Inadequacy of Environmental Impact Assessment (EIA) in Bangladesh

By Syed Masiur Rahman and Yusuf Adedoyin Aina
March 2005

The Authors are Research Assistants at the King Fahd University of Petroleum & Minerals in Dhahran, Saudi Arabia. → See also:

Bangladesh is a victim of local and regional environmental problems along with global problems. The major environmental concerns for Bangladesh are deforestation, deteriorating water quality, natural disasters, land degradation, salinity, unplanned urbanization, discharge of untreated sewage and industrial wastes, and so on. The first environmental activities in Bangladesh were taken as a result of the Stockholm Conference on Human Environment in 1972. As a follow up action to the Conference, the Government of Bangladesh (GoB) funded, after promulgating the Water Pollution Control Ordinance in 1973, a project primarily aimed at water pollution control. In subsequent years, various events took place. Before 1992, there were few regulations to assist environmental protection in Bangladesh. The regulations, which did exist, included the Pesticide Law (1971), the Bengal Law for Irrigation (1976) and Environmental Pollution Control Ordinance (1977). There was no statutory obligation on conducting EIA until 1992. Due to the pressure from donor agencies, EIA was undertaken by Bangladesh Government to create an embankment around the capital city of Dhaka when it flooded in 1991. In fact, donor agencies or Non Government Organizations (NGOs) have introduced the culture of EIAs voluntarily because of the implications of foreign funding.

In 1977, Environment Pollution Control Board headed by a Member of the Planning Commission and Environment Pollution Control was established. This was followed in 1977 by the establishment of the Environment Pollution Control Project, in 1985 by the establishment of the Department Pollution Control and finally, in 1989 by the restructured and renamed the Department of Environment the activities of which are overseen by a Director General.

The current EIA system in Bangladesh is inadequate even to ensure environmental sustainability at the project level let alone promote environmental considerations at the strategic level. The major inadequacies are in legislative control of the EIA, procedural appropriateness of current EIA system, institutional capacity and public participation (Ahammed and Harvey, 2004). There are no specific guidelines for conducting and reviewing the environmental assessment of non-industrial projects, for which, currently, EIAs done by the project sponsor are sent to the DOE for environmental clearance by the sectoral line agencies of the government (Ahammed and Harvey, 2004). In fact, the DOE is still following an ad hoc based procedure for giving environmental clearance of non-industrial projects. On the other hand, Strategic Environmental Assessment (SEA) is inherently suitable for taking care of non-project activities.

In Bangladesh, usually in EIA study, no alternatives in terms of design, technology or location are suggested (for e.g. EIA of Gas Infrastructure Development Project, 1994). In Jamuna Multipurpose Bridge Project, no alternative to the project site was identified in the EIA report. SEA addresses those shortcomings by offering the possibility of contemplating alternative technologies, lifestyle choices, and resource uses. The State of Environment report is strongly recommending inclusion of environmental issues in various sector policies in Bangladesh, and making the different sector policies coherent regarding environment. These aspects are not considered in the existing policy measures and action programs.

The degradation of the natural resource base and environment in Bangladesh started with various human and economic development activities due to a lack of appropriate sector policies, awareness, and integration of environment and development into conventional development strategies. The government of Bangladesh recently realized the need for concern regarding environmental issues, and started incorporating environment into policies dealing with various sectors (Bangladesh: State of the Environment, 2001). Various policies are now under preparation by the relevant ministries that aim for a sustainable approach towards environmental management and development (Bangladesh: State of the Environment, 2001). However, there is no appropriate system in place to examine and assess the environmental soundness of these policies. This shortcoming might hinder the quest of Bangladesh towards sustainability especially at the strategic level.

Studies by Ahammed and Harvey (2004) and Momtaz (2002) have shown that the EIA system in Bangladesh has not been appropriately implemented. The requirements for an effective EIA system have not been adequately fulfilled and this has affected the implementation of EIA at the strategic level.

There is the need to enhance the EIA system by improving the level of public participation, inaugurating a more effective EIA legislation and improving institutional capacity. The EIA legislation should highlight the EIA procedures and the responsibilities of stakeholders. The procedure should ensure that cumulative effects are considered and alternative plans are generated. Public participation in the EIA process should be enshrined in the legislation and the public awareness should be improved. The NGOs might play vital roles in this aspect. The capacity of government institutions (such as DoE) to implement and enforce the EIA system should be improved upon through training and the promotion of an enabling environment.

In order to ensure the consideration of environmental issues at the decision-making level, SEA system should be implemented. In the context of Bangladesh, it might be more appropriate to institute SEA as an EIA-based SEA. The present EIA mechanism can be improved by promoting EIA at the strategic level. The DoE has a vital role to play in this context by liaising with the different plan and policymaking bodies to ensure the environmental sustainability of plans, programs and policies.

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