ENHANCING OPPORTUNITIES FOR CLEAN AND RESILIENT GROWTH IN URBAN BANGLADESH COUNTRY ENVIRONMENTAL ANALYSIS 2018 SEPTEMBER 2018 ENHANCING OPPORTUNITIES FOR CLEAN AND RESILIENT GROWTH IN URBAN BANGLADESH COUNTRY ENVIRONMENTAL ANALYSIS 2018 SEPTEMBER 2018 © 2018 The World Bank 1818 H Street NW, Washington DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org Some rights reserved This work is a product of the staff of The World Bank. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of the Executive Directors of The World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. 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CONTENTS ACRONYMS AND ABBREVIATIONS ii ACKNOWLEDGMENTS 1 EXECUTIVE SUMMARY 2 INTRODUCTION 6 CHAPTER 1: Impacts and Costs of Environmental Degradation in Urban Bangladesh 8 1.1 Impacts and Trends 8 1.2 From Impacts to Estimating Economic Costs 14 CHAPTER 2: Policy and Institutional Framework for Pollution Control and Cleaner Production 18 2.1 Core Environmental Policies and Standards Governing Industries 18 2.1.1 Revising the Environment Conservation Rule 20 2.1.2 Legal Framework for Industrial Hazardous Waste Management 21 2.2 Enforcing Environmental Compliance 22 2.2.1 The Department of Environment 22 2.2.2 Environment Court System 30 2.2.3 Civil Society 31 2.3 Promoting Better Environmental Performance and Green Growth 33 2.3.1 Policy Framework for RECP 33 2.3.2 Institutional Framework for RECP 33 CHAPTER 3: Toward Cleaner and More Resilient Cities in Bangladesh 42 3.1 Understanding Environmental Management Responsibilities at the City Level 42 3.2 Urban Environmental Management Experiences in Case Study Cities 43 3.2.1 Dhaka—The Mega City 43 3.2.2 Cox’s Bazar—A Tourist Coastal City 48 3.2.3 Environmental Management in the Municipality of Pabna 51 3.2.4 Madhabdi and Narshingdi—A Tale of Two Cities 53 3.2.5 Mymensingh—A University Town 54 3.3 Priorities for Action 55 CHAPTER 4: A Way Forward 57 REFERENCES 66 ANNEX A: Key Achievements in the Development of Bangladesh’s Environmental Legal and Regulatory Framework Since 2006 72 ANNEX B: Key Observations and Recommendations for the Draft 2017 ECR 75 ANNEX C: Comparison of the DoE’s Organizational Structure with Those of Other Countries 78 ANNEX D: Hazardous Wastes in Bangladesh—Policy Note 85 i Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh ACRONYMS AND ABBREVIATIONS µg microgram µm micrometer 3R reduce, reuse, recycle ADB Asian Development Bank BAPA Bangladesh PoribeshAndolon BB Bangladesh Bank BBS Bangladesh Bureau of Statistics BCIC Bangladesh Chemical Industries Corporation BDT Bangladeshi Taka (Tk) BELA Bangladesh Environmental Lawyers Association BEPZA Bangladesh Export Processing Zones Authority BEZ Bangladesh Economic Zone BEZA Bangladesh Economic Zone Authority BFD Bangladesh Forest Department BFIDC Bangladesh Forest Industries Development Corporation BFRI Bangladesh Forest Research Institute BFSIC Bangladesh Sugar and Food Industries Corporation BGMEA Bangladesh Garment Manufacturers and Exporters Association BIWTA Bangladesh Inland Water Transport Authority BPC Bangladesh Parjathan Corporation BSCIC Bangladesh Small Cottage Industries Corporation BSEC Bangladesh Steel and Engineering Corporation BTFEC Bhutan Trust Fund for Environmental Conservation BUILD Business Initiative Leading Development BWDB Bangladesh Water Development Board CASE Clean Air and Sustainable Environment CBECAM Community-Based Ecologically Critical Area Management CCTF Climate Change Trust Fund CEA Country Environmental Analysis CETP centralized effluent treatment plant CIP Country Investment Plan CoED cost of environmental degradation CoUK Cox’s Bazar UnnayanKartripakkay or Cox’s Bazar Development Authority CSR corporate social responsibility CWBMP Coastal and Wetland Biodiversity Management Project DALY disability adjusted life year DAP Detailed Area Plan DC Deputy Commissioner DCC Dhaka City Corporation DG Director General DMA Dhaka metropolitan area Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh ii DNCC Dhaka North City Corporation DoE Department of Environment DoF Department of Fisheries DPHE Department of Public Health Engineering DSCC Dhaka South City Corporation DWASA Dhaka Water Supply & Sewerage Authority EA environmental assessment EC electrical conductivity ECA Environment Conservation Act ECC Environmental Clearance Certificate ECR Environment Conservation Rule EF environmental fund EFCC Environment, Forestry, and Climate Change EIA Environmental Impact Assessment EMF Environmental Management Framework EMP Environmental Management Plan EPZ export processing zone EQS Environmental Quality Standards ESRM Environmental and Social Risk Management ETP effluent treatment plant FCK fixed-chimney kiln FD Forest Department FFZ floodflow zone FY fiscal year GoB Government of Bangladesh GDP gross domestic product GHG greenhouse gas GIS geographical information system GIZ Gesellschaft fürInternationaleZusammenarbeit (German Agency for International Cooperation) GNI gross national income HAP household air pollution HHK Hybrid Hoffman kiln IEE initial environmental examination IFC International Finance Corporation IHME Institute for Health Metrics and Evaluation IQ intelligence quotient ISO International Organization for Standardization JICA Japan International Cooperation Agency LGED Local Government Engineering Department MIST Military Institute of Science & Technology MoC Ministry of Commerce MoEFCC Ministry of Environment,Forest, and Climate Change MoF Ministry of Finance MoHPW Ministry of Housing and Public Works MoI Ministry of Industry MoL Ministry of Land MoP Ministry of Planning iii Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh MoTJ Ministry of Textiles and Jute MSDP Mymensingh Strategic Development Plan NBR National Board of Revenue NBSAP National Biodiversity Strategy and Action Plan NDC Nationally Determined Contribution NGO nongovernmental organization PaCT Partnership for Cleaner Textile PCB polychlorinated biphenyl PIL public interest litigation PM2.5 particulate matter with diameter smaller than 2.5µm POP persistent organic pollutant ppb parts per billion PPD public-private dialogue ppm parts per million PSDSP Private Sector Development Support Project RAJUK Capital Development Authority or Rajdhani UnnayanKatripakha RECP resource-efficient and cleaner production RHD Roads and Highways Department RMG readymade garment SDG Sustainable Development Goal SEZ special economic zone SME small and medium enterprise TLCC Town-Level Coordination Committee TSDF treatment, storage, and disposal facility TSIP Toxic Sites Identification Program TSP Textile Sustainability Platform UDD Urban Development Directorate ULAB used lead-acid battery UNDP United Nations Development Programme UNEP United Nations Environment Programme UNIDO United Nations Industrial Development Organization VCG village conservation group VSBK vertical shaft brick kilns VSL value of statistical life WASH water, sanitation, and hygiene WB World Bank WDI World Development Indicators WEF World Economic Forum WHO World Health Organization WRA water retention area WTP willingness to pay WWF World Wildlife Federation Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh iv ACKNOWLEDGMENTS This report was prepared by a team of World Bank Bazar Urban Development Directorate, officials from Group staff and experts led by Suiko Yoshijima (Senior Rajdhani Unnayan Katripakha, the Bangladesh Water Environmental Specialist) and Nadia Sharmin (Senior Development Authority, representatives from local Environmental Specialist), and consisted of Tijen Arin government, academia, research and development, (Senior Environmental Economist), Leanne Farrell and civil society organizations, all of whom provided (Senior Environmental Specialist), Sebnem Sahin very useful feedback during the various discussions (Senior Environmental Economist), Antoine Coste and consultations that took place in Dhaka. (Economist), Jia Jun Lee (Research Analyst), Asif Zaman (Consultant), Md. Khaliquzzaman (Consultant), Constructive comments on the report were received Tanvir Ahmed (Consultant), Elena Strukova Golub from the following peer reviewers: Maria Sarraf (Consultant), Mokhles Rahman (Consultant), Santiago (Lead Environmental Economist), Nagaraja Rao Enriquez (Consultant), Shoeb Ahmed (Consultant), Harshadeep (Lead Environment Specialist), Helena Bret Ericson (Director, Pure Earth), and G. C. Naber (Senior Environmental Specialist), and Datta Roy (Consultant). Additional critical support Jonathan Coony (Senior Private Sector Specialist). throughout various stages of preparation was provided The team would also like to acknowledge several other by A. S. Harinath (Senior Environmental Specialist), colleagues for their suggestions, including Sanjay Iqbal Ahmed (Environmental Specialist), Mehrin Srivastava (Program Leader), Ernesto Sanchez-Triana Mahbub (Communications Officer), Montserrat (Lead Environmental Specialist), Carter J. Brandon Meiro-Lorenzo (Senior Public Health Specialist), (Lead Economist), Urvashi Narain (Lead Economist), Poonam Rohatgi (Senior Program Assistant), and Susmita Dasgupta (Lead Environmental Economist), Angie Harney (Program Assistant). Overall guidance and Glenn-Marie Lange (Senior Environmental was provided by Kseniya Lvovsky (Practice Manager) Economist). Valuable comments were also received and Qimiao Fan (Country Director). from Dr. Mary Jean (Adjunct Professor, Harvard T.H. Chan School of Public Health). The team also The team would like to express its gratitude to Mr. thanks Karin Kemper (Senior Director) for her Abdullah Mohsin Chowdhury, Secretary, Ministry of encouragement and support. Environment, Forest, and Climate Change; Mr. Raisul Islam Mondal, Secretary, Ministry of Fisheries and The manuscript was edited by Lauri Scherer. Any Livestock; and Mr. Sultan Ahmed, Director General, remaining errors or omissions are the authors’ own. Department of Environment. The work was done in The cover page photos were provided by Leanne full collaboration with the Economic Relations Division Farrell, Nadia Sharmin, and Suiko Yoshijima. The and the Department of Environment. The team would team gratefully acknowledges the financial support also like to thank the Mayors and officials of various provided for the report by the PROFOR and the pourashava/municipalities, the Chairman of the Cox’s Korean Green Growth Trust Fund. 1 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh EXECUTIVE SUMMARY Bangladesh aspires to become an upper-middle- Yet urbanization and industrial growth have come income country by growing its gross domestic with high environmental costs that are increasingly product (GDP) at 7 to 8 percent per year in the next harming Bangladesh’s prospects for continued strong decade. The country has sustained robust economic economic progress. Growth has featured uncontrolled growth (6.7 percent of GDP per year on average), led urbanization and industrialization in a context of by industrial development and urbanization, for the inadequate pollution control and poor management past three decades. In July 2015, Bangladesh officially of natural resources that provide critical ecosystem graduated to the level of lower-middle-income country services. Encroachment of wetland areas, combined with a gross national income (GNI) per capita of over with inadequate waste management and maintenance US$1,046. Looking forward, besides increasing export of drainage canals, have increased cities’ vulnerability revenues, remittances, and private sector investments, to flooding and reduced their climate resilience. Bangladesh will need to substantially expand productive These worrying trends have adverse implications employment opportunities to sustain growth and for the livability and long-term sustainability of cities ensure its benefits are widely shared. and the health and well-being of their inhabitants. In addition, environmental risks often affect women In tandem with its economic development, disproportionately. Reducing negative environmental Bangladesh has been increasingly urbanizing—led externalities is a priority if Bangladesh is to continue by the massive growth of Dhaka, the nation’s capital. to reduce poverty and achieve shared prosperity The national urban population grew at an average (World Bank 2015). annual rate of 3.5 percent, and is expected to increase from 28 percent of Bangladesh’s total population today Urban environmental pollution is already imposing to 40 percent by 2025 (World Bank 2015). At the same a significant cost on Bangladesh’s economy. In 2015, time, the population living in slums within the urban the total annual number of deaths and disability areas is growing at double the average urban rate— adjusted life years (DALYs) attributable to air around 7 percent annually. Over the last two decades, pollution, inadequate water, sanitation, and hygiene Dhaka’s population doubled; yet because of land (WASH), arsenic in drinking water, and occupational constraints, the city is now among the world’s most pollutants in urban areas is estimated at some 80,000 densely populated. In 2011, population density was and 2.6 million, respectively in 2015. In Dhaka already about 8,000/sq. km in Dhaka’s metropolitan alone, the corresponding estimates are almost 18,000 area (DMA), and 31,000/sq. km in Dhaka City and 578,000. The economic cost of this mortality Corporation (DCC) (BBS 2014). Population density in terms of foregone labor output is estimated at in slums, meanwhile, is estimated at about 205,000/sq. US$1.40billion in all urban areas of Bangladesh, and km in Dhaka and 255,000/sq. km in Chittagong, the at US$310 million in Dhaka alone. This is equivalent second largest city in Bangladesh. to 0.7 percent and 0.2 percent of Bangladesh’s 2015 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 2 national GDP, respectively. Taking into account the enhancements to the legal framework for pollution broader welfare impacts of mortality that go beyond control, management, and accountability. Some foregone labor output, tthe economic impact is industry-specific initiatives for scaling up cleaner estimated at US$6.52 billion in urban Bangladesh and production practices have also gained momentum. US$1.44 billion in Dhaka alone, which are equivalent to 3.4 percent and 0.7 percent of the 2015 national Yet much more needs to be done to arrest the stark GDP, respectively (see Table ES-1). These figures effects of pollution and environmental degradation may be considered as the lower and upper ends of a on people’s health and economic productivity. plausible range of estimates of the economic cost of Achieving Bangladesh’s objective to reach upper- mortality attributable to quantifiable environmental middle-income status through cleaner and more health risks. In addition, the costs of productivity resilient growth will depend on further developing loss in the readymade garment industry due to air and strengthening a range of complementary policies pollution, of IQ loss among children exposed to lead and systems for environmental protection, urban from industrial sources, and of morbidity from air development, and industrial management. This is pollution and inadequate WASH were estimated. even more critical and urgent for Bangladesh than for most other countries at a similar income level due to Over the last decade, Bangladesh has improved its its uniquely high population density and vulnerability policy regime and systems for environmental and to climate risks. Moreover, institutional reforms and pollution management. Since 2006, when the World capacity building will be key in all areas to ensure Bank’s first Country Environmental Analysis (CEA) effective implementation of adopted strategies and for Bangladesh was published, the country has made policies. Based on the analysis in this CEA, priorities for tangible progress in further developing environmental reform and investment should include the following: policies, guidelines, and legislation. This progress toward mainstreaming the environmental agenda i. Enhance environmental policy and institutions across government is especially apparent in the at the national level. To reverse the trend country’s national development, environment, of environmental degradation and promote and climate change strategies, as well as in specific cleaner and resilient growth, significant policy TABLE - ES-1: ESTIMATED COST OF MORTALITY IN URBAN BANGLADESH AND GREATER DHAKA (US$ BILLION) AND NATIONAL GDP (2015) EQUIVALENCES Urban Bangladesh Greater Dhaka Welfare Loss Foregone Output Welfare Loss Foregone Output Amount GDP Amount GDP Amount GDP Amount GDP equiv. equiv. equiv. equiv. PM2.5 air pollution ambient 2.42 1.24% 0.49 0.25% 0.53 0.27% 0.11 0.06% household 1.27 0.65% 0.25 0.13% 0.28 0.14% 0.06 0.03% Inadequate water, sanitation and hygiene direct impact 0.43 0.22% 0.14 0.07% 0.09 0.05% 0.03 0.02% indirect impact 0.08 0.04% 0.04 0.02% 0.02 0.01% 0.01 0.00% Arsenic in drinking water 0.80 0.41% 0.18 0.09% 0.18 0.09% 0.04 0.02% Occupational pollutants 1.52 0.78% 0.29 0.15% 0.34 0.17% 0.06 0.03% TOTAL 6.52 3.35% 1.40 0.72% 1.44 0.74% 0.31 0.16% 3 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh and institutional reforms at the national level serve as an effective deterrent to polluters. Such are required. The Department of Environment rules should be complemented with (i) realistic (DoE) needs to be reformed and allocated and scientifically grounded emission/discharge adequate resources to modernize its information and ambient environmental quality standards; management, monitoring, and enforcement (ii) an option to develop a monitorable and systems; build up and organize its staff to more time-bound compliance plan when the current effectively respond to pressing environmental technology is unable to meet the standard; and challenges; and effectively decentralize to district (iii) the operationalization of a funding stream and divisional levels, with priority given to areas/ dedicated to environmental remediation (see cities with the highest levels of pollution. Beyond point iv, below). A comprehensive information the DoE, it is essential to mainstream environmental management system with automated monitoring management and green development objectives for compliance and enforcement would help across all relevant line ministries and agencies to reduce enforcement costs and improve its create an enabling environment for sustainable effectiveness. Outside experts should be used to growth. support environmental clearance processes and compliance monitoring to supplement DoE’s ii. Enhance environmental management at the local/ staff capacity. A more effective environment court city level. A lack of local-level urban planning system and greater transparency of environmental capacity is leading to unplanned urbanization, not information are also important tools for holding only in Dhaka but also in many secondary towns. polluters accountable. Integrated urban planning that takes into account the role of natural resources is necessary for iv. Leverage market-based instruments to protect livable city development. Local governance should the environment and unlock green financing. be strengthened through institutional reform, Achieving sustainable growth will require that the particularly to clarify overlapping or overlooked private sector and markets direct more resources mandates in urban planning and implementation toward greener activities and investments. that result in a lack of accountability in terms of As a complement to adopting and enforcing protecting wetlands and other environmental environmental regulations, using fiscal instruments assets from encroachment and pollution. A to internalize environmental externalities would major effort is needed at the local/city level to help minimize resource use and pollution from clarify institutional arrangements and strengthen production and consumption. Adequate pricing capacity for effective implementation and of key resources, such as water and energy, are enforcement of the adopted policies and plans. essential to foster their efficient use. Building on There is also a pressing need for regional waste current efforts, Bangladesh should strive to scale management facilities, including ones that can up financing for green investments. Following handle the hazardous wastes that contaminate soil successful initiatives in other countries, Bangladesh and increase health costs. The underlying policy could also consider establishing a national trust regime will need to be improved to make better fund dedicated to conservation and environmental waste management options viable and financially management to diversify sources of funding. sustainable. Finally, better planning and increased investments in secondary cities could relieve the v. Promote resource-efficient and cleaner concentrated pressure on Dhaka. production (RECP) as a tool for reconciling environmental performance with competitiveness. iii. Strengthen the enforcement and accountability Mainstreaming RECP among polluting industries regime. There is significant scope to increase can help reconcile better environmental accountability, trust, and deterrence in performance with competitiveness. The adoption the environmental enforcement regime by of RECP can be scaled up by addressing modernizing and replacing what is perceived as an several gaps related mainly to awareness and ad hoc application of the “polluter pays principle” to technical and financial capacity, both on the with a transparent, rule-based system that can part of industry and government. Bangladesh Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 4 could consider establishing a dedicated technical countries. In this regard, enhanced disclosure and institution to identify, demonstrate, and promote accessibility of data on environmental degradation cleaner technologies, following the model of and pollution (e.g., ambient air and water quality, Cleaner Production Centers adopted in many emissions from industries) is key for empowering countries. To foster private investments in clean citizens. It is also important to make urban technologies, public-private dialogue also needs communities, including children, more aware of to be strengthened among government, industry, the value of natural resources and the importance and financial institutions. of including, protecting, and managing wetlands and their functions in urban settings. To this end, vi. Harness the power of public pressure. Pressure relevant agencies should organize events and from citizens, especially those in the rapidly programs on what citizens can do, and develop and expanding middle class, have been a major driving disseminate educational materials on wetlands’ force for change in tackling pollution in various values, functions, and management. 