The Rationale for SEA to Overcome the Inadequacy of Environmental Assessment in Bangladesh

http://jed.sagepub.com

Development The Journal of Environment &

DOI: 10.1177/1070496507300917 2007; 16; 227 The Journal of Environment Development

Habib M. Alshuwaikhat, Syed Masiur Rahman and Yusuf Adedoyin Aina Assessment in Bangladesh

The Rationale for SEA to Overcome the Inadequacy of Environmental

http://jed.sagepub.com/cgi/content/abstract/16/2/227 The online version of this article can be found at:

Published by:

http://www.sagepublications.com

at:can be foundThe Journal of Environment & Development Additional services and information for

http://jed.sagepub.com/cgi/alerts Email Alerts:

http://jed.sagepub.com/subscriptions Subscriptions:

http://www.sagepub.com/journalsReprints.navReprints:

http://www.sagepub.com/journalsPermissions.navPermissions:

© 2007 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution. at King Abdulaziz City for on April 11, 2008 http://jed.sagepub.comDownloaded from

http://jed.sagepub.com/cgi/alerts

http://jed.sagepub.com/subscriptions

http://www.sagepub.com/journalsReprints.nav

http://www.sagepub.com/journalsPermissions.nav


227

Authors’ Note: The authors acknowledge the support of King Fahd University of Petroleum & Minerals. Theviews and comments of the referees are also acknowledged. Address correspondence to Dr. Habib M.Alshuwaikhat, P.O. Box 1632, Dhahran 31261, Saudi Arabia. E-mail: [email protected]

The Journal of Environment& Development

Volume 16 Number 2June 2007 227–246

© 2007 Sage Publications10.1177/1070496507300917

http://jed.sagepub.comhosted at

http://online.sagepub.com

Policy Analysis

The Rationale for SEA to Overcome the Inadequacy of Environmental Assessment in BangladeshHabib M. AlshuwaikhatSyed Masiur RahmanYusuf Adedoyin AinaKing Fahd University of Petroleum & Minerals, Dhahran, Saudi Arabia

The first remarkable environmental initiatives in Bangladesh were taken because of theStockholm Conference on Human Environment in 1972. The provision that requiresEnvironmental Impact Assessment (EIA) for any new public and private project was firstincorporated in the National Environmental Policy, 1992. Still environmental degradationis one of the major concerns in Bangladesh. Like some other developing countries, it ini-tiates and conducts EIA in order to satisfy international donor agencies. Now, EIA isbecoming matured through the positive steps of government, non-governmental organiza-tions (NGOs) and international agencies. However, EIA cannot adequately address all theprevailing environmental issues in Bangladesh because of its inherent and contextual lim-itations. This article explores the evolution of environmental assessment in Bangladesh,mostly at the strategic level. It investigates some of the policy failures, which resulted dueto the absence of environmental assessment at the strategic level. Through a questionnairesurvey (e-mail) and extensive literature review, this research concludes that StrategicEnvironmental Assessment (SEA) as a process can effectively address the limitations ofEIA and contribute to policy development in order to ensure sustainable development.

Keywords: environmental assessment; SEA; EIA; sustainability; Bangladesh

Introduction

Environmental Impact Assessment (EIA) identifies and predicts the impact on theenvironment and on human health and well-being of legislative proposals, policies,programs, projects, and operational procedures, and interprets and communicatesinformation about the impacts (Munn, 1979). Due to the rapid industrialization and



population growth in developing countries and the recognition of environmentalimpacts of many development projects, EIA is adopted as a tool to help the author-ities make decisions concerning project approval. Developing countries are accept-ing more responsibility for the environmental impacts that result from theirdevelopment activities and in the last two decades many have developed EIA legis-lation as a management tool for these impacts. EIA is now practiced in more than100 countries worldwide (Donnelly, Dalal-Clayton, & Hughers, 1998). Today, EIAis firmly established in the planning process in many of these countries (Momtaz,2005). In 1989, the World Bank ruled that EIA for major projects should normallybe undertaken by the borrower country under the supervision of the World Bank. TheUnited Nations Environment Program (UNEP) also made recommendations tomember states regarding the establishment of EIA procedures and established goalsand principles for EIA. It subsequently issued guidance on EIA in developingcountries (UNEP, 1988). In the early 1990s, researchers studied the limitations ofproject-level EIA (Glasson, Therivel, & Chadwick, 1994; Lee & Walsh, 1992). Theirfindings led to the introduction of a different procedure from the project-level EIAto ensure environmental considerations. Briffett (1999) suggests that despite theexistence of good EIA guidelines and legislation, environmental degradation contin-ues to be a major concern in developing countries. EIAs have not been able to pro-vide ‘environmental sustainability assurance’ (ESA) for these countries (Sadler,1999).

Based on the research works of Glasson et al. (1994) and Lee and Walsh (1992),Alshuwaikhat (2005: 308) summarizes the limitation of project-level EIA as:

1. Project EIAs react to development proposals rather than anticipate them.2. Project EIAs do not adequately consider the cumulative impacts caused by several

projects or even by one project’s subcomponents or ancillary developments.3. Some small individual activities are harmless, but the impact of those activities can

be significant, which cannot be addressed by project EIAs.4. Before preparation of the EIA, a project can be planned quite specifically, with irre-

versible decisions taken.5. Project EIAs cannot address the impacts of potentially damaging actions that are

not regulated through the approval of specific projects.6. Project EIAs often have to be carried out in a very short period of time because of

financial constraints and the timing of planning applications.7. Assessing impacts from ancillary developments, difficulties can arise in evaluating

the environmental impacts, which may result from indirect and induced activitiesstemming from a major development.

8. Foreclosure of alternatives, typically, by the project assessment stage, a number ofoptions, which have potentially different environmental consequences from thechosen one, have been eliminated by decisions taken at earlier stages in the plan-ning process, at which no satisfactory environmental assessment may have takenplace.

