities, construction materials should not occupy cultivable land as that may cause permanent damage to crops. Land should be cleared from construction material as soon as possible. Dredged material should be disposed properly. Compensation should be provided for any kind of permanent damage to crops. The project proponent should consider the construction of fish friendly structures like fish pass along with water regulatory structures to facilitate migration of fish. The proponent should also consider establishing fish sanctuary in critical areas for conserving native fish species to mitigate the adverse effect of the project on fish diversity. The fisherman whose livelihood will be affected by the construction activities should be compensated as well. Construction material should always be covered to decrease dust and to control runoff of fine particles to river stream.
3. Post construction phase
Project proponent should take necessary measures to protect all the embankment constructed under the project from wave action during flood. Trees should be planted along the embankments. Provision of movement and ghats should be incorporated in the embankment to facilitate navigation. Project should have provision for emergency repair and maintenance. Community should be trained to properly operate and maintain the structures of the project. Department of Agricultural Extension (DAE) should work closely with the farmers for effective management of pesticides to reduce amount of pesticide getting into surface runoff. Farmers should also consult DAE for efficient use of irrigation water. Fishing in the project area should be done is sustainable manner. As fish production will decrease due to the project, rice cum fish culture might be a alternative to mitigate the effect of fish production decline. A breeding hatchery could be constructed to breed rare fishes to offset the adverse effect on fish diversity. Concerned government departments working in the project area should work closely with the community to raise awareness about the impact of overfishing, overexploitation of resources and educate people about the advantage of sustainable use of resources. Extensive monitoring activities should be undertaken by the relevant government agencies for proper implementation of EMP.
Critical Evaluation of EIA:
Morrison-Saunders (2011) identified 10 principles based on IAIA guidelines for effective EIA. Measure of EIA effectiveness of proposed project based on these principles are given below:
Principle 1: Think before act and consider alternatives (planning tool):
Five different options for the project was considered and one option was selected based on least impact which shows proper planning (Appendix-1).
Principle 2: Environmental significance screening test (environment-centred):
Screening of the project was done in accordance with the Environmental Conservation Rules (1997) of Bangladesh (Appendix-1).
Principle 3: Proponent is responsible (polluter-pays):
As the proponent for this project is a government agency, they are bound by law to be responsible. Although sometimes its difficult for a government agency to enforce law upon another government agency because of complex bureaucratic issues (Momtaz 2011).
Principle 4: Identify, predict, monitor and mitigate environmental effects (rational-scientific process):
Various possible factors were identified, their possible impact was identified, and mitigation measures of adverse environmental effect was prescribed in EMP of EIA report. Haor ecosystem is the source of various ecosystem services which is valuable to humans (Sun, Zhen & Miah 2017). But in the EIA report, ecosystem services of haor area were not systematically identified. Ahmed & Ferdausi (2016) identified lack of proper framework for monitoring and auditing the EMP process as major weakness of EIA implementation process. Proper monitoring framework is also absent in the EIA.
Principle 5: Equitable environmental protection now and for long term (sustainability):
According to Social Watch, 2018 there is lack of integration of SDG principles in Bangladesh national plans such as seventh five-year plan and Perspective Plan 2021. This hinders proposed projects sustainability outcome.
Principle 6: Affected persons consulted before decisions taken (natural justice):
Local community was consulted during the EIA process in the form of Public Consultation Meeting (PCMs) and their suggestion was considered. But there was no systematic stakeholder consultation to find interest groups and their relative importance for successful implementation of EIA process (Appendix-1). Public participation in EIA process is limited by law in Bangladesh (Hassan 1999). Lack of stakeholder participation in EIA process hinders the overall implementation of EIA (Momtaz 2001).
Principle 7: Transparent and open process with third party appeal rights (accountability):
When EIA is submitted to DoE of Bangladesh for environmental clearance, project proponent can submit their case in detail. Project proponent also have the right to appeal and held approving authority responsible (Ahmed & Ferdausi 2016).
Principle 8: Independent advice provided to decision-makers (integrity):
EIA of this project was done by CEGIS which is a government trustee organization whereas project proponent BWDB is also a government organization. EIA document will be assessed by DoE which is a government department. This presents a situation where bureaucratic influence may hinder independent assessment of impacts and EIA process becomes procedural rather comprehensive assessment (Kabir & Momtaz 2013). This is the result of lack of quality environmental consultants throughout Bangladesh (Ahmed & Ferdausi 2016).
Principle 9: Approval decision by elected politician (democracy):
Approval of the EIA process is finalized by the Minister of Planning as he gives his decision on the project (Circular on project approval process, Bangladesh). Minister of Planning is a elected politician, so the approval process is democratic.
Principle 10: Approval conditions legally binding, auditable and enforced (credibility):
EMP is the approval condition of the EIA process which is legally binding, auditable and enforceable by The Environment Conservation Rules 1997 of Bangladesh (Ahmed & Ferdausi 2016). Although weak institutional arrangement and lack of strong leadership in government agencies working in environmental sector is a major drawback in implementing and enforcing the EIA (Kabir & Momtaz 2013).
There are some other drawbacks in implementing systematic EIA in Bangladesh. There is lack of quality environmental professional in DoE of Bangladesh to assess the EIA process (Ahammed & Harvey 2004, Momtaz 2001). Ahammed & Harvey (2004) also identified lack of adequate best practice guidelines and scoping requirement as drawback for quality EIA. Before the approval of the project, proponent is allowed to develop the site which makes the transparent EIA process difficult (Ahmed & Ferdausi 2016). Lack of political will to strictly enforce environmental law is a major hindrance to effective EIA process (Khan & Belal 1999)
Significance of EIA in decision making:
Despite having some shortcoming and lack of adherence to best practice as discussed earlier, content of the EIA of Gungiajuri Haor lead to the decision of revising Gungiajuri Haor project by the Ministry of Planning of Bangladesh (Appendix 2). This is among very few cases in Bangladesh where project has been revised due to its adverse effect on environment. This shows the growing importance of EIA process in development context of Bangladesh (Kabir & Momtaz 2013).
Haor ecosystem is one of the most productive and diverse ecosystems of the world. Projects with major structural interventions have adversely effected the overall ecosystem of haor. This report has analyzed the EIA of Gungiajuri Haor water management project, which included some major structural interventions. EIA report has identified some major negative impacts that the project will have on the haor ecosystem. This report used the EIA as case study to find the effectiveness of EIA system in Bangladesh. This report has identified well-developed legal framework, screening mechanism and approval process for effective EIA process in Bangladesh. However, despite those advantages, lack of monitoring framework, weak institutional arrangement, lack of strong leadership and lack of quality environmental professionals hinders quality EIA assessment in Bangladesh. Government of Bangladesh should take necessary steps to address these shortcomings to improve the integration of environmental considerations into decision-making process to protect the invaluable ecosystems like haor ecosystems and other environmental resources for sustainable development.
such, the policy makers and scientific community has to definethe degree of trade off between agricultural development and ecosystem damage that would be acceptable to all and will bring sustainable socio-economic development.
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