5 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh INTRODUCTION Bangladesh aspires to become an upper-middle- km in Dhaka City Corporation (DCC) (BBS2014). income country by growing its gross domestic Population density in slums, meanwhile, is estimated product (GDP) at 7 to 8 percent per year in the next at about 205,000/sq. km in Dhaka and 255,000/sq. km decade. The country has sustained robust economic in Chittagong, the second largest city in Bangladesh. growth (6.7 percent of GDP per year on average), led by industrial development and urbanization, for Urbanization and industrial growth have come the past three decades.1 In July 2015, Bangladesh with high environmental costs that are increasingly officially graduated to the level of lower-middle- harming Bangladesh’s prospects for continued strong income country with a gross national income (GNI) economic progress. Growth has featured uncontrolled per capita of over US$1,046. Looking forward, urbanization and industrialization in a context of besides increasing export revenues, remittances, and inadequate pollution control and poor management private sector investments, Bangladesh will need of natural resources that provide critical ecosystem to substantially expand productive employment services. Encroachment of wetland areas, combined opportunities to sustain growth and ensure its benefits with inadequate waste management and maintenance are widely shared. of drainage canals, have increased cities’ vulnerability to flooding and reduced their climate resilience. These In tandem with its economic development, worrying trends have adverse implications for the Bangladesh has been increasingly urbanizing—led livability and long-term sustainability of cities and the by the massive growth of Dhaka, the nation’s capital. health and well-being of their inhabitants. Reducing The national urban population grew at an average negative environmental externalities is a priority annual rate of 3.5 percent, and is expected to increase if Bangladesh is to continue to reduce poverty and from 28 percent of Bangladesh’s total population achieve shared prosperity (World Bank 2015). today to 40 percent by 2025 (World Bank 2015). At the same time, the population living in slums is growing Since 2006, substantial efforts have been made to at double the average urban rate—around 7 percent strengthen environmental policies and regulations. annually. Over the last two decades, Dhaka’s population In 2006, the World Bank published the first Country doubled; yet because of land constraints, the city is now Environmental Analysis (CEA) for Bangladesh.2 among the world’s most densely populated. In 2011, The analysis intended to help the Government of population density was already about 8,000/sq.km Bangladesh (GoB), civil society, and development in Dhaka’s metropolitan area (DMA), and 31,000/sq. partners identify and address critical environmental 1. WDI 2017. 2. The CEA is an upstream analytic tool that aims to integrate environmental considerations into the development process and sustainable development assistance by identifying key areas for policy reform, institution building, and investment. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 6 constraints to sustainable, poverty-reducing growth. notably by better incorporating wetlands into urban The study included the cost of environmental planning, enforcing zoning, and investing in waste degradation and identified three significant target management. areas that needed priority attention: (i) urban and indoor air pollution threats to human health; (ii) Given the growing environmental challenges that treatment of urban and industrial sewage in Dhaka; Bangladesh’s cities face, this CEA focuses on the and (iii) the continuous decline of capture fisheries. country’s urban areas. The report analyzes the A set of actions in each target area was proposed, impacts and causes of pollution levels and natural and a series of measures that could strengthen resource degradation in Dhaka and other rapidly environmental governance was identified. Annex A growing cities. It updates the first CEA prepared over presents progress made on the recommendations. a decade ago with the aim of (i) better understanding Over the last decade, the GoB has integrated the the environmental challenges, trends, and implications Sustainable Development Goals (SDGs) in its National of rapid economic growth in urban areas; and (ii) Development Strategy (2010) and Seventh Five-Year identifying paths toward cleaner and more climate- Plan (2015), and taken substantial steps to strengthen resilient growth4 through technological changes environmental policies, legislation, and regulations. and institutional, regulatory, and policy reforms. Enhancing urban resilience and reducing greenhouse The analysis includes case studies at the city level, gas (GHG) emissions by promoting energy efficiency including the Greater Dhaka area and other cities of among industries are key areas of the Nationally various sizes. Determined Contribution (NDC), and some industry- specific initiatives for scaling up cleaner production This report has benefited from three background technologies and practices have gained momentum. papers5 and several consultations with a wide range of stakeholders. It is structured as follows: Nonetheless, policies and institutions need further • Chapter 1 presents the updated impacts and costs of strengthening. In practice, pollution continues to environmental degradation in Bangladesh’s urban occur unabated, due largely to the weak institutional areas based on the assessments of economic and capacity of enforcement agencies and the insufficient social costs of air, water, and soil pollution. engagement of other key players. It is becoming • Chapter 2 analyzes the institutional framework for increasingly urgent for Bangladesh to further environmental management and green growth strengthen its regulatory framework and institutional in Bangladesh. It outlines recommendations to capacity to manage negative environmental improve policies, regulations, and institutional externalities associated with rapid industrial and urban capacity in the areas of pollution management, growth. This includes significantly strengthening resource efficiency, and environmental environmental monitoring, enforcement, and public awareness efforts, as well as better embedding performance. environmental considerations across the government • Chapter 3 presents several case studies that ministries. At the same time, more needs to be done focus on cities of various sizes to draw specific to incentivize the private sector to adopt resource- recommendations for resilient urban development, efficient and cleaner production (RECP) technologies with a particular focus on urban wetlands and practices,3 building on successful existing management. initiatives. In addition, cities need to proactively plan • Chapter 4 summarizes the findings and prioritizes and manage their environmental assets to ensure recommendations for Bangladesh to embark on continued livability as well as climate resilience, greener and more climate-resilient growth. 3. Following the definition established by UNIDO and UN Environment, RECP refers to the “continuous application of an integrated preventive environmental strategy to processes, products and services to increase efficiency and reduce risks to humans and the environment.” 4. Clean/green and resilient growth can be defined as “growth that is efficient in its use of natural resources, clean in that it minimizes pollution and environmental impacts, and resilient in that it accounts for natural hazards and the role of environmental management and natural capital in preventing physical disasters” (World Bank 2012). 5. The three background papers are “Impacts and Costs of Environmental Degradation in Urban Bangladesh,” “Towards Clean and More Resilient Cities,” and “Institutions for Clean and Green Industrial Growth.” The third background paper became a basis of this synthesis report. 7 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh CHAPTER 1. IMPACTS AND COSTS OF ENVIRONMENTAL DEGRADATION IN URBAN BANGLADESH 1.1 IMPACTS AND TRENDS for Bangladesh in 2015, some 234,000 were due to environmental pollution and other environmental Globally, Bangladesh is among the countries most health risks—more than 10 times the number of affected by pollution and other environmental health deaths from road injuries/traffic accidents (21,286). risks. Diseases caused by pollution were responsible for Fine particulate matter (PM2.5) air pollution, both 16 percent of all deaths worldwide in 2015 (Landrigan ambient and indoor, is by far the most significant et al. 2018). In Bangladesh, this proportion was nearly environmental risk, causing about 21 percent of 28 percent; as such, Bangladesh’s numbers were the all deaths in Bangladesh.6 While air pollution is the highest out of all of South Asia, where the average was leading environmental risk factor in all South Asian nearly 26 percent (see Figure 1-1). In other words, countries, the levels in Bangladesh are the highest in of the 843,000 cause-attributable deaths estimated the region (see Figure 1-2). FIGURE - 1-1:  DEATHS ATTRIBUTED TO ENVIRONMENTAL RISKS IN SOUTH ASIAN COUNTRIES, 2015 (%) South Asia average 25.9 Bangladesh 27.7 India 26.5 Nepal 25.8 Pakistan 22.2 Afghanistan 20.6 Bhutan 17.7 Sri Lanka 13.7 Maldives 11.5 0 5 10 15 20 25 30 Share of all-cause mortality due to environmental health risks (%) Source: IHME 2017. The joint impact of ambient and indoor air pollution is lower than the sum of these risk factors individually (indicated in Figure 1-3) 6. due to interactions of effects. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 8 FIGURE - 1-2:  SHARE OF ENVIRONMENTAL RISKS IN MORTALITY IN SOUTH ASIA, 2015 (%) 14 12 Ambient PM 2.5 Share of total all-cause mortality in 2015 (%) 10 Household air pollution 8 6 Unsafe water source 4 Unsafe sanitation 2 0 Lead exposure s l sia ta n es h ta n di a nk a ve pa ta n A is ad hu In a di e is ut h n l L al N Pa k Occupational environmental ha ng B ri M So Af g B a S hazards Source: IHME 2016. During the past three decades, Bangladesh, like impact of indoor air pollution also decreased, albeit many other developing countries, has experienced less dramatically. At the same time, rapid growth a dramatic shift in exposure to environmental of export-oriented manufacturing—notably of health risks. The role of “traditional” environmental textiles and readymade garments (RMGs)—and risk factors has decreased while that of modern risks the concurrent increase in the urban population— linked to urbanization has increased. As Figure 1-3 from less than 40 million in 2006 to more than 55 shows, between 1990 and 2016, premature deaths million in 2015 (WDI 2017)—had immense impacts and disability attributed to unsafe water, sanitation, on exposing the growing urban population to and hygiene (WASH) fell drastically. The size and environmental hazards. FIGURE - 1-3:  EVOLUTION OF MORTALITY AND DISABILITY ATTRIBUTED TO ENVIRONMENTAL RISKS IN BANGLADESH OVER TIME (A) (B) 120 8,000 Mortality cases per 100,000 7,000 100 DALYs per 100,000 6,000 80 5,000 60 4,000 3,000 40 2,000 20 1,000 0 0 1990 1995 2000 2005 2010 2016 1990 1995 2000 2005 2010 2016 Unsafe water, sanitation, and handwashing Unsafe water, sanitation, and handwashing Ambient particulate matter pollution Ambient particulate matter pollution Household air pollution from solid fuels Household air pollution from solid fuels Lead exposure Lead exposure Occupational risks Occupational risks Source: Estimated from IHME 2017. 9 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Ambient air pollution. Mortality from ambient and the average household size is about 5, this translates PM2.5 air pollution, which has been shown to cause into 5.5 million urban households that use solid cardiovascular and respiratory diseases, and cancer, fuels for cooking in urban areas alone. Recognizing appears to have declined little in Bangladesh since 1990 the immensity of the challenge, the GoB has been (see Figure 1-3). There is also increasing international supporting a program to replace traditional cookstoves evidence that air pollution reduces the productivity with improved ones, and as of 2017 had delivered of healthy workers, including in the RMG industry, one million improved cookstoves. Nevertheless, a which in Bangladesh is significant for continued 2017 household survey found that the reduction in competitiveness and high GDP growth. Based on household air PM2.5 concentration is limited, from data from 11 continuous air quality monitoring 265µg/m3 in households using traditional cookstoves to stations in eight urban areas, the urban population- 211µg/m3 in those with improved cookstoves (Begum weighted annual PM2.5 concentration is estimated 2017.) The overall exposure depends on where in the at 80µg/m3 for 2013–15, more than five times the dwelling cooking takes place and the number of hours Bangladeshi standard and eight times the World per day spent indoors vs. outdoors. Health Organization (WHO) guideline. The source apportionment undertaken by the Department of Inadequate WASH. Inadequate WASH directly and Environment (DoE) identifies vehicles and brick kilns indirectly affects public health. Directly, poor WASH among the key sources. The seasonal nature of brick causes diarrheal infections and other health effects, kiln operations leads to seasonal variations in ambient which in turn lead to mortality, especially in young PM2.5 concentrations. Consequently, in winter, daily children. Indirectly, poor WASH contributes to poor concentrations are in the range of 150–350 µg/m3, or nutritional status in young children who experience 2.5–5 times the national standard for 24-hour mean diarrheal infections. Problems related to water supply PM2.5 concentration, 65 µg/m3 (see Figure 1-4). and health are intensified where industrial pollutants contaminate water systems because treatments that Household air pollution. A Department of Health control infectious agents do not effectively remove Services survey found that 50 percent of urban many toxic chemicals from drinking water. There are households use solid fuels (NIPORT, Mitra and hundreds of industrial chemicals, pharmaceuticals, Associates, and ICF International 2016). Considering and pesticides in water systems. Much of the worst that Bangladesh’s urban population is about 55 million biological and chemical drinking water pollution FIGURE - 1-4:  SEASONAL VARIATION IN AMBIENT PM2.5 AIR QUALITY IN DHAKA AND NARAYANGANJ 450.00 400.00 350.00 300.00 250.00 µg/m3 200.00 150.00 100.00 50.00 0.00 1/01/2012 12/15/12 01/28/13 03/13/13 04/26/13 06/09/13 07/23/13 09/05/13 10/19/13 12/02/13 01/15/14 02/28/14 04/13/14 05/27/14 07/01/14 08/23/14 10/06/14 11/19/14 01/02/15 02/15/15 03/31/15 05/14/15 06/27/15 08/01/15 09/23/15 11/06/15 12/20/15 02/02/16 03/17/16 04/30/16 06/13/16 07/27/16 09/09/16 10/23/16 12/06/16 19/01/17 04/03/17 04/17/17 05/31/17 07/14/17 27/08/17 Dhaka N. Ganj BD standard Source: DoE 2017. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 10 FIGURE - 1-5: BATTERY RECYCLING Photo credit: Mr. Raihan Uddin Ahmed is seen in rapidly urbanizing and industrializing and disability from cardiovascular diseases, cancer, Bangladesh, where local waterways and groundwater and infectious diseases. According to the Multiple are heavily polluted and serious health conditions Indicator Cluster Survey 2012–13, nearly 20 percent are widely reported, but no alternative water sources of the urban population had arsenic above 10 parts exist (World Bank 2008). Dhaka Water Supply & per billion (ppb), which is the WHO guideline, in their Sewerage Authority’s (DWASA) monitoring results drinking water (BBS and UNICEF Bangladesh 2014). with regards to dissolved oxygen and biological oxygen demand of six Dhaka rivers in May 2015 Occupational pollutants. Occupational pollutants in indicate that at most of the monitoring stations, the workplace include carcinogens such as asbestos, river water quality was at class IV or V, well below polycyclic aromatic hydrocarbons, silica, sulfuric drinking water quality (DWSSP 2005). In low-flow acid, trichloroethylene, arsenic, benzene, beryllium, winter months, all rivers surrounding Dhaka are cadmium, chromium, diesel exhaust, secondhand designated as ecologically critical areas, as they are smoke, formaldehyde, and nickel; particulate matter, almost completely unable to sustain life. High heavy gases, and fumes; and asthmagens. In Bangladesh, metal concentrations have been documented near workers in industrial establishments—including industrial areas in the water column and sediments micro, small, and medium facilities that use any of (Ahmed et al. 2010; Siddiquee et al. 2012; Islam et these materials as inputs—face the risk of cancer, al. 2014). chronic respiratory disease, and other health impacts due to the lack of mitigation practices, including the Arsenic in drinking water. Arsenic in groundwater— use of personal protective equipment. For example, which serves as the primary source of drinking water— an estimated 22,000 workers in Bangladesh’s is largely a natural occurrence, mostly affecting rural shipbreaking industry are exposed to elevated levels of areas. However, with urbanization, it is becoming a asbestos, polychlorinated biphenyls (PCBs), cadmium, problem for the urban water supply in some urban lead, and mercury in the naval and merchant ships growth centers such as Khulna. Arsenic causes death they dismantle (Sarraf et al. 2010). 11 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Soil, heavy metal, and chemical pollution. Heavy metal contamination and the poor. An initial Urbanization and industrialization have increased the visual analysis of spatial association of heavy metal- amount of waste generated. Without proper collection contaminated sites in Greater Dhaka suggests that and disposal, solid waste clogs channels, leading to pollution hotspots tend to be in poor areas. Figure urban floods. Unsafe recycling of hazardous waste, 1-6 shows upazila-wise poverty rates in Greater including of used lead-acid batteries (ULABs) on a Dhaka, the location of slums as of 2010, known growing number of sites and waste from shipbreaking, land contamination sites by type of pollutant (color) poses a growing public health hazard. and population at risk (size), and the metropolis’s nine industrial cluster areas for small and medium Lead. Human exposure to lead can result in increased enterprises (SMEs). Noteworthy is the geographical incidence of cardiovascular disease and diverse overlap of lead and chromium pollution and slums in neurological outcomes. High levels of lead exposure the southwest, which is dominated by ULAB recyclers by pregnant women can lead to miscarriage, stillbirth, and the leather industry. premature birth, and low birth weight. Young children are particularly vulnerable to the toxic effects of lead, Solid waste dumping and encroachment on wetlands. which may include death and irreversible neurological In a number of Bangladesh’s urban areas—most and behavioral impacts. Informal recycling of ULABs notably Dhaka, but also in emerging smaller cities such (see Figure 1-5) is among the key sources of lead as Pabna—wetlands and khals (channels) provided contamination of soil and air. While there are currently flood retention and drainage prior to the accelerated 148 known ULAB sites, the total number is more than urban development of recent decades. As more and 1,100, and the number of people at risk is nearly one more people moved into urban areas, these wetlands million. were encroached upon, reducing them in size by FIGURE - 1-6:  LAND CONTAMINATION HOTSPOTS, POVERTY, AND SLUMS IN AND AROUND GREATER DHAKA Key pollutants Arsenic Cadmium Chromium (Total) Lead Pesticides Industrial clusters Slums (>1 acre), as of 2010 Poverty rate 0.0 - 8.5 8.6 - 16.3 16.4 - 22.3 22.4 - 27.5 27.6 - 31.9 32.0 - 36.5 36.6 - 41.6 41.7 - 48.1 48.2 - 56.3 56.4 - 68.8 Source: World Bank, WFP, and BBS 2010; World Bank, forthcoming a; Pure Earth, n.d.; Gruebner et al. 2014. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 12 nearly 75 percent in slightly more than 40 years (see addition to sewage. The result has been an increase Figure 1-7). This CEA found that between 2010 and in so-called urban floods even following moderate 2016, 41 percent of flood flow zones (FFZs) and 21 amounts of precipitation, often lasting for weeks, as the percent of water retention areas (WRAs) that had accumulated rainwater cannot be channeled out of the been designated as such by the Capital Development urban area (Dasgupta et al. 2015). Urban floods cause Authority, or Rajdhani Unnayan Katripakha significant damage to health through the propagation (RAJUK), in the Detailed Area Plan (DAP) had been of infectious diseases, property, infrastructure, and converted, raised, and used for other purposes. In livelihoods. Chapter 3 presents in-depth case studies addition, as urban populations grew, more solid waste on wetlands encroachment and its implications. was generated. In the absence of a well-functioning waste collection and disposal system, wetlands and Reduced groundwater availability. Groundwater khals turned into dumping grounds for waste, in recharge area is diminishing with urban development Box 1-1: Women Are Disproportionately Impacted by Environmental Risks Household air pollution (HAP). Health effects from HAP disproportionally affect women and young children, who spend the most time inside residences. Pregnant women are especially vulnerable to HAP. Because of their increased inhalation and deposition in fatty tissue, more pollutants are diffused into the placenta and accumulated in fatty tissue. Exposure to air pollutants also restricts the regular transport of oxygen and nutrients to the fetus, resulting in adverse pregnancy outcomes such as stillbirth, low birth weight, miscarriage, and retarded fetal growth (Dutta et al. 2017; Hackley, Feinstein, and Dixon 2007; Butter 2006). Inadequate WASH. Women and girls bear a disproportionate burden of limited access to clean and safe water. Water pollution and water scarcity affect women’s health, nutrition, workload, and, consequently, their opportunities to overcome poverty. Because of their central role in water fetching, which is physically demanding and time-consuming, women and girls have reduced time for education and income-generating opportunities. They are also more exposed to environmental health risks from water pollution because they are responsible for collecting and storing water and washing clothes and utensils. Poor water quality also contributes to reduced property values, aggravating women’s limited access to land, housing, and other assets. In addition, lack of access to proper water resources and the increasing demand for water by households, farms, and industries can create societies that are more unequal, unstable, and prone to tensions and conflicts (WWAP 2015)—situations in which women are more vulnerable to gender-based violence. Additionally, inadequate sanitation and lack of separate toilets in schools contribute to reduced attendance and increased dropout rates among girls reaching puberty. Exposure to chemicals. Because of biological and gender-related factors, women and men have different vulnerability and exposure to chemical pollution. For example, persistent organic pollutants (POPs) may cause moderate to severe congenital defects, impairing health over multiple generations. Research also indicates that women are more vulnerable to cadmium and lead poisoning (Butter 2006, 222). Occupational activities that are typically performed by women both inside and outside the home result in increased exposure to toxic chemicals. For example, women are at greater risk from exposure to pesticides used in urban agricultural activities—by applying those chemicals to crops, storing pesticides at home, or recycling pesticide containers for domestic use due to lack of protective equipment and awareness of harmful chemicals. Because of their role in housekeeping, women are more exposed to toxic chemicals from cleaning products, pest control, and house building materials (for example, asbestos, lead, mercury, and arsenic). Source: World Bank, forthcoming 2018b. 13 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh due to increased extraction for drinking and industrial 1.2 FROM IMPACTS TO ESTIMATING purposes and reduced recharge capacity. Water ECONOMIC COSTS depletion is acute in Dhaka City. In 1990, the depth of the water table was 15 m in central Dhaka and 4 m in peri-urban areas (Abedin and Rakib 2013), while in These environmental impacts have large economic 2002 it was 50 m and in 2005 was 60 m. The pervious costs for Bangladeshi society.7 When workers— layer is important to effectively recharge groundwater. especially highly skilled ones—cannot work because With increasing pavement in urban areas, a substantial they get sick or die, both industry and the economy area of suitable pervious layer has been lost, which suffer production losses. Both families and public reduces the potential to recharge groundwater agencies incur treatment costs. No less important are and thus exhausts aquifer levels. In addition, the strains and suffering of impacted individuals and imperviousness of the ground increases storm runoff families. Pollution also makes it more expensive for by reducing runoff “lagtime” and puts increased water authorities to abstract and deliver safe drinking pressure on drainage canals. It is noted that DWASA water to citizens; it also restricts recreational amenities relies on groundwater to supply drinking water to the for urbanites, such as strolling along, swimming, or residents of Dhaka City; thus, loss of the pervious layer fishing in rivers. Finally, clogging natural drainage combined with the loss of wetlands would affect water channels with sewage and solid waste has been directly availability. In Chittagong, extraction of groundwater linked to urban floods in Dhaka, impacting health, has accelerated salinity intrusion. property, and production (Dasgupta et al. 2015). FIGURE - 1-7:  HISTORICAL CHANGE IN WETLANDS, BUILT-UP AREAS, AND AREAS UNDER AGRICULTURE/FALLOW/BARELAND (HA) IN DHAKA CITY 85,000 77,080 75,000 73,376 69,667 68,708 70,417 65,000 68,144 55,000 60,702 53,727 54,869 55,921 45,000 35,000 25,000 20,686 20,503 14,784 15,000 6,298 5,520 5,000 1967 1977 1989 1999 2010 Permanent wetland area Settlement and build up area Agri/follow/bare land Source: CEGIS 2012. The World Bank published its last CoED study on Bangladesh in 2006. It is important to note that the estimates are not comparable due 7. to (i) differences in coverage—while this CoED focuses on the environmental cost in urban and industrial areas, the 2006 CoED covered pollution issues nationwide and included natural resources degradation issues, including fisheries and forestry; and (ii) differences in methodology—estimation methodologies have evolved during the past 12 years. Hence, as tempting as it might be to make comparisons, especially of the overall CoED estimates, doing so would be misleading. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 14 TABLE - 1-1: DEATHS AND DALYS ATTRIBUTABLE TO ENVIRONMENTAL RISK FACTORS Urban Bangladesh Greater Dhaka Deaths DALYs Deaths DALYs PM2.5 air pollution ambient 30,353 857,432 6,685 188,843 household 15,933 456,572 3,509 100,557 Inadequate water, sanitation and hygiene direct impact 4,893 409,157 1,078 90,114 indirect impact 966 108,511 213 23,899 Arsenic in drinking water 10,028 313,377 2,209 69,019 Occupational pollutants 19,087 482,877 4,204 105,350 TOTAL 80,294 2,627,926 17,897 578,781 Source: Forest Cover Map, FAO (2010) Scope. This section examines those economic attributable to a particular environmental risk were impacts for which cause-effect linkages have estimated and adjusted for multiple risk factors, been well-established and credible estimation where applicable.. To this end, data published by the methodologies and data are available. As such, the Global Burden of Disease Project (IHME 2016), the CEA focused on (i) diseases and reduced worker DoE, the Bangladesh Bureau of Statistics (BSS), and a productivity caused by ambient and indoor PM2.5 variety of national and international organizations and air pollution; (ii) diseases caused by unsafe water researchers were used, and state-of-the-art estimation combined with inadequate WASH; (iii) diseases techniques were applied. Next, the estimated mortality caused by occupational carcinogens, particulate was multiplied with the present value of lifetime matter, and asthmagens; (iv) diseases caused earnings (based on 2015 urban per capita income) to by arsenic in drinking water; and (v) reduced calculate foregone labor output and with the value intellectual ability caused by children’s exposure to of statistical life (VSL) to calculate the welfare loss.9 lead. The fact that the CEA was unable to estimate Where possible, the cost of morbidity was estimated other losses does not mean they equal zero; it just using appropriate methodologies. means that at this time they could not be estimated. Results. Using the two approaches above, the Methodology. Two approaches were used to estimate total annual number of deaths and DALYs in 2015 the economic cost of the health burden attributed to attributable to environmental risks in urban areas was pollution: foregone labor output and lost welfare.8 In both estimated at some 80,000 and 2.6 million, respectively cases, the numbers of premature deaths (mortality) (see Table 1-1). In Dhaka alone, the corresponding and disability adjusted life years (DALYs) that are estimates are almost 18,000 and 579,000. 8. A detailed discussion of the methodology used in the CoED exercise may be found in the background paper, “Impacts and Costs of Environmental Degradation in Urban Bangladesh.” 9. A VSL measure “represents an aggregate of individuals’ willingness to pay (WTP) for marginal reductions in their mortality risks. It is not the value of any single person’s life or death, nor does it represent a society’s judgment as to what that value should be” (Narain and Sall 2016). VSL is estimated using the stated preference approach, whereby surveyed individuals are asked how much they would hypothetically be willing to pay to marginally reduce their mortality risk. As such, VSL is not limited to the value of output that would be lost in case of premature death, but covers an array of other values that contribute to an individual’s and society’s welfare. Therefore, this measure is not directly comparable with GDP. The method used to derive a VSL measure for Bangladesh is described in the background paper. 15 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh TABLE - 1-2: SUMMARY OF COST OF MORTALITY ESTIMATES IN URBAN BANGLADESH AND GREATER DHAKA (US$ BILLION) AND NATIONAL GDP (2015) EQUIVALENCES Urban Bangladesh Greater Dhaka Welfare Loss Foregone Output Welfare Loss Foregone Output Amount GDP Amount GDP Amount GDP Amount GDP equiv. equiv. equiv. equiv. PM2.5 air pollution ambient 2.42 1.24% 0.49 0.25% 0.53 0.27% 0.11 0.06% household 1.27 0.65% 0.25 0.13% 0.28 0.14% 0.06 0.03% Inadequate water, sanitation and hygiene direct impact 0.43 0.22% 0.14 0.07% 0.09 0.05% 0.03 0.02% indirect impact 0.08 0.04% 0.04 0.02% 0.02 0.01% 0.01 0.00% Arsenic in drinking water 0.80 0.41% 0.18 0.09% 0.18 0.09% 0.04 0.02% Occupational pollutants 1.52 0.78% 0.29 0.15% 0.34 0.17% 0.06 0.03% TOTAL 6.52 3.35% 1.40 0.72% 1.44 0.74% 0.31 0.16% The economic cost of this mortality in terms of and time costs of illness attributed to inadequate health foregone labor output is estimated at US$1.4 billion are estimated at US$130 million. Finally, the lost in all urban areas of Bangladesh and at US$310 income due to IQ loss in children exposed to lead near million in Dhaka alone. This is equivalent to 0.6 ULAB sites is estimated at US$50 million (see Table percent and 0.1 percent of Bangladesh’s GDP in 1-3). These estimates do not lend themselves to being 2015, respectively. Considering the broader welfare added together due to differences in the estimation impacts of mortality that go beyond foregone labor output, we estimated the economic impact at US$6.52 billion in urban Bangladesh and US$1.44 billion in TABLE - 1-3: ADDITIONAL COED Dhaka alone, which are equivalent to 3.4 percent and ESTIMATES (US$ BILLION) 0.7 percent of the 2015 GDP, respectively (see Table AND 2015 NATIONAL GDP 1-2). These figures may be considered the lower and EQUIVALENCES upper end of a plausible range of estimates of the economic cost of mortality attributable to quantifiable Amount GDP environmental health risks. equivalent Productivity loss in RMG 0.09 0.04% In addition, non-mortality costs of several aspects of industry due to air pollution environmental degradation in urban areas have been assessed. Specifically, following Narain and Sall (2016), Foregone labor output due to 0.05 0.03% IQ loss in children exposed the cost of health burden of PM2.5 air pollution was to lead estimated at 10 percent of the welfare loss estimate, namely US$370 million. The annual productivity loss Morbidity from air pollution of healthy workers in the RMG industry caused by ambient 0.24 0.12% ambient air pollution is estimated at US$90 million household 0.13 0.07% annually, a significant figure as it points to a potential vulnerability of Bangladesh’s wage competitiveness in Morbidity due to inadequate 0.13 0.07% this nationally important export sector. The treatment WASH Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 16 methods used. Equally as important, adding them productivity, and general welfare if environmental up would suggest completeness, whereas in fact, for management in urban areas was improved. The the majority of environmental health risks, the cost of next chapters present recommendations for priority disability—that is, treatment cost or lost productivity— institutional, technological, and planning measures is an area that still needs to be investigated. to be implemented by regulators, industries, and city governments to achieve cleaner industries and more It is important to note that these estimates are resilient urban areas. Undoubtedly, these measures conservative and do not reflect the entire cost come with costs to be incurred by these parties. of urban environmental degradation. This is However, these estimates show that such measures because these figures cover only a select number of would also help avoid significant costs to the economy environmental degradation impacts on humans, for and society. The selection of priority measures would which data and established estimation methodologies be best done on a location-specific cost-benefit or cost- are available, and also because estimations were made effectiveness analysis, whereby the avoidance of some of using conservative assumptions. For example, it was the costs identified would be accounted for as benefits. not possible to estimate the cost of lost biodiversity and recreational services from severe water pollution, or of The CoED exercise further highlights the need the health and behavioral impacts of exposure to lead. for more research in Bangladesh on emerging In addition, impacts of urban pollution go beyond the environmental externalities and their costs. In limits of urban areas. A good example is PM2.5 air particular, the sources of heavy metal contamination by pollution, which impacts peri-urban and rural areas industrial and non-industrial sources, and the health near the cities where the pollution sources are. and developmental impacts attributable to different sources, need to be better understood. Finally, it will Nevertheless, the estimates point to the gains be important for Bangladeshi research institutions to that could be made in terms of human health, lead such research. 17 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh CHAPTER 2. POLICY AND INSTITUTIONAL FRAMEWORK FOR POLLUTION CONTROL AND CLEANER PRODUCTION To put Bangladesh on a greener growth trajectory, the 2.1 CORE ENVIRONMENTAL government will need to strengthen different policies POLICIES AND STANDARDS and institutions and better leverage complementary approaches. With respect to industries, these GOVERNING INDUSTRIES include systems to (i) control pollution by enforcing Bangladesh’s policy and legal framework governing environmental standards and enabling public pressure; environmental performance has been gradually and (ii) support a shift toward cleaner technologies improving. The 1992 National Environment Policy and practices. This chapter presents an analysis of was Bangladesh’s first environmental law, which was existing policy and institutional systems that pertain revised in 2013 and is currently being updated. Since to industrial pollution, and makes recommendations then, over 25 different acts, policies, guidelines, and for their development. The chapter’s particular focus regulations have been instituted that play a role in on the manufacturing sector is justified by the sector’s regulating the environmental footprint of industries increasing contribution to air, water, and soil pollution, and development activities, as well as promote RECP. by the concentration of polluting manufacturing firms Figure 2-1 summarizes the chronological development in and around urban areas, and by the government’s of these policies and regulations (further information on plans for further growth of this sector, notably through progress since 2006 to build the environmental policy the establishment of many new economic zones. The and regulatory framework is provided in Annex A). key components of this analysis are: The policy framework and enforcement regime need • Adequacy of core environmental policies, to be strengthened to effectively address mounting regulations, and standards that govern industries environmental degradation and pollution. The and other sources of pollution; available benchmark data suggests that Bangladesh’s • Effectiveness of the enforcement and accountability regime for environmental protection is not as strict as regime, including the primary environmental in some other countries in Asia. Figure 2-2 compares regulator and the environment court system, as Bangladesh with select countries based on both the well as civil society as an agent in holding polluters stringency of environmental regulations and their accountable; and enforcement. The rankings are based on responses • Status of approaches to foster cleaner production. given by more than 14,000 executives in 148 countries to a survey carried out by the World Economic Forum (WEF). The highest ranked countries in the region include Japan and Korea (both high-income economies), and Malaysia (upper-middle-income). However, Bangladesh ranks lower than several lower- Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 18 FIGURE - 2-1:  CHRONOLOGY OF POLICIES, REGULATIONS, AND STRATEGIC PLANS RELATED TO ENVIRONMENTAL PROTECTION, INDUSTRIAL POLLUTION MANAGEMENT, AND RESOURCE EFFICIENCY IN BANGLADESH National Environmental Policy 1992 Environment Conservation Rules SREDA Act 2012 National Energy Policy 1995 1997 (Amended Feb and Aug 2002) Action Plan for Energy Conservation 2013 Environment Conservation Act 1995 National Industrial Policy 2005 Energy Efficiency & Conservation Master Plan National Environment Management Environment Court Act 2000 2014 Action Plan (1995-2005) Environment Conservation Act National Environment Policy 2013 (Amended 2000 and 2002) Brick Manufacturing and Brick Kiln Environment Conservation Rules Establishment (Control) Act 2013 1997 (Amended 2005) Bangladesh Water Act 2013 National River Conservation Act 2013 1990 1995 2000 2005 2010 2015 2020 Environmental Conservation Renewable Energy Policy 2008 Bangladesh Electricity & Energy Rules 1997 BEZA Act 2010 Research Council Act 2015 Bangladesh Climate Change Trust Act 2010 Bangladesh Standards and Guidelines Balumahal & Soil Management Act 2010 for Sludge Management 2015 Speedy Increase of Electricity & Fuel (Special National Industrial Policy 2016 Provision) 2010 Energy Audit Rules 2016 National 3R Strategy 2010 Petroleum Act 2016 Environment Court Act 2010 Bangladesh Biodiversity Act 2017 Environment Conservation Rules 1997 Environment Conservation Rules (Amended Feb 2010) 1997 (Amended Feb 2017) Environment Conservation Act (Amended 2010) middle-income countries, such as the Philippines, terms of stringency, Bangladesh was perceived as Indonesia, and Cambodia. Although the surveyed weaker on enforcement. The key areas in need of group ranked Bangladesh higher than Vietnam in improvement are discussed below. FIGURE - 2-2: STRINGENCY AND ENFORCEMENT OF ENVIRONMENTAL REGULATIONS IN SELECTED COUNTRIES, 2015 Japan Country Stringency Enforcement Malasia ranking (out of ranking (out of 113 countries) 113 countries) Republic of Korea Japan 6 5 Philippines Malaysia 24 19 Indonesia Republic of Korea 46 39 Thailand Philippines 47 46 Cambodia Indonesia 55 51 Bangladesh Thailand 81 70 Vietnam Cambodia 95 91 0 2 4 6 Bangladesh 97 98 Vietnam 101 87 Enforcement Stringency Source: Browne et al. 2014. For more details on the methodology used to ensure data quality, see the Global Competitiveness Report 2014–2015 at http://reports.weforum.org/global-competitiveness-report-2014-2015/results-computation/. 