228 The Journal of Environment & Development



In general, SEA is described as the process for assessing the potential environ-mental impacts caused by a proposed policy, plan, or program. It is the formalized,systematic, and comprehensive process of evaluating the environmental impacts of apolicy, plan, or program and its alternatives, including the preparation of writtenreports on the findings of that evaluation, and using the findings in publicly account-able decision making (Therivel, Wilson, Thompson, Heaney, & Pritchard, 1992). Itis, in other words, the EIA of policies, plans, and programs, keeping in mind that theprocess of evaluating environmental impacts at a strategic level is not necessarily thesame as that at a project level (Glasson et al., 1994).

At the end of the 1990s, the term SEA was used in an interchangeable manner fora wide range of different kinds of assessments, ranging from policy assessment forcomplex multisectoral systems to the assessment of large projects (Tomlinson, 2000).In general, SEA involves the early consideration of environmental issues in policy,plan, and program decision making but there is no clear consensus on the definitionof SEA based on its strategic characteristics (Noble, 2000). Sadler and Verheem(1996) emphasize the consideration of environmental consequences at the earliestappropriate stage of decision making, along with economic and social considerations.Barrow (1997) emphasizes a ‘tiered, nested, or sequential’ framework within whichproject, program, and policy assessment can take place. The Council for Scientificand Industrial Research (CSIR, 1996) emphasizes ‘issues driven’ and ‘participative’approaches to the environmental assessment of plans and policies. The majority ofdefinitions proposed in the literature define strategic environmental assessment usingthe term strategic with little explanation as to what it means and subsequently,therefore, what makes SEA strategic (Noble, 2000).

Sadler (2001) summarized the evolution of SEA into three stages. He termed theperiod from 1970 to 1989 the “formative stage” because the role and scope of SEA waslimited and restricted to a few countries, such as the United States, Canada, theNetherlands, and Australia. The next period of development of the SEA system, whichis the “formalization stage,” lasted from 1990 to 2000. During this period, SEA wasintroduced to a number of countries and became diversified. Finally, in the last period,which is called the “extension stage” (from 2001 to now), SEA appears to be on thethreshold of widespread adoption and further consolidation as a result of internationallegal and policy development (Ministry of Environment, Government of Japan, 2003).However, considering the strategic characteristics SEA can be defined as “the proac-tive assessment of alternatives to proposed or existing PPPs, in the context of a broadervision, set of goals, or objectives to assess the likely outcomes of various means toselect the best alternative(s) to reach desired ends” (Noble, 2000, p. 205).

Stinchcombe and Gibson (2001) found ten key benefits of SEA for sustainability,which are as follows:

• Provides a process for integrated pursuit of sustainability objectives in policy mak-ing and planning;

Alshuwaikhat et al. / The Rationale for SEA to Overcome the Inadequacy 229



• Operationalizes sustainability principles;• Improves the information base for policy making, planning and program develop-

ment;• Is proactive and broad in ways that strengthen consideration of fundamental issues;• Improves analysis of broad public purposes and alternatives;• Facilitates proper attention to cumulative effects;• Facilitates greater transparency and more effective public participation at the strate-

gic level;• Provides a framework for more effective and efficient project-level assessments;• Provides a base for design and implementation of better projects where project-level

assessment is not required;• Facilitates establishment of a more comprehensive overall system of sustainability

application at all levels from the setting of decision objectives to the monitoring ofimplementations effects.

On the other hand, “arguments were raised that broad principles of EIA werealready incorporated in the decision-making processes . . . and that the adoption ofSEA in a systematic manner would represent only marginal benefits” (Partidario,2000, p. 651). Moreover, the initially popular form of SEA includes similar kinds ofEIA procedure, and SEA was considered as making the planning practices andprocedures more complex (Partidario, 2000).

In the context of Bangladesh, environmental assessment procedure has beenlimited to project-level EIA, which has not been effectively implemented.Ahammed and Harvey (2004) evaluated the EIA system in Bangladesh andconcluded that:

• There is a need for clear EIA guidelines.• Capacity building should be a priority both within and outside the government at

various levels.• It is required to strengthen the enforcement mechanism of the Department of

Environment (DOE).• The [Ministry of Environment and Forestry] MOEF/DOE should establish formal

linkages wit h universities, research organizations, and NGOs within the county toshare expertise.

This study examines the improvement of Bangladesh environmental assessmentsystems through the implementation of SEA. The adopted research approach includesthe analysis of responses from governmental officials, academicians, environmentalconsultants, and researchers in reply to an e-mail questionnaire containing both objec-tive and open-ended questions. An extensive literature search was also conducted tocomplement the survey. The first part of the article introduces the EIA in developingcountries and SEA in general, the second part examines the historical developmentof environmental assessment, some environmental policies and the policy-making




process in Bangladesh, the third part highlights key policy failures that buttress theneed for SEA. The article concludes by arguing for the implementation of SEA inBangladesh.

Current Status of Environmental Assessment in Bangladesh

Historical Development of Environmental Assessment

Bangladesh is a victim of local and regional environmental problems, as well asglobal problems. The major environmental concerns for Bangladesh are deforesta-tion, deteriorating water quality, natural disasters, land degradation, salinity, unplannedurbanization, discharge of untreated sewage and industrial wastes, and so on. Thefirst environmental activities in Bangladesh were taken because of the StockholmConference on Human Environment in 1972. As a follow-up action to the confer-ence, the Government of Bangladesh (GoB) funded, after promulgating the WaterPollution Control Ordinance in 1973, a project primarily aimed at water pollutioncontrol. In subsequent years, various events took place. Before 1992, there were fewregulations to assist environmental protection in Bangladesh. The regulations thatdid exist included the Pesticide Law (1971), the Bengal Law for Irrigation (1976),and the Environmental Pollution Control Ordinance (1977).

In 1977, the Environment Pollution Control Board, headed by a member of thePlanning Commission and Environment Pollution Control, was established. Thiswas followed in 1977 by the establishment of the Environment Pollution ControlProject, in 1985 by the establishment of the Department of Pollution Control, andfinally, in 1989 by its restructuring and renaming as the Department of Environment,the activities of which are overseen by a director general.

There was no statutory obligation on conducting EIA until 1995. The voluntaryundertaking of EIA by donor agencies in the late 1980s created indirect pressure ongovernment, which undertook EIA for a project to create an embankment around thecapital city of Dhaka when it flooded in 1991. In fact, the culture of EIAs was intro-duced voluntarily by donor agencies or NGOs because of the implications for for-eign funding. The major events related to the environment in Bangladesh can besummarized as shown in Table 1.

MOEF identified EIA as a management tool in 1992 for sustainable developmentof the country. In line with the general recommendations of the Rio Earth Summit,the National Environmental Policy was framed in 1992 for the protection of the envi-ronment in Bangladesh (Ahammed & Harvey, 2004). The provision to require EIAfor any new public and private project was first incorporated in the NationalEnvironmental Policy, 1992. In the adopted EIA processes in Bangladesh, publicparticipation is not an obligatory element (Figure 1).

DOE (1997) published a book on EIA to fulfill the needs of environmentalists.It addresses the issues related to the EIA of industries. It provides EIA guidelines




for a few sectors, including cement manufacturing plants, fertilizer plants, andpulp and timber processing. The International Union for Conservation of Natureand Natural Resources (IUCN) and the Government of Bangladesh (GoB) developa draft National Conservation Strategy in 1992 (Ahammed & Harvey, 2004). DOEdoes not prepare any guidelines regarding the authority to carry out EIA.Therefore, the entrepreneurs themselves can conduct EIA and provide the state-ments. They can also seek help from local or foreign consultants. If there are EIAguidelines in any sector then DOE suggests the corresponding industries followthem. Entrepreneurs in sectors that do not have guidelines are required to followinternational guidelines, especially those of the World Bank and the AsianDevelopment Bank.


Table 1Major Events Related to Environmental Initiatives in Bangladesh

Year Event

1973 Declaration of Water Control Act1977 Declaration of Environment Pollution Control Act and the establishment of the

Department of Environment Pollution Control (DEPC)1989 Inception of the Ministry of Environment and Forestry (MOEF), DEPC is renamed to

Department of Environment (DOE) and brought under MOEF1992 Declaration of Environmental Policy, 1992

Country report on Bangladesh along with the participation in the conference of RioEarth Summit

Signing in UNFCC on climate change.Signing in Biodiversity Convention (CBD).Inception of National Environment Management Action Plan (NEMAP).Development of National Environment Council (NEC)First EIA guidelines through Flood Action Plan (FAP)Development of EIA guidelines for small-scale water resource development project

under Local Government Engineering Department (LGED)1993–1994 Signing in UNFCC and CBD by National Parliament, Preparation of NEMAP1995 Improvement of NEMAP by participation

First EIA legislation ECA, 19951996 Declaration of Environment Conservation Act, 1995; initiation of the implementation of

National Environment Conservation StrategyNEMAP is prepared and accepted

1997 Declaration of the Environmental Conservation Rules,1997 to enforce ECA, 1995;improvement of the implementation act of NEMAP; second meeting of NEC is heldunder the chairman, the prime minister

1998–2003 Implementation of NEMAPPreparation of EIA field handbook for rural road improvement projects by CARE

Bangladesh & USAID IN 1998.2001 Major review of FAP’s 1992 guidelines through Water Resource Planning Organization

(WARPO)



Policy Initiatives Toward Environmental Impact Assessments

A cabinet headed by the prime minister and comprised of other ministers formu-lates policies and takes key decisions on matters relating to governance of the coun-try. Then legislators help to enact laws to affect the cabinet policies through scrutinyand debate in the Parliament. The business of governance is carried out through min-istries, which are manned by civil servants of the republic, with directorates, depart-ments, corporations, and statutory bodies to execute government decisions anddirectives. The Planning Commission examines the development projects of variousorganizations in order to assess their feasibility and inclusion in the AnnualDevelopment Programs (ADP). On the other hand, fund allocation is the responsi-bility of the National Economic Council (NEC), which is the highest economicpolicy-making body, headed by the prime minister (Figure 2).

After the independence of Bangladesh, many policies were developed to take careof the environment. Some of them are discussed below to represent the focus ofthose environmental policies. These policies reflect the institutional development ofthe environmental sector within the country, which will help to demonstrate govern-mental efforts towards this sector and the understanding of the sustainability conceptwithin the government.

In 1989 a new Ministry of Environment and Forests was created and theDepartment of Environment Pollution Control (DEPC) was renamed the DOE andbrought under the control of the ministry. In May 1992, a national environmental


Figure 1EIA Processes in Bangladesh

Project Proposal

Screening by DOE

IEE, EIA or both required

IEE preparation

Approved by DOE Rejected by DOE

EIA preparation, and Review by DOE

Source: Based on Harvey and Ahammad (2004).



policy was approved, along with a national environmental action plan. According tothis policy, DOE will evaluate and monitor all EIAs. This policy demanded to deter-mine an EIA index for all government and non-government industries that haveimpacts on the environment, and to conduct EIAs for fuel and mineral resourcesexploration projects before they start.

One of the main aims of the Industry Policy, 1991 is to take necessary actions inorder to control environmental pollution and maintain the equilibrium of the envi-ronment. It contains a chapter on the monetary incentives for industries. However, itdoes not contain any sort of incentives for environment pollution control manage-ment. There are 17 members on an executive committee under this policy. However,there is no member from DOE. Even the Divisional Industry Development Committeedoes not have a single representative of DOE.

The National Water Policy, 1998 declares that a National Water Management Plan(NWMP) will be prepared and it will be updated regularly. In the planning processthe participation of people of all classes and sectors is mandatory. Moreover, Socialand Environmental Assessments will be obligatory. All agencies and departmentsrelated to water resources are supposed to work according to the NWMP in order toconserve the environment and improve it. They are supposed to follow the EIAguidelines and Water Sector Project Manual to conduct EIA officially. This policy isa very first step to change the approach to water management from the dominanceof floods as the issue and infrastructure as the solution to a new policy emphasizinginstitutional change. The WARPO, an institution under the Ministry of WaterResources, was the main contributor of the preparation of NWMP, which aims totranslate the National Water Policy into 84 programs within the framework ofIntegrated Water Resources Management (IWRM).