19 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 2.1.1 Revising the Environment Conservation there is no requirement for local disclosure, in the Rule local language, of summary information from the initial environmental examination (IEE)/EIA process. Bangladesh’s umbrella act for conserving the EIA findings are also not systematically disclosed on environment, improving environmental standards, the DoE website or any other government site, unless and controlling and mitigating pollution is the mandated by the disclosure requirements of donor Environment Conservation Act (ECA) of 1995. The agencies. Furthermore, the DoE does not publicly ECA is operationalized through the Environment disclose environmental monitoring information from Conservation Rule (ECR) of 1997, Bangladesh’s main industries or development projects, or compliance legislative tool for the environmental regulation of records, including fines or compensation levied for industries, which is currently being updated.10 The violations and damages. ECR 1997 lays out (i) the requirements for and procedures to obtain and renew an environmental Improving public disclosure and access to clearance for industries or other development environmental information will increase activities; and (ii) the national environmental quality transparency, accountability, and public trust in standards for ambient air, various types of water, the system. Greater transparency would help the industrial effluents, emissions, noise, vehicular DoE uphold the objectives of the ECA and ECR by exhaust, etc. better enabling public pressure to hold polluters accountable. In line with international good practice, – Improving the transparency of the environmental the DoE should require public disclosure of all clearance process environmental information related to facilities and development projects subject to Environmental The ongoing revision to the ECR provides a precious Clearance Certificates (ECCs). This should include opportunity to introduce stronger requirements for IEEs/EIAs, summaries in the local language, terms of public consultation and disclosure of environmental the ECC (including any special conditions imposed by information. The revised ECR is expected to improve the DoE), and ongoing compliance monitoring and the environmental clearance process, which is the enforcement data. The online component of a public government’s main opportunity to review and disclosure system of industry-specific environmental evaluate the potential environmental impacts of a information could be achieved by building on the proposed industrial facility (or other development recently developed online system for ECC issuance activity), and to specify environmental mitigation, and other services recently developed by the DoE. management, and monitoring requirements. The new Under the new system, an entrepreneur can submit proposed ECR does make consultations mandatory a clearance application and monitor it online from for “Red” category projects (highest potential risk) to his or her own office. This online system will help obtain site and environmental clearances, which is a create a central database of industries, industry types very important and positive amendment to the ECR and categories, and ECC renewal status. However, 1997. Nonetheless, the draft ECR revision leaves public access to such information in this system the public disclosure of draft or final Environmental is still very limited. There is significant scope to Impact Assessment (EIA) reports to the discretion of advance this system to incorporate additional data the Director General (DG) of the DoE. In practice, at fields and provide public access to more information, least some information is typically disclosed at the local including EIA report summaries, renewal status, level as part of public consultations for Red category environmental monitoring reports, and so on. It is projects, but completed assessments—which should therefore recommended to (i) further develop this outline the mitigation and management requirements system to incorporate key environmental clearance of the industry or facility—are not readily available to and compliance information of the industries; and (ii) local communities or the general public. In addition, make the information publicly available. A draft revision of the ECR was completed and approved by the Director General of the DoE in late 2017, and at the time of writing it 10. was awaiting formal approval by the ministry for official gazetting. The draft was made available to the World Bank by the DoE for early review. See Annex B for detailed observations and recommendations on the draft revised ECR. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 20 – Improving environmental quality standards be practical from an enforcement perspective, given existing baseline pollution levels (such as ambient air The usefulness of environmental clearances and quality standards). monitoring requirements in controlling pollution hinges on the environmental quality standards (EQS) Ambient standards need to be supported by that underpin them. Bangladesh’s EQS are set by compliance monitoring of pollution levels and a both the ECA of 1995 and the ECR under it (both the periodically updated plan to achieve compliance. prevailing 1997 rules and subsequent amendments, The DoE has some legal authority to collect and and the 2017 proposed revisions). They include publish information on environmental pollution, and ambient standards, i.e., limits to the concentrations publishes an annual report. However, monitoring and of certain chemical substances that pose significant reporting of area-based (e.g., for airshed, water basin, risk to human health, the environment, or biota ecosystems, etc.) environmental quality data is not (such as fisheries, biodiversity, forests etc.), as well as legally binding. Some DoE initiatives are underway, complementary limits for discharges, emissions, and such as the monitoring of criteria air pollutants in losses for these substances. major cities.11 The data is disclosed with a 24-hour lag period. The DoE also performs ambient water The proposed standards in the draft ECR revision quality monitoring for the four rivers around Dhaka. are partially strengthened, but could be more Area-based environmental quality monitoring is coherent. Some standards are tightened, but without recommended, with a gradual, phased approach adequate justification or nuance to reflect and provide starting with the most polluted hotspots, accompanied guidance for specific technologies used in Bangladesh. by strengthening the capacity of the DoE to perform For example, the emissions standard for brick kilns monitoring and compliance with EQS. Furthermore, has been tightened but the reduction appears ad disclosing environmental quality monitoring data in hoc and remains significantly above what is readily real-time, where available, will increase its utility to achievable under currently available technologies. the public and raise public awareness. Water quality standards have also been tightened, but a few (namely those regarding iron) are now below 2.1.2 Legal Framework for Industrial Hazardous WHO and developed countries’ standards, which Waste Management seems impractical/unachievable from an economic perspective and lack clear justification from a health Hazardous waste management remains an under- perspective. regulated and relatively unpublicized aspect of the country’s industrial development. Bangladesh The process of revising the EQS would benefit from is a signatory of the Basel Convention (Secretariat wider technical and public review and comment. To of the Basel Convention 1989) and the Stockholm facilitate this review, a background paper explaining Convention.12 The Bangladeshi legal framework on and justifying the proposed changes would need hazardous wastes centers on the Hazardous Waste to be prepared and published. This would enable and Ship breaking Waste Management Rules of 2011, a sound scientific and public debate to facilitate (i) promulgated under the ECA of 1995 (amended). adjusting certain standards to be meaningful and Hazardous materials (hazmats)—of which hazardous achievable in the Bangladeshi context, as well as to wastes are a subset—are defined and classified under clarify many standards that are too generic and lack the rules (details are provided in Annex D). Data on the technology-specific thresholds (notably for power extent of hazardous wastes in Bangladesh is outdated plants); (ii) tightening other standards that are now and incomplete, although a 2007 DoE study indicates behind current technologies (such as brick kilns) that industries producing hazardous materials are and inconsistent with international norms; and (iii) centered largely in Dhaka and Chittagong. Most clarifying standards that do not currently appear to hazardous wastes get disposed of in regular landfills, 11. Currently in the eight largest cities, soon to be scaled up to an additional five cities under additional financing from the World Bank– funded Clean Air and Sustainable Environment (CASE) Project. 12. Stockholm Convention on Persistent Organic Pollutants (2001). 21 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh where chemicals may leach into groundwater and protection, and has been given wide powers under contaminate soils, or be burned and release toxins into the 1995 ECA.14 However, as the reality on the ground the air. shows, the DoE is under equipped to effectively address the country’s mounting pollution challenges. The DoE, The hazardous materials management regime needs which sits under the Ministry of Environment, Forest, to be improved, especially in terms of data collection, and Climate Change (MoEFCC), was established in regulations, and institutional framework. Further 1977 as the Environmental Pollution Control Board assessment is needed to better understand the current following promulgation of the Environment Pollution quantities and types of hazardous material produced Control Ordinance of 1977. This Board was assisted in Bangladesh and the challenges and options related by a Pollution Control Cell, which ultimately grew into to its disposal. Importantly, the legal framework also the Department of Environmental Pollution Control requires further review—for example, to fully align the and subsequently the Department of Environment. hazmats classification system with Basel Convention Under the provision of the 1995 ECA, the DoE is requirements, and to clearly mandate a 3R (reduce, responsible for: reuse, and recycle) approach for industries, including considering full product lifecycles as part of industrial • granting ECCs to factories and development permitting requirements. There is also a need to set projects; up a system, including policy, regulatory, and funding • undertaking inspections of industrial units and aspects (with clarity on revenue structure for financial monitoring compliance with and enforcement of sustainability) to clean up and remediate legacy environmental standards; contamination.13 • preventing activities likely to cause environmental degradation; and • carrying out various other advisory and research 2.2 ENFORCING ENVIRONMENTAL activities. COMPLIANCE – Strengthening human resources and the organizational Even a robust legal and regulatory framework is only structure as effective as its implementation. The institutions charged with implementing and upholding the laws With the increase in responsibilities over time, and regulations are therefore the second critical pillar as well as the country’s growing environmental of environmental governance. The following section challenges, the DoE requires a significant increase examines three essential elements of an effective in staffing to perform its core functions. The compliance, enforcement, and accountability regime: volume of tasks undertaken by the DoE has increased (i) the capacity and effectiveness of Bangladesh’s DoE, manifold over the last two decades due to the scale as the country’s primary environmental regulatory of environmental issues and regulatory demand, and authority; (ii) the environment court system; and (iii) changing economic, population, and environmental civil society as an agent and promoter of environmental conditions. However, its manpower has not increased accountability. nearly enough to accommodate this increase. The DoE currently operates with a staff of 431 against 2.2.1 The Department of Environment an approved 735 posts (the rest being vacant due to bureaucratic delays). In 2016, the DoE requested the Bangladesh’s DoE has the mandate to implement additional hiring of 1,222 staff to meet its needs for Bangladesh’s legal and regulatory framework for all district and divisional offices, but only managed environmental protection, but lacks the resources to get 172 new posts approved. If Bangladesh is to to effectively do so. The DoE is the only institution successfully tackle pollution and set the country on a in Bangladesh with a mandate for environmental long-term sustainable development path, the DoE’s Additional analysis and recommendations are provided in Annex D. 13. 14. Other institutions that also play a role in promoting and regulating industrial production—and can therefore help shape the environmental outcomes of those activities—are discussed in Section2.3. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 22 TABLE - 2-1: STAFF  IN SELECTED COUNTRIES’ ENVIRONMENTAL AGENCIES Bangladesh Philippines Mexico Population (million) 161.0 100.7 127.0 GDP (US$ million) 195.1 292.5 1,143.0 Total approved agency headcount 735 1,780 6,593 National population per employee, 220,000 56,573 19,262 based on approved headcount Note: Based on data from GoPh 2018, GoM 2018, and World Bank 2017. budget allocation and approved headcount need to DoE office have to apply to the nearest DoE office. reflect its central importance in this challenge. This often results in processing delays, as it further burdens the already overstretched neighboring offices. While Bangladesh aspires to become a middle- Moreover, in areas with no district office, the DoE also income country, the DoE’s approved headcount lacks eyes on the ground to monitor and follow up on is significantly lower than that of environmental cases of ECC noncompliance. agencies of comparatively sized middle-income countries, where staffing data was available. Using A needs assessment for DoE services based on total population per approved agency staff as a proxy concentration of industries and polluting activities measure, Table 2-1 compares Bangladesh’s DoE with would allow prioritizing of opening and staffing field approved posts in the Philippines’s Environmental offices. For example, with the increased number of Management Bureau, and the sum of approved posts washing and dyeing plants in Valuka, Mymensingh, as covering similar environmental policy, compliance, well as polluting industries in Netrokona and Sherpur, and enforcement functions in Mexico, which are additional resources in this region are strongly spread across three Mexican agencies.15 justified. The recently approved Divisional Office in Mymensingh likewise needs to be quickly staffed given Staffing increases are especially needed at the that area’s trends in industrial development and urban divisional and district levels. Inadequate manpower growth. With the increased need to protect sensitive and physical resources at the field level do not allow ecosystems, stop hill-cutting, and address pollution, the DoE to extend its activities in a fully decentralized additional manpower is also urgently warranted for way. The DoE is set up in six divisional headquarters,16 Cox’s Bazar District Office. In some of these industry- underneath which are field offices in 21 districts intensive districts, it may be further warranted to have (out of the 64 districts in 8 divisions of Bangladesh) DoE offices at the subdistrict (upazila) level. (see Figure 2-3). Divisional offices typically have 5–6 staff, while district offices typically have just 3 staff. Aside from decentralization, the DoE needs to They are nonetheless supposed to process all files ensure that the core functional areas related to major related to environmental clearances, remediation, environmental priorities are clearly reflected in and corrective and enforcement actions for all the organogram. Since the 2006 CEA, the DoE has industries and development activities that trigger commendably created a Directorate for Air Quality such requirements in that division/district. Industries with functional focus on Air Quality Management, as seeking environmental clearance or processing of well as a Directorate for Climate Change. However, other compliance-related actions in districts with no similar directorates do not exist for other core 15. Mexico’s Ministry of Environment (SEMARNAT), the agency that approves environmental clearances and conducts environmental enforcement for the energy sector (ASEA), and the enforcement of environmental regulations by Procuraduría Federal de Protección al Ambiente (PROFEPA). 16. Currently, there are eight divisions in Bangladesh, with Mymensingh the latest formed out of the Dhaka Division. 23 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh functional areas, such as water quality, wastewater An “environmental cadre” system could be management, hazardous waste management, considered to help attract and retain talented and environmental quality, laboratories, and so on. Adding competent professionals, as well as bolster the DoE’s such directorates would help ensure that these issues authority within the government. Under the current receive the attention they require and bring the DoE system, professional career staff cannot make it to in line with the environmental authorities of many senior leadership levels due to lack of a cadre. This other countries.17 serves as a disincentive for recruitment and long- term retention of professional staff, who may choose Full separation between environmental clearance instead to seek opportunities in the private sector or staff and monitoring and enforcement staff would elsewhere after hitting the internal “glass ceiling.” enhance accountability and efficiency. As shown in the organogram (see Figure 2-3), environmental – Improving information management systems clearance is already separate from monitoring and enforcement at the directorate level. However, The environmental clearance renewal system staff are not consistently distinct in divisional and is poorly implemented, undermining its utility. district offices. This separation needs to be further Project proponents are currently required to follow implemented through clear job descriptions and the conditions prescribed by the ECC granted by responsibilities down to the district level offices. the DoE regarding the implementation of mitigation FIGURE - 2-3:  ORGANOGRAM OF THE DEPARTMENT OF ENVIRONMENT Director General Additional Director General Headquarters Divisional /Regional Office Director Director Director Director Director Director Director Director Director (Climate Change (Natural Resources (Administration) (Environmental (IT) (Air quality (Planning) (Monitoring and (Legal) and International Management) Clearance) management) Enforcement) Convention) Director Director Director Director Director Director Director Director Director Director Chittagong Chittagong (Metro) Chittagong (Lab) Dhaka (Regional) Dhaka (Metro) Dhaka (Lab) Rajshahi Khulna Sylhet Barisal (Regional) District Office District Office District Office District Office 1. Deputy Director- Cox’s Bazar 1. Deputy Director- Dhaka 1. Deputy Director- Rangpur 1. Deputy Director- Jessore 2. Deputy Director-Chittagong 2. Deputy Director- Gazipur 2. Deputy Director- Rajshahi 2. Deputy Director- Kushtia 3. Deputy Director- Feni 3. Deputy Director- Narayanganj 3. Deputy Director- Bagerhat 4. Deputy Director- Noakhali 4. Deputy Director- Manikganj 5. Deputy Director- Chadpur 5. Deputy Director- Narsingdi 6. Deputy Director- Comilla 6. Deputy Director- Munshiganj 7. Deputy Director- Brahmanbaria 7. Deputy Director- Tangail 8. Deputy Director-Maymensingh 9. Deputy Director- Faridpur A quick way to achieve this without excessive organizational reform may be to put the general affairs and services in the office of the 17. DG/ADG, thus freeing the positions of a number of directors (e.g., administration, law, IT, etc.) and to replace these positions with directors with functional focus and deliverable objectives. With the new Climate Change Division (section) in the ministry, the Climate Change Director’s functions may be considerably reduced. Thus, the functions of this director (which may only be inter-agency liaison now) may be placed under the Planning Director, freeing another director position. Further comparative information and examples of organizational structures for agencies/departments from other countries with similar roles and responsibilities are provided in Annex C. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 24 FIGURE - 2-4:  EXPECTED AND ACTUAL NUMBER OF ECC RENEWALS, 2010–15 29,097 22,833 16,980 11,677 5,427 4,754 4,076 2,226 1,409 73 2011 2012 2013 2014 2015 Cumulative Number of Orange and Red category projects approved since 2010 Incremental number of ECC renewed since 2010 Source: Ahmed and Ferdausi 2016. measures and the agreed monitoring program. track all ECC holders, the status of their compliance, The Environmental Management Plan (EMP)—a and ECC renewal would make the DoE’s enforcement requirement for obtaining the ECC—becomes a function more efficient. Such a system should be binding obligation. Additionally, project developers transparent to the public via a website portal to enhance and industrialists must also apply for periodic ECC polluters’ accountability. The portal could also receive renewal for the entire lifespan of the project or facility. automated monitoring data from industrial clusters The application for ECC renewal is supposed to and large industries, and track grievances related to include environmental monitoring data, which should environmental management issues on specific facilities serve as an important indicator for the effectiveness or projects. of mitigation measures suggested in the EMP. Data collected over the last five years regarding the issuance – Bringing in outside expertise and outsourcing and renewal of ECCs shows a growing disparity between the project EIA approvals and the number of Drawing on outside experts for EIA review could ECC renewals. While the number of renewals should be a way to supplement the DoE’s limited internal theoretically match the cumulative number of ECCs capacity for the environmental clearance process. issued to the total projects each year, the number of The increase in the number of Red category project additional renewals is only a small fraction of this applications in Bangladesh over recent years (see expected number (see Figure 2-4). This indicates Figure 2-5) have created additional workload, if the that the DoE’s internal mechanisms for tracking, DoE is to adequately scrutinize the EIA documents monitoring, and following up on ECC renewals required to issue ECCs. These EIA reports are mostly are currently ineffective. In many cases, it has been related to power, water resources, land resources, and found that the proponents are totally unaware of this infrastructure development projects, which require particular provision of the 1997 ECR, which is also a a wide variety of expertise to review and monitor. symptom of the DoE’s inadequate capacity for follow Though most Red category projects are typical, there up. are some projects for which EIA reports require very specific expertise to review (e.g., nuclear power plants, The DoE should invest in better monitoring and coal-based power plants). Under the current system, enforcement systems. Developing a comprehensive only DoE officials review the EIA, and no independent information management system and database to technical experts are involved. Therefore, not only 25 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - 2-5:  NUMBER OF DIFFERENT PROJECT CATEGORIES GIVEN ECC, 2010–14 Number of Projects given Environmental 7000 6000 5000 Clearance 4000 3000 2000 1000 0 2010 2011 2012 2013 2014 Red 201 205 269 278 290 Orange B 2,495 2,768 3,272 2,874 2,953 Orange A 2,266 2,454 2,709 2,151 2,610 Green 25 9 32 8 14 Source: Ahmed and Ferdausi 2016. does the sheer volume of Red category projects experts to assess Red category projects and advise on become burdensome to an understaffed technical whether site and environmental clearances should be committee, but the lack of specific expertise in the issued. evaluation committee might result in poor quality EIA reports being approved. The proposed 2017 ECR has Similarly, the DoE can look into ways to outsource its a provision for constituting a clearance committee in monitoring activities to competent consulting firms, the DoE for deciding on Red category projects. It is given inadequate in-house staffing and multiple recommended that the committee involve outside mandates. Even with the best data management FIGURE - 2-6:  PROPORTION OF INDUSTRIES SUBJECT TO DOE ENFORCEMENT, 2014–15 Brick Kilns Others Dyeing Factories Banned Polythene 1% 21% 30% Factories / Stockpiling Companies 3% Steel Mills 1% Real Estates 1% Paper Mills 5% Washing Factories 38% 2014-2015 FY Enforcement activities (based on industry type) Source: DoE 2016. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 26 FIGURE - 2-7:  DOE ENFORCEMENT BASED ON NATURE OF POLLUTION, 2014–15 Miscellaneous Air Pollution Pollution10% 2% Noise Pollution 1% Filling Water Bodies 1% Hill Cutting 3% Water Pollution 83% 2015-2016 Fiscal Year Enforcement Activities (based on nature of pollution) Source: DoE 2016. systems, competent staff are still needed to review pollution; and (iv) there are other sources of pollution monitoring data and follow up with polluters. In this beyond industry (e.g., municipalities, agriculture), regard, the DoE could leverage the services of different further pointing to the importance of the area/ laboratories of other government organizations and watershed-based approach noted above. The DoE educational institutions. should reassess its strategies to identify and address actual causes of pollution. – More consistent application of penalties Ad hoc application of the polluter pays principle The current penalty system does not provide needs to be replaced with a rule-based system under effective deterrence and requires an overhaul. the ECA. The DoE applies the polluter pays principle The DoE applies the “polluter pays principle” for to calculate the fines incurred by a particular polluting environmental conservation according to Section 7 of industry (which is based on a calculation of cost for the 1995 ECA (amendment 2010), which states that if it treatment per cubic meter of wastewater times the appears “that any act or omission of a person is causing volume of wastewater discharged). However, evidence or has caused injury to the ecosystem, the person may from various newspaper reports suggest that fines (i) bound to compensate that.” Factories that contribute are arbitrary in nature and do not distinguish between to water pollution have been fined the most compared different levels of violation; (ii) may be too low to deter to other industries (see Figures 2-6 and 2-7). Those polluting activities; and (iii) do not clearly distinguish fined the most (both in terms of number of industries repeated offenders. Table 2-2 shows the level of fines and quantity fined) were dyeing operations, washing for different violations, which appears to vary among factories, and paper mills. However, water pollution different groups of violations and even within a group. continues unabated and river water quality has Even if the factory is fined twice a year, for an average continued to deteriorate. This may be due to various of BDT 10,00,000 (approx. US$120,000), it would be factors, including: (i) fines/compensation are not high more economical to pay the fine rather than run a enough; (ii) fines/compensations are not realized; wastewater treatment plant.18 Furthermore, the DoE (iii) the degree of enforcement activities is very low does not currently maintain a comprehensive database compared to the number of industries responsible for of inspections, fines, and compensation levied. The It has been estimated that the average cost of wastewater treatment for a textile dyeing factory is around BDT 32 per cubic meter using 18. chemical method, which can translate into an annual cost of BDT 1,33,50,000 for a small factory (Prothom Alo 2013). 27 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh TABLE - 2-2:  FINES IMPOSED BY THE DOE ON INDUSTRIES CAUSING WATER POLLUTION, 2011–16 No clearance ETP turned off and bypass drain used ETP not operating Clearance not renewed; no ETP Clearance not renewed; faulty ETP Fine based on discharge quality report Bypass drain and ineffective ETP Bypass drain ETP turned off No ETP Faulty ETP No clearance; no ETP 0 10 20 30 40 50 60 70 Mean fine (lakh BDT) Standard deviation Source: Haque 2017. policy implications are significant, as the lack of clear The process of collecting fines needs to be more evidence that repeating an offense will result in greater efficient. Table 2-3 shows that in most cases, fines fines weakens deterrence (Haque 2017). A rule-based are collected less than 50 percent of the time. Two system is needed, which specifies progressive fines key reasons for this inefficiency may be: (i) payments that vary with the ranked level of violation. Repeated are made in installments; and (ii) project proponents violators must be penalized at progressively higher take shelter in courts, which delays the process if an rates or subjected to forceful closure. Also, the DoE injunction is ordered. On the latter, the High Court needs to maintain a proper database for recording has over time developed more confidence in the inspections so it is easier to track industries’ activities DoE’s compensation calculation methodology, and after they are penalized. in recent instances has approved the DoE’s method TABLE - 2-3: DOE ENFORCEMENT ACTIVITIES BASED ON POLLUTION TYPE, 2014–15 Pollution type No. of entities Compensation Compensation Collection fined imposed (Crore) collected (Crore) rate Air pollution 68 2.10 1.19 57% Noise pollution 3 - - River pollution/water pollution 283 32.52 15.42 47% Cutting hills 9 1.50 0.60 40% Filling water bodies 10 0.34 0.16 47% Other 29 0.49 0.47 96% Total 402 36.95 17.84 48% Source: DoE 2015a. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 28 of collecting compensation—and even instructed current year is only BDT 365 million (approximately the DoE to calculate compensation on the court’s US$4.4 million). behalf. It is therefore possible that fine collection may become more efficient in the future. It is nonetheless By international comparison, the DoE’s budget recommended that the DoE look into additional ways is notably low to fulfill its mandate. It is not easy to enhance expedient collection of fines, which will to provide direct international comparisons due also serve to increase their deterrence value. to limited public availability of detailed budget information, a variety of methodologies or categorical – The DoE’s financial sustainability groupings employed by different countries in their public reporting, and varied environmental contexts The DoE’s non development budget (e.g., recurring and institutional structures for environmental agencies core expenditure) has been stagnant, despite the across countries. However, some comparisons can still department’s increasing responsibilities. In the fiscal be made. Figure 2-8 compares budget allocations to year (FY) 2017 national budget, the MoEFCC’s total comparable environmental authorities or agencies allocation was BDT 10.3 billion (approx. US$124 from Bangladesh, the Philippines, Mexico, and Peru. million), or about 0.2 percent of the national budget. The information is presented on a per capita basis, The DoE’s budget within this allocation was BDT 1.02 and as a share of the national budget, taking into billion (approx. US$12.3 million), or about 10 percent account that the selected countries’ populations and of the MoEFCC’s budget.19 In the most recent (FY18) economies vary widely. The DoE’s budget allocations budget, the MoEFCC’s total allocation went up by are significantly smaller than those of the other about 8 percent, to BDT 11.2 billion (approximately countries, particularly when compared on a per capita US$135 million). Within this envelope, the DoE’s basis. budget allocation increased to BDT 1.36 billion (approx. US$16.4 million), which is an increase of 34 percent over the previous year. By comparison, the  FIGURE - 2-8: ANNUAL BUDGET overall national budget increased by 15 percent during ALLOCATED TO the same period. While the increase in the DoE’s ENVIRONMENTAL budget compared to the national budget is notable, DEPARTMENTS/AGENCIES the additional budget is allocated almost entirely to OF SELECTED COUNTRIES development expenditures (e.g., financing public 6.00 0.30 investment projects, which are a one-time budget US$ % for specific purposes), rather than nondevelopment 4.00 0.20 expenditures (e.g., recurrent expenditures for 2.00 0.10 carrying out core functions, such as public officials’ salaries, goods needed to provide services, social or - - Bangladesh Philippines Mexico Peru economic interventions, interest payments, and so on). The increase in the DoE’s budget for nondevelopment Environment department/agency budget per capita expenditures is only 2 percent over the previous Environment department/agency budget as a share of year—which actually represents a net decline when national budget factoring in annual inflation of approximately 5.6 Source: Based on GoPh 2018, GoM 2018, GoPe 2018, MINAM 2018, percent. The DoE’s nondevelopment budget for the OEFA 2018, and SENACE 2018b.20 19. In addition to the DoE, there are four institutions under the MoEFCC: the Forest Department (FD), the Bangladesh Forest Industries Development Corporation (BFIDC), the Bangladesh Forest Research Institute (BFRI), and the Bangladesh National Herbarium. 20. Bangladesh’s data is based on the DoE’s most recently available annual budget allocations. The Philippines’ data is for the Environmental Management Bureau. In Mexico, data include aggregate budget for (i) policy making at the Ministry of Environment (SEMARNAT); (ii) the agency that approves enviromental clearances and conducts environmental enforcement for the energy sector (ASEA); and (iii) the agency that oversees enforcement of environmental regulations (PROFEPA). In Peru, the estimates comprise the aggregate budget for (i) policy making at the Ministry of Environment (MINAM); (ii) the agency that approves EIAs (SENACE); and (iii) the environmental enforcement agency (OEFA). 29 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 2.2.2 Environment Court System situated in Dhaka, received just 43 appeals during 2005–15. In contrast, the Green Tribunal system in Outside the DoE, the environmental enforcement India—which was set up in 2010 under a similar regime is limited by the lack of an effective mandate (but with a broader scope and covering environment court system. In Bangladesh, a separate a number of environmental laws)—has disposed environmental court system is envisioned under the 19,970 cases between its creation and September law, but has not been fully implemented to date and 2017, from its central and zonal benches (National remains difficult to access for the public. This section Green Tribunal 2016).21 It has been perceived as a discusses the limitations and possibilities for reforming “fast-track court” for effectively and expeditiously this system. disposing cases relating to environmental protection and conservation. Bangladesh’s environment courts The environment court system was established with have not achieved a similar level of confidence and the idea that specialized courts would expedite cases efficiency. As another point of comparison, almost related to environmental pollution. Bangladesh’s 700,000 cases are filed every year in the Environment traditional adalat (court) system was deemed Control Board of New York City (Sajal 2015). inadequate for executing environmental laws and policies. For this reason, the government enacted the Several factors may contribute to the low use of the Environment Court Act of 2000, which was revised in environment court system to date: 2010, with the aim of ensuring implementation of the 1995 ECA and 1997 ECR through judicial activities. i. The legal framework limits people’s right to The act aims to establish one or more environment access environment courts directly.22 There is an court in each district, presided by a joint district exception to this provision, whereby the court judge. However, it does not mandate the creation may recognize an offence of a complainant of a separate or independent environment court in directly, but the procedural provisions are more each district. As such, only three district-level courts complicated,23 and this probably discourages (Dhaka, Chittagong, and Sylhet—all established under potential complainants from moving forward with the original 2000 Act) and an appellate court in Dhaka their cases. have been established to date. ii. Given the current set up, the general understanding is that since the DoE is primarily Despite the continued growth of Bangladesh’s responsible for filing a suit and performing an environmental problems, very few cases have investigation, the ability of the environment been filed in the three environment courts and courts to properly function rests with the DoE. the environment appellate court. Just 100 cases Yet as previously discussed, the DoE’s capacity are filed on average in Bangladesh’s environment is extremely limited, especially in district and courts every year. Between 2003 and June 2015, divisional offices. 467 cases were filed in the Dhaka Divisional iii. The environment courts’ jurisdiction is limited. Environment Court, of which 350 were disposed According to the 2010 Act, environment courts and 117 are still pending as of writing. During a can only entertain offences and claims for similar period, almost 350 cases were filed in the compensation under “environmental law,” which Chittagong Divisional Environment Court, of is defined to include the 1995 ECA and 1997ECR, which 250 are still pending at the time of writing. and provides for other laws to be added to the The country’s only environment appellate court, list if subsequently specified by the government 21. For more information see National Green Tribunal, http://www.greentribunal.gov.in/Home.aspx. 22. According to Section 7(4) of the 2010 Environment Court Act, “No Environment Court shall receive any claim for compensation under environmental law except on the written report of an Inspector of the Department of Environment (DoE).” Section 6(3) states, “No Special Magistrate Court shall take cognizance of an offence except on the written report of an Inspector or DG, DoE.” 23. If the environment court/Special Magistrate Court is satisfied that a person presented a written request to the said inspector to accept a claim for compensation/a complaint and no action was taken within 60 days after such request, and that such claim/complaint deserves to be taken into cognizance for the purpose of trial, then the court may, after giving the inspector or DG a reasonable opportunity to be heard, directly receive the claim for compensation/complaint without such written report or may, if it considers appropriate, direct the said inspector to investigate the claim/offence. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 30 in an official gazette. However, only one other In Bangladesh, public interest litigation (PIL) law—the Brick Manufacturing and Brick Kilns has allowed important strides in establishing Establishment (Control) Act of 2013—has been environmental case law to hold companies or subsequently specified by the government in the individuals accountable for causing environmental official gazette to fall under the jurisdiction of the harm. The concept of PIL emerged in Bangladesh’s environment court. judicial administration in the early 1980s, primarily iv. Even if the courts were open to the public to directly inspired by its evolution and use in India and Pakistan. file cases against polluters, proving environmental Since then, it has been crucial in the country’s pollution requires technical knowledge and development of environmental jurisprudence. By scientific evidence, both of which are typically out definition, PIL means litigation filed in a court of law of reach for common citizens without institutional for the protection of “public interest,” which includes assistance. If that assistance is not available (either environmental issues as they relate to the fundamental from the DoE or any interested parties), the right to have a healthy and safe environment in case is unlikely to be pursued, especially because which to live. Previously, only individuals whose common citizens may be too intimidated to file a interest was directly affected typically filed such lawsuit against polluters with potentially powerful litigation. Nowadays, any concerned citizen (or citizen economic and political connections. group) can file a PIL case on behalf of a group of individuals whose rights are affected. The Bangladesh To make the environment court system a more effective Environmental Lawyers Association (BELA) has been mechanism for holding polluters accountable and to leading the PIL movement in Bangladesh. Some provide public recourse in the case of environmental notable environmental PIL cases are synthesized damages, several actions could be taken. In particular: in Table 2-4. All these resulted in the High Court issuing a rule on the implementing and regulatory i. The Environment Court Act of 2010 would benefit agencies asking for an explanation of negligence, or from amendments to make the environment by directing the executing agencies to immediately courts people-focused, allowing the public to cease harmful activities. directly file lawsuits rather than going through the DoE, and to have a broader mandate covering all Bangladesh’s civil society has played a notable role in environmental policies and acts. advocating for environmental protection. Bangladesh ii. Setting up environment courts in all districts Poribesh Andolon (BAPA), launched in 2000, is one of would facilitate public access. the most prominent civil society organizations in the iii. DoE field offices need to be strengthened in terms country. Its mission is to create a nationwide, united, of skilled manpower to provide better support to and strong civic movement to protect Bangladesh’s the public in filing cases with the environment environment. BAPA has already brought some positive courts. This is relevant even if the act is amended changes to the environmental cause in Bangladesh, to allow for direct filing, given that affected parties working together with other environment-focused are still likely to require assistance to gather civil society organizations, such as the Coalition of evidence and provide technical backing to the Environment NGOs, Forum of Environmental NGOs, lawsuit. Association of Development Agencies Bangladesh, etc. Some successful campaigns that eventually influenced 2.2.3 Civil Society the government to adopt environmental protection measures include, for example: The third key element of any effective environmental enforcement system is the ability of civil society to 1. Removal of two-stroke engine vehicles, which were play an active role in holding polluters accountable. a major cause of urban air pollution in Bangladesh; This subsection discusses the Bangladeshi civil 2. Ending the use of leaded gasoline in Bangladesh; society’s capacity in this regard, and ways that it 3. Passing a ban (in 2018) limiting lead content in could be further strengthened to contribute more paint to 90 ppm; actively to environmental protection and sustainable 4. Re-imposing the ban on the use of polythene bags; development. and 31 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh TABLE - 2-4: SAMPLE PUBLIC LITIGATION CASES Public interest litigation Environmental issues addressed Dr. Mohiuddin Farooque vs. Indiscriminate cutting of hills causing degradation and ecological Bangladesh and Others imbalance of Chittagong Dr. Mohiuddin Farooque vs. Negligence in preventing the fire that engulfed the Magurchara gas Bangladesh and Others field and adjoining areas while the Occidental oil company was carrying out their regular excavation, regulatory bodies approving such activities without proper EIA BELA vs. Bangladesh and Illegal encroachment on the Buriganga River Others Biplob Kumar Roy vs. Illegally leasing out parts of the Nobogonga River in Narail, affecting the Bangladesh and Others livelihood of poor fishermen BELA vs. Bangladesh and Illegal earthfilling of Ashulia FFZ by Jamuna Builders Ltd. in 2002 Others without the permission of RAJUK, in gross violation of the Master Plan BELA vs. Bangladesh and Unlawful filling up of Gulshan, Banani, and Baridhara lakes for creating Others housing plots Quazi Faruque vs. Ministry of Inadequate life-saving buoys and apparatuses in all launches carrying Shipping and Others passengers BELA vs. Bangladesh and Pollution of coastal and marine ecosystems caused by the disposal of Others hazardous shipwastes from the shipbreaking operation in Sitakunda of Chittagong in violation of environmental and labor protection BELA vs. Bangladesh and Relocation of tanneries in the Hazaribagh area to suitable locations and Others ensuring adequate pollution prevention devices are developed in the new location under existing regulations Source: DoE 2015a. 5. Initiating a river-saving movement in Dhaka, transparency, raising awareness of environmental leading to the removal of many structures issues and concerns, and establishing mechanisms encroaching on rivers in and around Dhaka. for engagement. With the broader adoption of smart phones, Internet access, and social media, there Strengthening the general public’s awareness can are new opportunities to strengthen awareness of be a way to exert pressure on polluters and hold the environmental issues in urban areas. By supporting system accountable. Print and electronic media are public education and awareness—such as by developing already playing an important role in this regard. The apps through which to display environmental citizenry’s greater environmental awareness also helps information such as pollution data, updates on individuals to make smarter personal choices in terms environment court cases, public consultation events of consumption patterns and market behaviors, which for EIAs, etc.—and by establishing online platforms in turn puts pressure on manufacturers and vendors that allow community members to identify polluters to clean up their supply chains and manufacturing anonymously (to protect whistle blowers and the practices. general public from retaliation), the government could reap the benefits of greater shared responsibility for Civil society’s role in environmental protection environmental outcomes, as well as citizens’ eyes and could be enhanced by improving information ears on the ground to track polluters. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 32 2.3 PROMOTING BETTER production through regulatory/institutional reforms and targeted programs would significantly contribute ENVIRONMENTAL PERFORMANCE to reducing industrial pollution, especially if combined AND GREEN GROWTH with more effective enforcement. Improving environmental performance in Bangladesh Inadequate pricing of resources and the lack of could yield significant social and economic gains. instruments to internalize environmental externalities Most industries in Bangladesh continue to rely on in production costs are partly responsible for the inefficient and polluting technologies and practices. current situation. In particular, the absence of water However, there is clear evidence from polluting charges and unmetered use of groundwater by sectors (textile, leather, brick) that investments in water-intensive industries, such as textile and leather better environmental outcomes through RECP could production, have long encouraged inefficient use and be financially profitable for firms while generating make water conservation unattractive from a purely multiple benefits, such as mitigating GHG emissions, financial perspective. Charges for industrial use remain saving scarce resources, and reducing pollution. This rare and water supplied through water authorities has would help firms reduce the cost of compliance with been significantly underpriced compared to other environmental regulation. It would also make them countries (WRG 2015). This situation could change more competitive by enhancing productivity and, with the implementation of the upcoming Bangladesh for industries inserted in global value chains (e.g., Water Act, which will officially introduce a tariff on textiles, garment, leather), their capacity to respond water usage. Likewise, industrial use of oil products to increasingly stringent buyer requirements. Despite this, several policy and market failures have limited and natural gas has been subsidized, which, in the uptake of RECP to date.24 addition to burdening public finances, disincentivizes energy efficiency and the switch to cleaner energy Policies, regulations, and programs to foster sources (Nordic Council of Ministers 2017). Finally, RECP can complement, incentivize, and enhance unlike several other developing countries that have environmental compliance. While far more attention addressed environmental issues through taxation and resources are needed to bolster the DoE’s core (such as China, Malaysia, and Vietnam), Bangladesh functions in regulating and enforcing environmental has not yet resorted to fiscal policy as a way to standards, this alone is unlikely to ensure a green internalize environmental externalities from resource development path for Bangladesh. This section use and pollution. Recent attempts to introduce a looks at the policies and role for the DoE and other pollution tax for industries and a carbon tax have institutions to promote RECP. been abandoned after lobbying from targeted sectors. On the other hand, customs duties on some products, 2.3.1 Policy Framework for RECP such as chemicals (World Bank 2014) and solar panels (Daily Star 2017), are increasing the cost of cleaner In Bangladesh, policies to foster RECP have been products and technologies. limited, to date. Industry-related environmental policy and regulations have so far mainly focused on 2.3.2 Institutional Framework for RECP “end-of-pipe” pollution control requirements and measures. Some policies—including the national 3R Several ministries and departments beyond the policy and the 2016 Industrial Policy—have promoted DoE can help create an enabling environment for more efficient and sustainable use of resources, but greener industrial growth. Industrial development in have yet to be implemented. Promising pilot initiatives Bangladesh will continue to come at a high cost to the have been successful in some polluting sectors, such as environment unless the DoE becomes more involved brick making and textiles, but more efforts are needed in RECP-related issues, and without other parts of to scale them up and reach more sectors and types government dedicating more attention to sustainability of firms. Stepping up efforts to mainstream cleaner concerns. Environmental systems and capacity must For an analysis of constraints to cleaner production in the case of the textile industry, see “The Bangladesh Responsible Sourcing 24. Initiative: A New Model for Green Growth” (World Bank 2014). 33 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh be developed and strengthened, particularly among The DoE could build on its experience in the brick the institutions responsible for directly overseeing sector to promote RECP at a larger scale. The brick industry, industrial estates—special economic zones example shows how different instruments can be (SEZs) and export processing zones (EPZs)—and used complementarily to advance the transition to commerce. The following subsections discuss how the cleaner production. This experience could inform the DoE, the Ministry of Commerce (MoC), the Ministry development of a more comprehensive framework of Industry (MoI), the Bangladesh Export Processing to promote RECP, coordinating both push and pull Zones Authority (BEPZA), the Bangladesh Economic factors.25 Regarding the latter, there is a need for Zone Authority (BEZA), and the Ministry of Finance more sources of information and technical support for (MoF) are contributing and could further contribute industries. As a starting point, virtual and/or physical to the greening of Bangladesh’s industrial sectors. knowledge centers could be established. Institutional modalities could also be explored to conduct research – The DoE and development on RECP and provide firms in priority polluting sectors with more direct technical support to pilot and demonstrate new RECP technologies. The DoE could play a more active role to promote For instance, the National Cleaner Production cleaner production, in partnership with industries Centers sponsored by the United Nations Industrial and their associations, which will facilitate Development Organization (UNIDO) and the United compliance. While monitoring and enforcing Nations Environment Programme (UNEP) have played environmental regulations should remain priority this role in almost 50 developing countries over the last functions, many environmental agencies around two decades, but no such center has been established the world also disseminate knowledge and provide in Bangladesh (UNIDO and UNEP 2015). Various industries technical support to foster the adoption institutional modalities that involve the public and of cleaner technologies and practices. In industrial private sector, as well as academia, could be explored sectors with high potential for efficiency gain, such for such a center. Finally, the GoB could support the as brick production (see Box 2-1), raising awareness development of the private supply of RECP-related and lifting technical and financial obstacles to cleaner technologies and services. The DoE could consider production may go a long way toward bringing using a public and private dialogue platform such as the industries in line with environmental standards while Green Growth Working Group26 to better coordinate improving their productivity and competitiveness. efforts by different actors to promote RECP. Box 2-1: Combining Policy Changes and Technical Support to Industries for Cleaner Brick Production in Bangladesh Strong regulations can usefully be coupled with programs to support the adoption of cleaner technologies. In the brick sector, the DoE led both policy changes and a supporting program to help brick kiln operators become cleaner. The availability of cleaner brick-making technologies presents an opportunity in Bangladesh. Five different technologies are used in brick kilns in the country: fixed-chimney kilns (FCKs), Zigzag, Hybrid Hoffman kilns (HHKs), vertical shaft brick kilns (VSBKs), and tunnel kilns (World Bank 2011). Among these technologies, the traditional FCK is the least efficient and most polluting, while tunnel kilns are the most efficient and least polluting. Other technologies, such as improved Zigzags and HHKs, are substantially cleaner, consume less energy, and emit much lower amounts of pollutants, but are still being piloted in Bangladesh. Table 2-5 shows the clear benefits in terms of environmental and production efficiency by converting to cleaner technologies, although some technologies, such as Hoffmann and HHKs, require larger upfront investments. 25. A more in-depth analysis of opportunities and challenges to promote RECP among manufacturing SMEs in Bangladesh is carried out through an ongoing regional technical assistance implemented by the World Bank. 26. The Green Growth Working Group was recently established by Business Initiative Leading Development (BUILD) and cochaired by the private sector and the MoEFCC. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 34 TABLE - 2-5: COMPARISON OF DIFFERENT TECHNOLOGIES’ ECONOMIC AND ENVIRONMENTAL BENEFITS Kiln Type Number Fuel consumed Investment & Production PM reduction per 100,000 Operation costs capacity compared to bricks (million USD)a (million/kiln) FCK FCK 4,500 20-22t coal 1.7 4 Zigzag 150 16-20t coal 1.6 4 40% Hoffmann (gas) 20 15-17,000m3 NG 5.7 15 90% HHK 10 12-14t coal 5.7 15 60% Source: S. Guttikunda & M. Khaliquzzaman (2013) a) Costs include initial investment, land, building, operational, and taxes estimates (World Bank, 2011) The availability of profitable cleaner technologies was not sufficient on its own to convert many kilns, which also required a complementary mix of technical assistance, financial support, and regulations. In 2009, the majority of brick kilns in Bangladesh were highly polluting FCKs, and only a few percent were using Zigzag and Hoffman kilns with lower emissions. Key policy changes, including a government notification in September 2010 that banned FCKS, along with the Brick Manufacturing and Brick Kilns Establishment Act of 2013, which restricted locations and coal use, set the stage for a major technology shift. TABLE - 2-6: BRICK PRODUCTION USING DIFFERENT TECHNOLOGIES Type of 2009 2017 technology Number of % of total Annual % of total Number of % of total Annual % of total kilns product- product- kilns product- product- ion ion ion ion (billions) (billions) FCK 4,500 92.2 13.5 89.5 2,373 35.2 7.1 31.2 Zigzag 150 3.1 0.5 3.0 4,247 63.0 12.7 55.8 HHK 30 0.6 0.5 3.6 61 1.0 1.1 4.8 Tunnel 0 0.0 0.0 58 0.9 1.7 7.6 Others 200 4.1 0.6 4.0 5 0.1 0.2 0.7 Total 4,880 100 15.1 100 6,744 100 22.8 100 Source: DoE 2017. However, the brick kiln case has shown that technical assistance is critical to achieve the policy changes intended benefits. In most cases, quick conversions did not follow the standard design for improved Zigzag kilns developed by the DoE. The emission levels of these converted kilns are highly variable, and in some cases as bad as the FCKs. The World Bank-financed CASE project is contributing with standardized design and providing support to address technical challenges. Today, about 60 percent of brick kilns have now converted to a cleaner technology (traditional Zigzag). The CASE project was launched on the premise that the DoE could play an important role in supporting industries to retrofit their initially hastily converted kilns to effectively comply with the lower emission standard (i.e., PM 35 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh emission < 200 mg/m3). The following illustrates how different instruments worked as drivers to advance transition in the brick-making sector and how one instrument without complementary instruments is likely to result in far more limited outcomes. • RECP technologies identified (Zigzag, Hoffman Kilns, etc.) Limited Technologies Awareness • Cost-benefit analysis prepared and brick kiln owners made conversion aware Accelerated Regulation • Ban on obsolete technologies (fixed chimney kilns) conversion (60%) Capacity • Standardized designs provided Improved effects Building Accelerated conversion but Regulation • Financial support needed for technologies that require with more Financial higher capital costs Standards options of Mechanism & Monitoring • Revised standard and monitoring technologies – Ministry of Commerce With respect to imports, the MoC plays a role in restricting certain harmful substances and mandating The MoC has a mandate to promote better minimum environmental, health, and safety environmental management of export-oriented standards. The current Import Policy Order (2015– industries, and could do more in this regard. 18) includes relevant content in this regard. Imports/ This could include updating the export policy to exports to and from Bangladesh Economic Zones incorporate environmentally sustainable production (BEZs) and EPZs are generally outside the purview considerations, which are not included in the current of this policy. However, the policy does state that the policy. The MoC’s previous export policy (2012–15) had banned items listed in Annexure 1 of the policy order a clear focus on environmentally friendly technology cannot be imported, including to BEZs and EPZs. in its objectives, and mentioned that export-oriented Furthermore, it states that for other imported items institutions will be encouraged to obtain ISO 14000 into BEZs and EPZs, “rules & regulations related to certification (environmental management). This public health and environment must be observed previous policy also specifically mentioned taking strictly” (Section 15, clause 1). The policy also has steps to establish wastewater treatment plants in the specific conditions for potentially harmful substances. RMG industry and encouraged waste management For example, under Section 35 (Import of Waste and initiatives for the leather industry, especially for the new Scrap), Clause 37 specifies that importers of Break BSCIC facility in Savar, near Dhaka. In 2015, the MoC Acrylic need to notify the DoE immediately after issued a new export policy (2015–18) that prioritized import. Also, importers of ozone-depleting materials 12 sectors as having the “most potential” and labelled need permission from the DoE (Chapter 6, Clause 56). 