The National Energy Policy was prepared in 1995 and adopted in 1996. Accordingto the policy, the Planning Commission, along with different ministries and agencies,


Figure 2The Policy-Making Process in Bangladesh

Parliament

Cabinet headed by the Prime Minister

MOEF Other Ministries

DOE Corresponding Departments



are involved directly and indirectly with the planning of commercial energyresources and biomass fuels. Different ministries and agencies involved with overalldevelopment and management of energy resources are shown in the same policy.There are four suggestions under the Environment Policy chapter, which are asfollows:

1. EIA is to be obligatory and it will become an indispensable part of any new fueldevelopment project.

2. The use of environment-friendly and economically viable technology should beencouraged.

3. The use of firewood is to be discouraged and the supply of alternative fuel at rea-sonable prices is to be increased.

4. Public awareness regarding environment conservation is to be increased.

According to the power policy, power subsector development should be appro-priate in terms of environmental effects and based on the cheapest production cost.For any power production project, it will be compulsory to conduct EIA. However,this assessment is to be issued quickly to meet the schedule and lessen unnecessarycosts. DOE will guide the EIA for power production and general projects. All therules, regulations, instructions, and standards developed during the project planningwill be applied for all new projects.

The Petroleum Policy, 1995 aims to provide the guidelines of EIA in the explo-ration of liquid, gaseous, or solid hydrocarbons, broadly in the petroleum sector. Dueto the guidelines of the policy, the establishment of new refineries in the privatesector does not require governmental permission. This policy permits the use ofConservation National Guidelines (CNG) for all sorts of land and water transports.In those cases, all the laws, rules, regulations, and guidelines of government are tobe obeyed for the sake of environmental conservation.

Analysis of Selected Program(s) and Polic(ies)

Food for Work Program

The Ministry of Relief and Rehabilitation initiated the Food for Work Programin 1975, which employed landless people on earthen road construction in ruralareas 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 ruralareas during the slack season (Nakashima & Khan, 1994). In 1990, a program-matic environmental assessment (PEA) was conducted to assess the success ofIFFW under the supervision of the Cooperative for Assistance and Relief Everywhere(CARE). A social soundness analysis was also conducted. These two studiesrevealed that the programs negatively impacted the Bangladesh environment




through damaging wetland ecosystems, flooding, loss of agricultural land, anddeclining numbers of fish species, and they also contributed to polarization ofpower and resources and inequality in rural areas. The benefits of FFWP were notonly undermined by this but also the outcomes were inconsistent with the coun-try’s sustainable development goals (Khan & Fitzcharles, 1998). These revelationsinfluenced the CARE to perceive EIA as “EIA examines problems, conflicts andnatural resource constraints that could affect the viability of a project. It investi-gates how project might cause harm to people, their homelands or their livelihoodsand to other nearby developments” (Nakashima & Khan, 1994, p. 12). Theconsiderations of sustainability concepts at the early stage of the programdevelopment could pinpoint the consequences, which were revealed during or afterthe project implementation.

National Water Policy

Due to the severe floods of 1987 and 1988, GoB decided to go for the FloodAction Plan (FAP) and “accepted the policy of high degree of structural protectionas a key element of the long term comprehensive flood control program” (http://banglapedia.com.bd). Some of the conclusions drawn by International Rivers Network(1992) on the Bangladesh Flood Action Plan are as follows:

1. The FAP cannot be justified economically on flood control grounds, and insteadrelies on the economic benefits of expected increases in food production, in effectbecoming a food action plan.

2. Canalization of the heavily sediment-laden rivers of Bangladesh will likely lead tosedimentation between the embankments, reducing flood control capacity andrequiring continual expensive raising of embankment heights.

3. The risk of catastrophic flooding, due to embankment failure, will be increased forareas “protected” by embankments.

4. Earthquakes capable of destroying the FAP embankments system can be expectedto occur during the lifetime of the project, causing floods greater in severity thanwould occur without embankments.

5. By blocking fish migration paths between rivers and submerged floodplain fields,the embankments of the FAP will likely result in significant adverse effects on thenation’s freshwater fisheries.

6. The FAP will require forced displacement of up to eight million people, andwill threaten the livelihoods of millions of other Bangladeshi farmers, creatingsignificant political and social obstacles, which could threaten the entireproject.

7. There has been minimal opportunity for participation by local communities whoare intended to benefit from the FAP and whose cooperation is essential to thePlan’s success according to the United Nations Development Program.

8. The World Bank is moving with FAP structural flood control projects before essen-tial studies of potential environmental and social impacts are complete.




The water development strategy of Bangladesh has so far been characterized byattempts to cordon off floodplains from adjoining rivers by creating polders, whichhas aggravated problems of flooding, drainage, soil quality, sanitation, preservation offreshwater fish stock, functioning of waterways, temperature balance, etc. The cordonapproach should be abandoned and instead rivers and other surface water bodies ofBangladesh should be preserved by adopting the ecology- and environment-friendlyapproach (International Rivers Network, 1992). In the report of FAP, EIA is used onlyto assess projects expecting to gain attention at the strategic level without clarifica-tion. The early considerations of the sustainability concept at the strategic levelthrough SEA could reveal the flaws of the FAP. In the proposed approach, which isdiscussed later, an independent body (IB) that consists of NGOs, international donoragencies, research and think tanks, and other independent organizations could shedlight on the issues that were identified by International Rivers Network.

Bangladesh is severely affected by arsenic contamination of groundwater, whichhad become the safest source of drinking water through the campaign of interna-tional agencies. Over a period of about 20 to 25 years about four million wells wereinstalled to utilize the groundwater from deeper aquifer layers, typically less than200 m deep (UNICEF, 1999). Exploitation of groundwater from these wells hasresulted in mobilizing the arsenic and led to mass poisoning in the region, which isdefined by the generic term arsenic sis (Rahman et al., 2001). “In the 1970s, inter-national agencies headed by the United Nations Children’s Fund (UNICEF) beganpumping millions of dollars of aid money into Bangladesh for tube-wells to provide‘clean’ drinking water. According to the World Health Organization, the directresult has been the biggest outbreak of mass poisoning in history” (Pearce, 2001).

UNICEF explains today “at the time, standard procedures for testing the safety ofgroundwater did not include tests for arsenic [which] had never before been found inthe kind of geological formations that exist in Bangladesh.” However, many geo-chemists, such as John McArthur at University College London, scoff at such a sug-gestion. They blame dogma among public health people with no knowledge of geology,and who equated underground water with safe water. (Pearce, 2001)

Therefore, it is not an exaggeration to conclude that adequate assessment was notconducted to find out the impacts of the policy on groundwater for drinking purposes.Still, a large quantity of contaminated groundwater is being utilized for irrigation pur-poses without scientific study of the potential uptake of arsenic into plants and foods.The impacts of the arsenic pollution on this worsening food security have not beenconsidered explicitly. The issues of food security, both science- and policy oriented,have to be considered in developing overall strategies for addressing the arsenic con-tamination problem. However, it can be concluded that government and internationaldonor agencies did not give enough attention to the environmental and social impactsbefore formulating and implementing the policies.




Agricultural and Industrial Policy

Dependence on chemical fertilizer and pesticides for higher crop yields is con-tributing to surface-water pollution in Bangladesh (Dhaka Declaration on BangladeshEnvironment, 2002). The analysis of prevalent agricultural policy reveals that theymostly emphasize economic aspects without much consideration of social and envi-ronmental aspects. “The government has adopted an approach of chemical agricultureand is focused on cropping systems rather than on integrated farming systems”(http://www.fao.org/). At the strategic level the consultation between the concernedministry, MOEF, and IB could develop an approach leading to sustainable agricul-ture. Specifically for the formulation of agricultural policies, government shouldconsult with farmers and NGOs, and involve them rather than relying solely on“experts.” At the strategic level, any proposed agricultural policy should be assessedfor productivity, sustainability, stability, and equity.

Industrial and urban wastes, agrochemicals, sewerage wastes, and seawater intru-sion are major sources of surface-water pollution in Bangladesh (http://banglapedia.com). Export Processing Zones (EPZ) set up in different parts of the country areadding seriously to the problem of surface-water pollution. Industrial waste hasalways been an important source of pollution of surrounding landmass, water bod-ies, and air. Setting up of EPZ in different districts is now spreading the threat ofindustrial pollution all across the country. The poultry farming industry has alsobecome a new source of pollution. These environmental and social threats are com-ing into being because of decision-making processes that did not take care of sus-tainable issues at the strategic level. The government usually prioritizes financialbenefits over social and environmental concerns during the formulation of any poli-cies, which is also reflected in the discussion of previous policies.

Discussion

Inadequacy of Environmental Impact Assessment

Ahammed and Harvey (2004) have highlighted that the major inadequacies of theBangladesh EIA system are in legislative control of the EIA, procedural appropriate-ness of the current EIA system, institutional capacity, and public participation. Theynoted that there are no specific guidelines for conducting and reviewing the environ-mental assessment of nonindustrial projects, for which, currently, EIAs done by theproject sponsor are sent to the DOE for environmental clearance by the sectoral lineagencies of the government. The DOE still adopts an ad hoc procedure for givingenvironmental clearance of nonindustrial projects. In essence, the current EIA systemin Bangladesh is inadequate even to ensure environmental sustainability at the projectlevel, let alone promote environmental considerations at the strategic level. Unlike theEIA procedure, SEA is inherently suitable for taking care of non-project activities.




Human and economic development activities have resulted in the degradation of thenatural resource base and environment in Bangladesh because of lack of appropriatesector policies, awareness, and integration of environment and development into con-ventional development strategies. The Government of Bangladesh has recently real-ized the need for paying due attention to environmental issues, and has startedincorporating environmental considerations into policies dealing with various sectors(Bangladesh: State of the Environment, 2001). The relevant ministries are now prepar-ing numerous policies that aim at a sustainable approach to environmental manage-ment and development (Bangladesh: State of the Environment, 2001). However, theappropriate framework or system for examining and assessing the environmentalimplications of these policies has not been developed. The State of the Environmentreport strongly recommends the inclusion of environmental issues in various sectorpolicies in Bangladesh, and making the different sector policies coherent with envi-ronmental sustainability principles. These aspects are not considered in the existingpolicy measures and action programs. The quest of Bangladesh towards sustainabilityespecially at the strategic level might be hindered by the shortcoming.

Studies by Ahammed and Harvey (2004) and Momtaz (2002) have shown that theEIA system in Bangladesh has not been appropriately implemented. The require-ments for an effective EIA system have not been adequately fulfilled and this hasaffected the implementation of EIA at the strategic level. The different policy fail-ures mentioned above indicate that EIA at the strategic level is not sufficient. Thesefailures underscore the need for an adequate implementation of SEA. In order to fur-ther buttress the need for EIA at the strategic level, an electronic mail survey wascarried out to provide an overview of the existing system. The authors chose thee-mail survey because it is difficult and costly to collect information from the expertsthrough other available means. We selected experts who are working on environ-mental issues of Bangladesh mostly through the help of the Web. We also selectedexperts who contributed mainly in environmental assessment related issues inBangladesh through publications. More than 50 questionnaires were sent by e-mailto officials in government organizations, universities, and research institutes, andnine responses (about 25%) were received. The responses indicated that about halfof the respondents have actually carried out an environmental assessment of policiesand programs. About two thirds of the respondents noted that environmental effectsof policies and programs are considered but they indicated that economic consider-ations, most of the time, do override the concern for the environment. Most of theexperts disagree with the following statement:

The level of public awareness and consultation in the planning and policy making pro-cess is adequate for environmental or sustainability appraisal.

Most of the respondents (about 95%) opined that the present institutional frameworkin Bangladesh is not adequate for the integration of SEA into the decision-making




process. It seems that they are referring to immediate adoption of SEA without ground-work. This article suggests that a few changes in the existing policy-making process(which will be discussed in the next section), along with the suggestions of the experts,can foster the adoption of SEA and contribute to good governance. The experts foreseeparticular problems for Bangladesh in developing the capacity to undertake environ-mental or sustainability appraisal of plans, which are as follows:

1. A general lack of understanding relating to what constitutes environmental sus-tainability.

2. Lack of ability of environmental and other regulatory authorities to assess EIAsand use them to guide sustainable development.

3. Lack of political commitment, community awareness, and expertise in the field.4. Resource constraints, corruption, and potential implementation problems, etc.5. Lack of a proper enforcement regime, an independent body to carry out EIA, ade-

quate financing, and absence of a proper mentality among the project proponents.

The experts made the following suggestions for successful implementation ofenvironmental assessment of plans and policies in Bangladesh.

1. To create an atmosphere in which the project proponents feel that EIA is not anunnecessary burden on them and to strengthen the enforcement regime.

2. A strong political commitment.3. A multisectoral agency that is able to provide frameworks for suitable EIA processes.4. Availability of sufficient financial and human resources.5. Community involvement in the planning process.6. Acceptance of an independent statutory authority by other relevant government

organizations.7. Effective legislation and goodwill of every authority to implement that legislation.8. A corruption-free socioeconomic and political system.9. Policies that address the three sustainability objectives, that is, economic develop-

ment, social development, and environmental sustainability.

Rationale, Prospect, and Framework of SEA

In Bangladesh, the current EIA process suffers from a number of common and con-tinuing problems that need to be addressed earlier at the strategic level. For example,land-use allocations in the planning process, policy decisions on technological andsocioeconomic issues relating to various sectors, and the setting of programs forprogressive developments in large areas, are to be decided before a project-based envi-ronmental assessment is undertaken (Briffet, Obbard, & Mackee, 2004). In addition tolocal contexts, which have shown the need for SEA, international practice alsoindicates the desirability of incorporating SEA into decision making to ensureenvironmental sustainability at the strategic level. EIA practice is constrained by




certain limitations and weakness, which are centered on the relatively late stage atwhich EIA is usually applied in decision making. Consequently, high-order decisionsregarding type and location of development have taken place with little or no environ-mental analysis. Project-by-project EIA also cannot take care of these issues. SEA cancomplement project-level EIA to incorporate environmental considerations and alter-natives directly into policy, plan, and program design. As a proactive approach, SEAidentifies alternative desired ends and seeks the preferred option among a variety ofalternative options to reach the most desired end. Ideally, SEA and EIA are consideredin sequence where SEA proactively examines a broad range of alternatives and selectsthe preferred course of action, and EIA is initiated reactively to determine in detail thepotential impacts of the preferred alternative (Noble, 2000). On the other hand, accord-ing to Partidario (2000), the concept of SEA is not related to impact assessment for along time and it is better represented by policy and planning tools where the aim is topreventively assist sound decision making. “The recognition and clear identification ofthe added value of SEA to decision making must be at the forefront of the debate andof the conceptualization of forms of SEA that satisfy existing decision-making proce-dures” (Partidario, 2000, p. 648).

SEA is to be introduced as a means of encouraging attention to matters neglectedin conventional decision making. It is an assessment process, which can be initiatedas a complement to narrow and fragmented conventional decision making, but thatcan reform and supplant the conventional approaches. SEA is gaining recognition asa supporting tool for decision making towards achieving sustainable development(Noble & Storey 2001; Brown & Therivel, 2000; Fischer, 1999). SEA is expresslyadopted as a visible confirmation of commitment to sustainability, and it necessarilyprovides a venue for closer attention to what sustainability means (Stinchcombe andGibson, 2001). It ensures broader exposure to notions such as carrying capacity, nat-ural capital, the precautionary principle, and intergenerational equity, and can trans-late the ideas of sustainability into the language of politics as a heuristic device(Therivel et al., 1992). SEA improves the information base for strategic-level deci-sions in two ways: by incorporating considerations traditionally neglected in con-ventional processes, and by introducing more sophisticated principles, concepts, andmethodologies (Stinchcombe and Gibson, 2001). These effects on the framework forinformation gathering influence the nature and quality of the information available,along with its organization and interpretation. SEA offers an opportunity to addresscumulative effects, which cannot be properly handled by EIA because of the perva-sive nature of cumulative effects and large-scale environmental change. Forexample, in Malaysia the types of project that require EIA under the legislation areincluded in a handbook, along with some quantitative guidelines, such as thatproposed developments on hillside or hilltop sites exceeding 50 hectares should besubjected to EIA. Unfortunately, these requirements are vulnerable to abuse throughmultiple submissions of mini projects, which, in combination, exceed the limitsstated (Briffet et al., 2004).




SEA can be used to assess regional and sectoral effects and integrate them intothe consideration of potential cumulative and synergistic effects from a strategic per-spective (Environment Canada, 2003). SEA offers the possibility of contemplatingalternative technologies, lifestyle choices, and resource uses that cannot be addressedpractically at lower levels (Stinchcombe and Gibson, 2001). For example, seriousevaluation of alternative transportation modes, such as public transit, is unlikely inthe assessment of a detailed road expansion proposal, even though the transit optionmay represent the best means of meeting transportation, ecology, and equity objec-tives, but it would be entirely appropriate in the assessment of transportation policygenerally (Wood & Dejeddour, 1992).

Bangladesh is one of the countries in the world identified as corrupted, whichundermines economic growth (Transparency International, 2005). This corruptionalso plays a negative role in the efficient implementation of any sustainability efforts.According to Ahmad (2001, p. 9), “Governance in Bangladesh suffers from trans-parency and accountability problems, confrontational politics, absence of consensuson basic national issues among major political parties, pervasive corruption, andbureaucratic procrastination and hurdles.” A transparent decision-making process isone of the vital elements in the success of any sustainability-led efforts. The responsesof the experts show the concern about a corrupted system of governance. The adop-tion of SEA along with an IB will improve the transparency of the decision-makingprocess, strengthen the PPP making process, and finally ensure good governance thatis trusted by the public. The formation of an IB should include NGOs, research andpolicy think tanks, international donor agencies, etc., to help in maintaining sustain-ability of the proposed policy, program or plan (PPPs) (Figure 3). However, this mod-ification should be mandated by legal requirements in order to ensure transparentdecision making led by the sustainability concept.

In the proposed policy-making process, the Cabinet will formulate the requiredapproach and details of adopted SEA with the consultation and recommendations ofIB and the ministries. In Bangladesh, research and policy think tanks such as theBangladesh Center for Advanced Studies (BCAS), Bangladesh Unnayan Parishad(BUP), the Centre for Policy Dialogue (CPD), the Institute for Development PolicyAnalysis and Advocacy of Proshika have programs to fill the existing gaps betweengovernment and communities. Those organizations interact with the policy planners,government agencies, donors, and the NGOs so that the results of research can beused at both policy and implementation levels. Those NGOs and research organiza-tions are the potential members of the proposed IB. The members of the IB will beselected in such a way that it will ensure the best probable participation of the con-cerned scientific community.

The existing National Environment Committee headed by the prime minister willconduct the screening process of SEA. The implementation of SEA is to be initiatedunder the MOEF facilitated by IB. This independent wing helps the Cabinet to ensuresustainability of any policy formulated by a ministry and conduct SEA auditing. SEAwill influence the decision makers to perceive the greater importance of sustainability




of PPPs. The better understanding of sustainability issues among the decision makerswill eventually wipe out some drawbacks of the existing EIA practices.

In Bangladesh, usually in EIA study, no alternatives in terms of design, technol-ogy, or location are suggested (e.g., EIA of the Gas Infrastructure DevelopmentProject, 1994). In the Jamuna Multipurpose Bridge Project, no alternative to the pro-ject site was identified in the EIA report. SEA addresses those shortcomings byoffering the possibility of contemplating alternative technologies, lifestyle choices,and resource uses. Nevertheless, a properly designed SEA is to be adopted to getthese inherent benefits of SEA. In our proposed public participatory SEA, the IB willcontinuously create pressure on the government to ensure a sustainable decision-making process. As the IB will bring the proposed policy issues to the public, thegovernment will feel obliged to stick to the sustainability principles. If the politicalcommitment towards the environmental concerns at the PPP level can be mandatedthen other problems found out by the experts through questionnaires, such ascapacity building and financial resources, can be easily solved.

The discussion in this section and the previous one does not conclude that theimplementation of SEA will eventually solve all the inadequacies of EIA prevalent inBangladesh. But SEA will significantly contribute in good governance practices,increase awareness among the high-level decision makers, and force the governmentto stick to a transparent and sustainable policy-making process. A properly designedSEA ensure a sustainable decision-making process by informing decision makers andstakeholders about the sustainability of strategic actions, aiding in the identification


Figure 3Modified Policy-Making Process and Adoption of SEA

Note: SEA = Strategic Environmental Assessment.



of best alternatives, and establishing a democratic decision-making process (IAIA,2002). Those improvements in the policy-making process will eventually ensurebetter EIA practices in Bangladesh.

Conclusions

The premise of this article is that if the current EIA system in Bangladesh cannotensure adequate environmental consideration at the project level then the environ-mental sustainability of policies and programs cannot be ensured. Thus, there is theneed for a more adequate system based on SEA. The review of the literature and theresponses from the survey have shown that the EIA system is lacking and inade-quate, especially for the environmental assessment of policies, plans, and programs.This has implications for the environmental sustainability of Bangladesh bearing inmind the environmental sensitivity and vulnerability of the country.

There is the need to enhance the EIA system by improving the level of public par-ticipation, inaugurating a more effective EIA legislation and improving institutionalcapacity. The EIA legislation should highlight the EIA procedures and the responsi-bilities of stakeholders. The procedure should ensure that cumulative effects are con-sidered and alternative plans are generated. Public participation in the EIA processshould 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 institu-tions (such as DOE) to implement and enforce the EIA system should be improvedupon through training and the promotion of an enabling environment.

In order to ensure the consideration of environmental issues at the decision-making level, the SEA system should be implemented. The survey revealed thatthere is an explicit concern against the political commitment and governance system,which hinders the path of sustainable development. A properly designed SEA is tobe adopted to get the inherent benefits of SEA. In our proposed public participatorySEA, the IB will continuously create pressure on the government to ensure a sus-tainable decision-making process. As the IB will bring the proposed policy issues tothe public, the government will feel obliged to stick to the sustainability principles.If the political commitment towards the environmental concerns at the PPP level canbe mandated then other problems found out by the experts through questionnaires,such as capacity building and financial resources, can be addressed.

Acknowledgment

The authors acknowledge the support of King Fahd University of Petroleum &Minerals. The view and the comments of the referees are also acknowledged.




References

Ahammed, R., & Harvey, N. (2004). Evaluation of environmental impact assessment procedures andpractice in Bangladesh. Impact Assessment and Project Appraisal, 22(1), 63–78.

Ahmad, Q. K. (2001, September 4). Perspectives on sustainable development in Bangladesh. Paper pre-sented at a Roundtable on Bangladesh Perspectives toward 2002 World Summit on SustainableDevelopment, Bangladesh Institute of International and Strategic Studies (BIISS) & BangladeshUnnayan Parishad (BUP), Dhaka.

Alshuwaikhat, H. (2005). Strategic environmental assessment can help solve environmental impactassessment failures in developing countries. Environmental Impact Assessment Review, 25, 307–317.

Bangladesh: State of the environment. (2001). Geneva: United Nations Environment Program (UNEP).Barrow, C. J. (1997). Environmental and social impact assessment: An introduction. London: Arnold.Briffett, C. (1999). Environmental impact assessment in East Asia. In J. Petts (Ed.), Handbook of envi-

ronmental impact assessment (Vol. 2). Oxford: Blackwell.Briffett, C., Obbard, J., & Mackee, J. (2004). Environmental assessment in Malaysia: A means to an end

or a new beginning? Impact Assessment and Project Appraisal, 22(3), 221–233.Brown, A. L., & Therivel, R. (2000). Principles to guide the development of strategic environmental

assessment methodology. Impact Assessment and Project Appraisal, 18(3), 183–189.CSIR (Council for Scientific and Industrial Research). (1996). Strategic Environmental Assessment

(SEA): A primer (CSIR report). The Division of Water, Environment and Forest Technology,Stellenbosch, Durban.

Department of Environment (DOE), Bangladesh. (1997). EIA guidelines for industries.Dhaka Declaration on Bangladesh Environment. Second International Conference on Bangladesh

Environment (ICBEN 2000) December 19–21, 2002.Donnelly, A., Dalal-Clayton, B., & Hughers, R. (1998). A directory of impact assessment guidelines (2nd ed.).

London: International Institute for Environment and Development.Environment Canada. (2003, January). Strategic environmental assessment at Environment Canada. An

integrated approach to the environmental assessment of policy, plan and program proposals.Fischer, T. B. (1999). The consideration of sustainability aspects within transport infrastructure

related policies, plans and programs. Journal of Environmental Planning and Management, 42,189–219.

Glasson, J., Therivel, R., & Chadwick, A. (1994). Introduction to environmental impact assessment.London, UK: University College Press.

IAIA (International Association for Impact Assessment). (2002). SEA performance criteria. Fargo, ND:IAIA.

International Rivers Network. (1992). Technical review of the Bangladesh Flood Action Plan (IRNWorking Paper No. 1). Berkeley, CA: International Rivers Network.

Khan, M. H., & Fitzcharles, K. (1998). Environmental management field handbook for rural roadimprovement projects. Bangladesh: Cooperative for Assistance and Relief Everywhere.

Lee N., & Walsh F. (1992). Strategic environmental: an overview. Project Appraisal, 7(3), 126–136.Ministry of Environment, Government of Japan. (2003, June). Effective SEA system and case Studies.

Tokyo: Ministry of Environment.Momtaz, S. (2002). Environmental impact assessment in Bangladesh: A critical review. Environmental

Impact Assessment Review, 22, 163–179.Momtaz, S. (2005). Institutionalizing social impact assessment in Bangladesh resource management:

Limitations and opportunities. Environmental Impact Assessment Review, 25, 33–45.Munn, R. E. (1979). Environmental impact assessment: Principals and procedures. New York: Wiley.Nakashim, S., & Khan, M. (1994). A basic guide to understanding the environmental impacts of rural

roads on the wetlands of Bangladesh. Dhaka, Bangladesh: Cooperative for Assistance and ReliefEverywhere (CARE) International.




Noble, B. F. (2000). Strategic Environmental Assessment: What is it? And what makes it strategic?Journal of Environmental Assessment Policy and Management, 2(2), 203–224.

Noble, B. F., & Storey, K. (2001). Towards a structured approach to a strategic environmental assessment.Journal of Environmental Assessment Policy and Management, 3(4), 483–508.

Partidario, M. R. (2000). Elements of an SEA framework: Improving the added-value of SEA.Environmental Impact Assessment Review, 20, 647–663.

Pearce, F. (2001, January). Bangladesh’s arsenic poisoning: Who is to blame? The Courier UNESCO,http://www.unesco.org/courier/2001_01/uk/planet.htm

Rahman, M. M., Paul, K., Chowdhury, U. K., Biswas, B. K., Lodh, D., Basu, G. K., et al. (2001). Currentstatus of arsenic pollution and health impacts in West Bengal and Bangladesh. Paper presented at anInternational Workshop on Arsenic Pollution of Drinking Water in South Asia and China. Tokyo,Japan, March 10.

Sadler, B. (1999). Environmental sustainability assessment and assurance. In J. Petts (Ed.), Handbook onenvironmental impact assessment, (pp. 12–32). London: Blackwell.

Sadler, B. (2001). A framework approach to strategic environmental assessment: Aims, principles and ele-ments of good practice. In J. Dusik (Ed.), Proceedings of the International Workshop on PublicParticipation and Health Aspects in Strategic Environmental Assessment (pp. 11–24). Szentendre,Hungary: Regional Environmental Centre for Central and Eastern Europe.

Sadler, B., & Verheem, R. (1996). Strategic Environmental Assessment: Status, challenges and futuredirections (Report 53). The Netherlands: Ministry of Housing, Spatial Planning and the Environment.

Stinchcombe, K., & Gibson, R. B. (2001). Strategic Environmental Assessment as a means of pursuingsustainability: Ten advantages and ten challenges. Journal of Environmental Assessment Policy andManagement, 3(3), 343–372.

Therivel, R., Wilson, E., Thompson, S., Heaney, D., & Pritchard, D. (1992). Strategic environmentalassessment. London: Earthscan.

Tomlinson, P. (Ed.). (2000). SEA and transport planning (Issue 1). Crawthrone, Berkshire: TransportResearch Laboratory.

Transparency International. (2005, October 18). Corruption still rampant in 70 countries, saysCorruption Perceptions Index 2005 (Press release). Berlin: Transparency International.

UNEP (United Nations Environment Program). (1988). Environmental impact assessment: Basic proce-dures for developing countries. Bangkok: UNEP Regional Office for Asia and the Pacific.

UNICEF (United Nation’s Children’s Fund). (1999). Arsenic mitigation in Bangladesh [Mediabrief]. NewYork: UNICEF.

Wood, C., & Dejeddour, M. (1992). Strategic Environmental Assessment: EA of policies, plans and pro-grammes. Impact Assessment Bulletin, 10(1), 3–22.

Habib M. Alshuwaikhat is an associate professor of sustainable urban planning and development at theDepartment of City and Regional Planning at King Fahd University in Dhahran, Saudi Arabia. His areaof research includes urban sustainability, strategic environmental assessment and development planning.

Syed Masiur Rahman and Yusuf Adedoyin Aina are research assistants at King Fahd University inDhahran, Saudi Arabia.




The Rationale for SEA to Overcome the Inadequacy of Environmental Assessment in Bangladesh

Documents

Transcript of The Rationale for SEA to Overcome the Inadequacy of Environmental Assessment in Bangladesh