14 other sectors as “special development.” However, The policy also refers to the 1995 ECA in relation to the new policy does not mention environmental, scrap vessels of the shipbreaking industry (Chapter 6, health, and safety requirements or good practices for Clause 39). any of these sectors. Measured average emission levels of seven improved Zigzag kilns designed and piloted in the CASE project is 71±36 mg/m3. So, more 27. than 99.9 percent of the kilns of this design should be able to meet the 200 mg/m3 standard. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 36 The MoC is well positioned to sponsor laws targeting their environmental management systems and invest specific chemicals that can harm the environment in RECP. These bodies include: or the public. One example where the Commerce Minister has stepped up in this regard was to i. The Bangladesh Chemical Industries Corporation propose the Formalin Control Act, which was passed (BCIC), which operates paper mills, urea factories, in 2015. The act regulates the import, production, tiles factories, etc.; transportation, storage, sale, and use of this ii. The Bangladesh Sugar and Food Industries preservative. The ministry has also prepared a draft Corporation (BFSIC), whose main activity is sugar law on classifying and treating industrial sludge, in production; collaboration with the MoEFCC. The MoC could take The Bangladesh Steel and Engineering iii. the lead on sponsoring and advocating for stronger Corporation (BSEC), which manufactures legislation on other hazardous substances. wires, pipes, cars (Pragoti), and motorcycles (in association with Honda) and manages dry – Ministry of Industry dockyards; and iv. The Bangladesh Small Cottage Industries The MoI has the potential take on a greater Corporation (BSCIC), established in 1957, which leadership role in environmental management facilitates the growth of medium, small, and and RECP through its core function of issuing and cottage industries through promotion and capacity overseeing industrial policy. A good example of building activities, including by administering 74 the MoI’s role in issuing a specific rule that directly industrial estates.29 addressed environmental aspects of a specific industry is the Ship Breaking and Recycling Rules (2011), – BEPZA which aim explicitly for “safe and environmentally sound ship recycling in Bangladesh.” The ministry The Bangladesh Export Processing Zones Authority also participates in various national committees (BEPZA) has made some efforts to improve its that broadly relate to environmental management, systems and capacity in environmental management. including the Climate Change, Climate Finance, and This is despite the Bangladesh Export Processing National Rivers Commission. However, with respect to Zones Authority Act of 1980 not having any specific other industries with major environmental footprints, environment-related clauses. In BEPZA’s investment the MoI has not been visible in incorporating proposal form for investors, proponents notably environmental concerns into industry-specific policies need to provide certain information related to the and rules. The ministry’s overarching Industry Policies composition of effluents and their proposal for in- of 2010 and 2016, which aim to promote industrial house treatment; arrangements for disposing of any development in Bangladesh, could also have more dangerous or injurious chemicals; and arrangements explicitly referenced environmental sustainability for environmental controls (BEPZA 2013). However, standards and encouraged clean production practices in BEPZA’s 2013 Information for Investors booklet, in industries. there is no specific guidance on conducting an EIA for the proposed industry or mention of any The MoI has a number of ways to promote and requirements for obtaining environmental clearance oversee environmental management of industries. from the DoE. Adding such guidance would help to While the MoI in Bangladesh has little control over further mainstream environmental considerations private industries, it could aim to provide support into BEPZA’s operations. for RECP by making this a more prominent focus of its National Productivity Organization.28 On the At the zone level, BEPZA could do more to ensure other hand, the MoI oversees a number of industrial each of its zones are properly sited, designed, and corporations and could encourage them to strengthen managed from an environmental, health, and safety For more information, see the National Productivity Organization’s website at http://www.npo.gov.bd. 28. Nine more industrial estates are being developed and 11 more are proposed. For more details, see the BSCIC website at http://www. 29. bscic.gov.bd. 37 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh perspective. A template for zone-level planning the Dhaka EPZ is a further positive step. It should be and management exists through the Environmental evaluated and updated periodically, integrated with Management Framework (EMF) that BEPZA the monitoring database, and be publicly accessible developed for the World Bank-financed Private through an online monitoring portal, which should Sector Development Support Project (PSDSP) in be set up by the DoE (see Section 2.2) and scaled up 2010 and then updated in 2015. The project assists across all EPZs. in the development of EZs and EPZs in accordance with “international practices of building safety, In addition to environmental compliance, BEPZA environmental and social safeguards” (Rosario 2015). could aim to promote RECP in the zones it manages. The project also supports private investments in This could include both support at firm-level and building central effluent treatment plants (CETPs) zone-level programs to foster cleaner production in existing zones. The EMF, which only applies to and “industrial symbiosis.” In doing so, it could draw the Bank-financed project, provides an outline of the on the international experience with eco-industrial necessary procedures for minimizing environmental parks.30 and social impacts of the project components and subcomponents. The EMF aims to fill the gap between – BEZA the government’s environmental regulations related to EPZs and the World Bank’s own safeguard policies. Unlike BEPZA, environmental management is built A review of the project’s experience with applying the into the legal framework of the Bangladesh Economic EMF—with the aim of refining and updating it based Zone Authority (BEZA). First, Clause 33 of the 2010 on lessons learned so it can be adopted across all of BEZA Act requires “the Authority, economic zone BEPZA’s operations—would be a useful exercise. For developers, industrial units established in economic example, one area in which further procedures and zones, financial and business institutions…to comply guidelines would be important relates to planning new with international commitments recognized by the zones. Neither the 1997 ECR nor the proposed 2017 Government of Bangladesh including compliance to ECR revision includes a requirement for zone-level all existing laws on environment and environmental environmental clearance. Nonetheless, when new zones protection.” Second, as per the 2010 BEZA Act, the are being planned, comprehensive environmental Minister and Secretary of the MoEFCC are members assessments (EAs) should be undertaken to ensure of the BEZA governing board. that nearby environmentally and socially sensitive receptors, environmental vulnerabilities, cumulative In spite of this, BEZA’s permanent capacity to impacts of the zone, and other developments in that deliver on its environmental responsibilities is not area on the natural resource base (land, air, and water, firmly established. Currently, BEZA has 72 staff and and biodiversity) are taken into account. the government recently approved an organogram with an additional 158 staff (BEZA 2016). Under one BEPZA has made important inroads in building its donor-financed project to build BEZA’s capacity, there internal staff and systems capacity on environmental is a dedicated environmental specialist staff. However, management, which should be continued and further there was no information available about positions with scaled up. In 2015, 38 BEPZA officials underwent a environmental management-related roles in the new three-month training program on environmental organogram. Environmental monitoring systems are management of EPZs organized by BEPZA and also needed at the zone level, for all zones, to enable the Military Institute of Science & Technology the identification of non-compliances by individual (MIST). Also, BEPZA recently requested the Asian industries within the zone, as well as to ensure that Development Bank’s (ADB) cooperation in setting common facilities, such as CETPs or common waste up CETPs in EPZs (BEPZA 2017). A reported online disposal facilities, are keeping the zone as a whole in environmental monitoring system recently initiated at line with relevant environmental quality standards. See, for instance, the joint international framework for eco-industrial parks published by the World Bank, UNIDO, and GIZ in 2017 30. (https://openknowledge.worldbank.org/handle/10986/29110). Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 38 As mentioned in the previous section, BEZA should environmental taxes, including a carbon tax, to adopt guidelines and procedures to ensure that disincentivize pollution and wasting resources. new economic zones are planned to incorporate comprehensive EAs. These assessments would need The Bangladesh Bank, the country’s central bank, to take into account proximity of nearby zones, has played a pioneering role among developing proximity of environmentally or socially sensitive countries to drive green finance through policies receptors, potential environmental vulnerabilities, and regulations over the last decade. It was the first as well as other existing and potential developments central bank in the world to issue a Green Banking in the area. For example, there are numerous zones Policy. In 2011, it published an Environmental Risk existing and proposed within the Greater Dhaka Management Guidelines for Financial Institutions in region that can have considerable cumulative impacts. Bangladesh (BB 2011), followed in 2015 by Guidelines Like BEPZA, BEZA could also aim to foster cleaner on Environmental and Social Risk Management production in the zones to be established. Synergies (ESRM) for Banks and Financial Institutions (BB between industries could, for instance, be taken into 2015). These efforts aimed to improve environmental account when selecting tenants. management capacity in the financial sector, which supports the country’s industrial growth. Despite this, – Ministry of Finance volumes of green finance remain limited so far (UK Aid 2017). The MoF can play a key role in fostering green growth through fiscal policy, as well as facilitating Building on results achieved to date from several access to finance for green investments. On both refinancing/on-lending schemes,31 there is scope for fronts, MoF agencies, including the National Board the BB to accelerate the growth of green lending. of Revenue (NBR) and Bangladesh Bank (BB), have Several of the above-mentioned schemes have faced some initiatives in place, which should be developed slow disbursements for various reasons, such as and scaled up to impact the rapid pace of industrial implementation difficulties, lack of capacity among development. partner financial institutions, and lack of awareness/ interest among potential borrowers. There is an The NBR is the country’s apex body for tax opportunity to take stock of progress to date on green administration. Recently, NBR announced income finance and identify remaining obstacles on both the tax concessions for garments exporters with supply and demand sides. internationally recognized Green Building Certificates (Independent 2017). This is part of the government’s – The private sector effort to promote pollution-free industrialization as well as a low-carbon economy. The 2016 draft national The private sector is critical for scaling up cleaner industrial policy includes some provisions for fiscal production. The government should actively engage incentives, where responsibility for acting upon the with the private sector to ensure that opportunities policy is entrusted to the Tariff Commission and NBR. and obstacles for RECP in different sectors are well Specifically, Section 4.19 outlines “special incentive/ understood, to obtain feedback on public interventions assistance for promoting green and environment on pollution control, and to promote cleaner friendly power system based on renewable energy.” production. Public-private dialogue (PPD) is key here The government could also consider using more to identify, design, and monitor needed reforms. The These schemes, implemented through partnering financial institutions, have included the Refinance Scheme for Renewable Energy 31. and Environmentally Friendly Financeable Sectors launched in 2009 (BDT 2.5 billion disbursed over FY13–17, half of which was for effluent treatment plants); the ADB-supported Financing Brick Kiln Efficiency Improvement Project launched in 2012 (US$50 million, of which 16.2 million disbursed as of mid-2017); and the Green Transformation Fund for Export Oriented Textile and Leather Sectors announced in 2016 (US$200 million). In addition to this, a US$100 million JICA-financed Energy Efficiency and Conservation Promotion Financing Project was implemented in 2016 by the Sustainable and Renewable Energy Development Authority (SREDA) to finance investments in energy efficiency equipment, including in industries, through financial intermediaries. More recently, the World Bank–financed Sustainable Enterprise Project was designed for scaling up cleaner production among microenterprises through microfinance institutions. 39 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Green Growth Working Group recently established by on building and worker safety, this renewed attention the Business Initiative Leading Development (BUILD) can also be used to push environmental sustainability. and co-chaired by the private sector and the MoEFCC Regarding supply chains, leading international brands is a valuable initiative that ought to be developed in the textile and apparel industry have since 2014 been with a strong mandate to foster RECP.32 Specific PPD closely involved with the successful PaCT program platforms for priority industries could be established financed by the International Finance Corporation as needed, with relevant public actors and industry (IFC) (see Box 2-2). In 2016, PaCT notably embarked associations. The Textile Sustainability Platform (TSP), on a partnership with Levi Strauss & Co to promote its established in 2016 under the Partnership for Cleaner suppliers’ environmental and social compliance and Textile (PaCT) as a PPD platform to promote efficient cleaner production in the Bangladeshi textile industry resource use in the sector, is a good example. (Levi Strauss & Co. 2016). Beyond export-oriented sectors, firms that produce for the domestic market Companies can play a major role through corporate could also be encouraged to develop their green CSR social responsibility (CSR) and supply chain and sustainable supply chain initiatives. India is an initiatives. Multinational corporations operating in interesting example of rapidly growing CSR in the Bangladesh have been under increased domestic and domestic private sector, which has been mandated by international pressure to commit to CSR following the a specific legal provision since 2014. This has led to an 2013 Rana Plaza collapse. While this has partly focused increase in CSR expenditure, amounting to around Box 2-2: The Partnership for Cleaner Textile (PaCT) PaCT started in 2014 (phase 2 was launched in October 2017) to promote the textile wet processing sector’s long-term competitiveness and environmental sustainability through the adoption of best practices for RECP. Implemented by the IFC, PaCT works with global apparel brands, the Bangladesh Garment Manufacturers and Exporters Association (BGMEA), and over 200 export-oriented textile factories. Its four pillars are: i. Brands. Reduce supply chain risks by working with leading global brands to integrate environmentally sustainable practices in design and sourcing decisions. ii. Factories. Support the adoption of best practices in textile factories by raising awareness, conducting diagnostics, and supporting implementation. This involves undertaking both (i) basic cleaner production assessments on how a factory can incorporate cleaner processes and adopt low- or no- cost measures to reduce its water footprint; and (ii) deep dives for a smaller number of factories to undertake full engineering assessments that take into account dyeing, finishing, laundry processes, and utilities. It helps factories to significantly reduce water, wastewater, sludge, and their carbon footprint, and to improve their environmental performance and production efficiency. iii. Sector. Address sector transformation and regulatory policy gaps (e.g., recommendations to the MoEFCC regarding what penalties to institute for the use and discharge of chemical pollutants). iv. Investment facilitation. Matchmaking between banks, textile factories, and technology suppliers, and build capacity for identifying and assessing bankable projects. Business Initiative Leading Development (BUILD) was established in 2011 as a joint initiative for PPD on private sector development 32. of the Dhaka Chamber of Commerce and Industry (DCCI), in partnership with the Metropolitan Chamber of Commerce and Industry (MCCI) and the SME Foundation (SMEF). Several thematic working groups are cochaired by a private sector leader and senior official from a relevant ministry. BUILD is a primary source of recommendations for meetings of the Private Sector Development Policy Coordination Committee (PSDPCC), a high-level forum established at the Prime Minister’s Office (PMO) and chaired by the Principal Secretary to the Prime Minister (http://www.buildbd.org). Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 40 PaCT activities to date have included: • Cluster-level work: GIS mapping, water consumption and pollution footprint assessments, developing centralized solutions, addressing WASH issues for local communities, etc. • Financial mechanisms: Helped BB establish the Green Transformation Fund to finance RECP in the textile and leather sectors. • Information: The IFC and BGMEA jointly established a technical knowledge hub, the Textile Technology Business Center (TTBC), to improve access to information on best practices, resource- efficient technologies, financing options, and technology suppliers, making matches between service providers and industries. • Tools: Developed a resource management diagnostic tool for continuous improvement in factories (PaCT Advantage). • Public-private dialogue: Launched the national TSP with BUILD, extending research, technical, and secretarial support. • Knowledge: Publishes reports and case studies of factories’ successful experiences with different aspects of RECP, etc. The program has achieved major impact so far, in terms of water savings (21.6 billion liter/year), energy savings (2.5 million MWh/year), GHG emissions avoided (460,000 tCO2e/year), wastewater avoided (18l.8 billion liter/year), investments (US$39 million) and factory savings (US$16.3 million/year). Source: PaCT, http://www.textilepact.net. US$1 billion in 2017 for the top 100 listed Indian enforcement are essential, such efforts would become companies, 11 percent of which were dedicated to too costly and unsustainable without the cooperation environmental causes (KPMG 2018). of other ministries and agencies, as well as the private sector. Coordination among ministries and agencies Finally, a concerted effort by several ministries and would help harmonize the policies to promote better agencies, private sector, and civil society is required environmental performance. A better coordinated to reverse trends of environmental degradation and mechanism to incentivize the private sector is needed shift the country toward a green development path. to scale up cleaner production, and PPD plays a critical While the DoE’s continuous efforts to strengthen role. 41 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh CHAPTER 3. TOWARD CLEANER AND MORE RESILIENT CITIES IN BANGLADESH This chapter analyzes environmental management The city has a high potential to continue to grow at the city level. While national-level institutions are rapidly as a tourism city. responsible for most aspects of environmental policy, • Pabna—a small but growing municipality planning, enforcement, and incentives (see Chapter 2), surrounded by wetlands that are threatened with some roles and responsibilities have been decentralized encroachment and pollution due to the shift from to city-level institutions on various aspects of land use, traditional agriculture to unplanned infrastructural natural resource and industrial planning, zoning and development. management, as well as provision of municipal services like solid waste and wastewater management—all of which significantly influence urban sustainability and 3.1 UNDERSTANDING climate resilience. ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES AT THE CITY A case study approach was adopted to examine LEVEL the city-level institutional complexity on these issues, and to spatially analyze outcomes on the Before delving into the specific selected cities, particularly critical issue of wetlands encroachment it is important to note the variety of governance and degradation. Through consultations with various arrangements that affect urban planning and stakeholders, five cities were selected that span across environmental management across Bangladesh, with different sizes, governance structures, development varying degrees of institutional complexity. Certain patterns, and multidimensional sustainability powers are devolved from the national institutions to challenges: local government authorities—e.g., City Corporation, upazila, or Union Parishad governments—but in • Dhaka—a megacity with a complex institutional the cases of the country’s five largest cities (Dhaka, setting and immense environmental challenges. Chittagong, Khulna, Rajshahi, and Cox’s Bazar), an • Narsingdi-Madhabdi—these two municipalities additional layer of urban governance resides with the (Paurashavas) of moderate size, only 11 km apart, urban development authorities, which fall under the present contrasting industrialization growth Ministry of Housing and Public Works (MoHPW). patterns. RAJUK (Dhaka’s urban development authority) is • Mymensingh—a historical town with hardly any the oldest and largest in terms of jurisdiction area, large industries, but likely to undergo changes as it manpower, revenue, and expenses. The mandate of has recently become a Divisional Headquarters and these institutions is to develop, monitor, and enforce a City Corporation. the structure plans, master plans, and detailed area • Cox’s Bazar—a medium-sized coastal municipality plans of their respective cities. They also play an facing various pressures on its natural resources. important role in regulating urban developments, Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 42 such as by issuing building development permits in institutions with varying capacity and authority, and accordance with their plans and rules. sometimes to the Union Parishads, which typically lack capacity to effectively enforce the plans. Only when The mandates of local government authorities, an area is 70–80 percent built up (often after many national institutions, and urban development low-lying areas and wetlands have been filled up in an authorities sometimes overlap at the city level. ad hoc manner), does the Local Government Division The jurisdiction of urban development authorities, give it the status of Paurashava/City Corporation.33 At where they exist, can cover more than one City that point, only the remaining 20–30 percent of land Corporation, municipality, and Union Parishad, designated to that urban area is available for planned which creates multiple layers of urban planning and development/urbanization, thus setting cities up to development. Some of their activities most relevant face difficult trade-offs in stimulating and allowing for to wetlands management—such as land acquisition, growth while also meeting environmental objectives filling and preparing land for housing and mixed-use under the NBSAP. As cities continue to grow and come projects, the construction of roads (including flyovers under the management of an urban development and bridges), etc.—are also carried out by City authority, the institutional complexity increases Corporations, municipalities, and Local Government across urban planning and implementation roles and Engineering Departments (LGEDs). City Corporations responsibilities, without consolidated accountability are meanwhile tasked with providing basic municipal and clear ownership over the multidimensional services; ensuring public health; removing, collecting challenges of natural resource and environmental and managing garbage; supplying water; maintaining management. Table 3-1 illustrates this complexity and managing drainage and water bodies; building for the case study cities, which span different types of and maintaining road networks; ensuring public city governance structures. Details for each city are safety; managing disasters; and managing open spaces analyzed in the subsequent section of this chapter. and parks (City Corporation Act 2009). In almost all cases, their planning role is further duplicated by the Urban Development Directorate (UDD) of the 3.2 URBAN ENVIRONMENTAL MoHPW. UDD has developed Master Plans for several MANAGEMENT EXPERIENCES IN Divisional Headquarters (Rangpur, Sylhet, Barisal, CASE STUDY CITIES and Mymensingh), as well as for other urban towns and cities. 3.2.1 Dhaka—The Mega City As the case studies show, this multi-layered urban Dhaka, the capital city of Bangladesh, is ranked institutional arrangement in practice contributes to as the ninth largest megacity in the world (Ahmed suboptimal management and protection of natural 2015). After independence in 1971, Dhaka underwent resources and the ecosystem services they provide in rapid growth along social, economic, political, and and around cities—particularly wetlands. The “wise institutional dimensions. Over the last 25 years, Dhaka use of wetlands” strategy under the 2014 update of City’s population increased by about threefold, from the National Biodiversity Strategy and Action Plan 6.8 million in 1991 to 18.2 million in 2016 (Siddiqui (NBSAP) was a sound regulatory initiative. However, et al. 2010; UN 2016). Today, the DMA covers 360 sq. it has been poorly implemented by cities of all sizes km, although the 2010 DAP covers a broader area of due to lack of clear mandates and accountability for 590 sq. km. This case study considers the DAP as the master planning. In small towns, urban plans tend basis of the analysis. to be developed by Paurashavas, municipalities, or LGEDs; in the case of Cox’s Bazar, it is the UDD. Dhaka is the country’s economic powerhouse, but Meanwhile, implementation is left to multiple is also beset with urbanization and environmental According to Section 3 of the Paurashava Act (2009), a rural area can be declared a “city area” if 75 percent of the people are involved in 33. nonagricultural professions, 33 percent of the land is of a nonagriculture type, population density is not less than 1,500 people/sq. km, and the total population will not be less than 50,000 people. Also, “no objection” needs to be provided by the relevant Union Parishad. If objection is raised, the government will need to resolve the issue within three months (MoEFCC 2011, Section 3). 43 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh TABLE - 3-1: INSTITUTIONAL MAPPING FOR ENVIRONMENTAL MANAGEMENT IN FIVE CITIES Urban planning (land Other urban services Traffic and transport Wetlands and urban Urban development Water & wastewater Urban drainage use and zoning) monitoring and Environmental Regulation of Air pollution Organization management management management management enforcement biodiversity Solid waste industriesb control system DoE Dh, Dh, Dh, Dh, CXB, CXB, CXB, CXB, MNP MNP MNP MNP Urban Dh Dh Dh Dh Dh Dh Dh Development Authority City Dha Dha Dh Dh Dh Dh Dh Dh Dh Corporation DWASA Dh Dh Dh Dh Dh Other utilities Dh, Dh, (e.g., power CXB, CXB, development MNP MNP board, Titas) LGED MNP Dh, CXB, MNP RHD Dh, CXB, MNP MoL MNP MNP Dh, Dh, CXB, CXB, MNP MNP Deputy MNP MNP CXB, Commissioner MNP BWDB Dh Dh, MNP Police Dh, CXB BFD CXB CXB Paurashava CXB, MNP CXB, CXB, CXB, CXB, CXB, CXB, CXB, MNP MNP MNP MNP MNP MNP MNP MNP DPHE CXB MNP UDD, Cox’s CXB CXB CXB CXB Bazar DoF Dh, MNP Notes: a. The City Corporations are involved in the planning process and have a Chief Town Planner position. They also have a role in development control through the 2009 City Corporations Act. Also, by varying the holding tax rates, they can indirectly influence urban development control in urban areas. b. National-level institutions also play a role, such as the MoI, MoC, etc. c. Dh: Dhaka; CXB: Cox’s Bazar; MNP: Mymensingh, Madhabdi and Narsingdi, Pabna. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 44 challenges that increasingly threaten inhabitants’ identified, mapped, and recommended protection for quality of life, productivity, and health. In particular, 30,252 ha of FFZs and 2,240 ha of WRAs to reduce city residents live with increasingly polluted air and the risk of flooding in Dhaka City. However, a field waterways. Dhaka’s environmental degradation is investigation carried out in November 2017 for a influenced by a variety of factors, including institutional background paper to this CEA revealed that, in just coordination issues, overlapping mandates, capacity eight years (2010–17), 41 percent of FFZs and 21 constraints, and lack of awareness among the public, percent of WRAs have been converted, raised, and government officials, and entrepreneurs. However, used for other purposes, including settlements and to there are cases in which long-standing environmental establish industries and brick kilns (see Table 3-2 and problems have been addressed through strong Figure 3-1). leadership and coordination efforts, such as the iconic Hatir Jheel Project (for restoring the wetlands), and TABLE - 3-2: CHANGE IN DAP- the relocation of tanneries. DESIGNATED FFZS AND WRAS, 2010–17 Numerous institutions are responsible for various aspects of planning, developing, and managing Land use DAP- Present Area Change greater Dhaka City’s urban development. With respect designated area, lost (ha) (%) to wetlands and waterways in and around Dhaka, these area, 2010 2017 institutions include RAJUK, DWASA, DCC (north and (ha) (ha) south), the Bangladesh Water Development Board FFZ 30,252 17,851 12,401 -41.0 (BWDB), the DoE, the Department of Fisheries (DoF), the Bangladesh Inland Water Transport Authority WRA 2,240 1,779 461 -21.0 (BIWTA), the Cantonment Board, the Ministry of Total 32,492 19,180 13,312 -41.0 Land (MoL), district administrations, and adjacent municipalities. These institutions have distinct roles Fieldwork and analysis revealed that infilling for and responsibilities and often perform their activities settlements and urban areas is responsible for 73 independently of each other. However, they also percent of FFZ and WRA conversions in both western have some areas of overlapping mandate or where and eastern sides of the city. Sand filling for housing better coordination is needed to address entrenched caused over 18 percent of FFZ loss, while just over 8 environmental challenges. percent was lost to raising land for the establishment of brick kilns. Similarly, WRAs are primarily converted to – Major environmental issues in Dhaka due to unplanned privately owned housing areas (87 percent), followed urbanization by urban areas/settlements (11 percent) and brick kilns (1 percent). It is noted that brick kilns are only Sustained unplanned urbanization, the infilling and found within the WRAs located in the eastern part of delinking of perennial wetlands and rivers, and the the DAP. Sand filling is also rampant on the eastern shrinking of many link canals across Dhaka has side, where 93 percent of the total retention area has exacerbated urban flooding and contributed to various been converted due to sand filling. Field investigation recurring environmental problems. Flooded roads and satellite map analysis of the relevant areas have contribute to traffic congestion and health hazards revealed that real estate companies, industry owners, from the spread of vector borne diseases. The polluted and brick kiln owners/operators filled up these low- state of rivers around Dhaka City further reduces their lying areas. An image analysis found that the city is ability to provide important ecosystem benefits. expanding into low-lying flood-prone areas that correspond to the FFZs and WRAs, and these areas The loss of FFZs34 and WRAs35 across the city are now experiencing increased localized flooding. in recent years is particularly striking. The DAP Aside from the infilling of FFZs and WRAs, a recent FFZs were defined by RAJUK in the DAP as areas typically inundated during flood events and/or inundated for a specific season. 34. WRAs were defined by RAJUK in the DAP as ponds that hold floodwater or excess/runoff water from heavy rains for an indefinite 35. period. 45 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh study (Chowdhury, Bhuyain, and Kabir 2015) The result is that huge parts of Dhaka are frequently revealed encroachment of more than 100 ha into the inundated following even a very small amount of four rivers around Dhaka City, including 39.34 ha of rainfall. Figure 3-2 shows a simulation of potential Buriganga, 49 ha of Turag, 3.6 ha of Balu, and 9.64 inundation from a 233 mm rainfall event (based on ha of Shitalakkhya. The change in land use pattern is an actual such event on October 22, 2017), under presented in Figure 3-1. a scenario of complete drainage system saturation or blockage. The analysis shows that such an event TABLE - 3-3: POTENTIAL INUNDATION could translate to potential inundation of 94,024 ha UNDER DIFFERENT within the DAP, including 44,869 ha of built-up areas. RAINFALL SCENARIOS Detailed simulations and analysis of potential flooded WITHIN THE DAP AND areas under three different rainfall scenarios, and of BUILT-UP AREAS the corresponding inundation extents both for the DAP area as a whole and for built-up areas within the Scenario Water level Total Potential DAP, indicate that under high rainfall conditions— considered potential inundation which are increasingly likely with climate change— inundated of built-up Dhaka City faces severe drainage congestion and area (ha) areas (ha) consequent flooding. The findings are presented in Table 3-3 and Figure 3-2. 1 4 m (158 mm 63,365 21,287 rainfall) A related problem stemming from in-filling and 2 5 m (210 mm 81,816 32,411 rapid urban development is the loss of groundwater rainfall) recharge areas. Data suggest that groundwater 3 6 m (256 mm 103,096 49,377 depletion is acute in Dhaka City. In 1990, the depth rainfall) of the water table was 15 m in central Dhaka and FIGURE - 3-1: CHANGES TO FFZS AND WRAS, 2010 (LEFT) TO 2017 (RIGHT) Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 46 FIGURE - 3-2: POTENTIAL INUNDATED of groundwater shortage is currently acute in the dry AREA UNDER 233 MM season, and it is likely that this problem would be RAINFALL WITHIN DAP aggravated in the future should there be further losses AREAS of wetlands and pervious surfaces. As yet another effect of the in-filling of wetlands in Dhaka, high-rise buildings built on sand-filled, low-lying areas are more susceptible to liquefaction effects during earthquakes. A study conducted in four sites in Dhaka City (Islam et al. 2010) revealed that liquefaction depth from existing ground level varies between 1.5–13.5 m, 1.5–4.5 m, 1.5–6.0 m, and 1.5–4.5 m for Bashundhara, Mirpur DOHS, Banasree, and Purbachal sites, respectively. Since the liquefaction depth is shallow, making the foundation deeper may overcome problems, but may also damage roads and other facilities (Islam et al. 2010). – A way forward for reduced waterlogging and flooding To counter these challenges, Dhaka can and must do far more to prevent encroachment, as well as invest in and sustainably manage the city’s wetlands and canals for maximum urban benefit. As outlined below, this requires a range of investments as well as institutional actions to restore and deepen canals, address solid waste management problems, and enforce master plans to prevent future encroachment. The effects of restoring a specific canal on inundation levels under different scenarios were assessed based on 4 m in peri-urban areas (Abedin and Rakib 2013). GIS analysis. The Ramchandrapur Canal is currently The pervious layer is important to effectively recharge 2,786 m long and covers an area of 3.06 ha, with its groundwater. With the increased paved area, a width 9–18 m at different points and its depth varying substantial area of suitable pervious layer has been from 1.2–2 m (see Figure 3-3)36. Due to encroachment, lost, reducing the potential to recharge groundwater; reduction of size, and waste dumping, the canal’s this exhausts aquifer levels and has adverse effects on water passage capacity was reduced and has become the availability of drinking water for urban residents. inadequate for draining the storm water from its The Earth’s surface is made impervious from catchment. As a result, every year following monsoon manmade construction features that considerably rainfall, land adjacent to the canal gets inundated reduce infiltration and groundwater recharge, and remains so for 1–3 days on an average, while the increase storm runoff by reducing runoff “lagtime,” low-lying Balur Math is waterlogged for around 12 and put increased pressure on drainage canals. It days. The different scenarios analyzed suggest that is noted that the DWASA relies on groundwater to widening and deepening the canal could significantly supply drinking water to the residents of Dhaka City; reduce flooding in adjacent areas compared to the thus, loss of the pervious layer combined with the loss baseline, by up to 39 percent with a 4 m widening plus of wetlands would affect water availability. The effect a 1.5 m deepening. For this assessment, a 1,480 m long section of the canal was considered. This section starts from Kallyanpur Point to 1,480 m upstream 36. (to Nobodoya Housing Point). An adjacent area of this section has low-cost housing, and the settlers are making roads along the canal by dumping wastes; these areas of the canal have the potential to be widened and deepened. 47 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - 3-3: RAMCHANDRAPUR CANAL FIGURE - 3-4: DURATION OF FLOODING (HOURS) IN BASELINE AND UNDER DIFFERENT RESTORATION SCENARIOS 34 17 7 3 2 Scenario: 1 Scenario: 2 Scenario: 3 Scenario: 4 Scenario: 5 (Baseline (4m (4m widening (4m widening (4m widening Condition) widening) plus 0.5 mm plus 1.0 m plus 1.5 m deepening) deepening) deepening) In addition to reducing the spatial extents of flooding, restoring the Ramchandrapur Canal in particular would also reduce the temporal extent of flooding. Figure 3-4 shows that under the baseline condition, adjacent areas of the canal, on average, remain inundated/waterlogged over a period of 34 hours following heavy rainfall. This time could be significantly reduced under the different restoration scenarios. TABLE - 3-4: SCENARIO ANALYSIS FOR The restoration scenario analysis suggests that FLOOD REDUCTION AT wherever feasible, existing canals should be widened RAMCHANDRAPUR CANAL and deepened to reduce problems associated with drainage congestion and flooding during monsoon Scenario Adjacent area Proportion rainfall. This would also require measures to restore flooded (ha) of baseline the areas of canals that have been encroached (%) upon, with due considerations of both social and 1) Baseline condition 15.11 100 environmental impacts. 2) 4 m widening of the 14.79 98 canal 3.2.2 Cox’s Bazar—A Tourist Coastal City 3) 4 m widening plus 12.84 85 Bangladesh’s favorite tourism city, Cox’s Bazar, has 0.5 m deepening seen one of the country’s fastest rates of population 4) 4 m widening plus 10.91 72 growth in recent years, fueled primarily by growth in 1 m deepening both domestic and international tourism and related industries (Rahman 2010; Seddique et al. 2013; 5) 4 m widening plus 9.29 61 Hossain and Mallik 2017). Cox’s Bazar Municipality 1.5 m deepening is a southeastern coastal town located on the Bay of Bengal. The urban area covers 2,081 ha (20.8 sq. km), and hosts a population of 167,477 (UDD 2011). Cox’s Bazar’s natural beauty is its primary draw for tourists: It has the world’s longest stretch of sandy beach (120 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 48 FIGURE - 3-5: LAND USE MAP IN COX’S BAZAR, 1988/2004/2017 km) in the west and has hilly terrain covered with The urban development driven by the growth in forests in the east (UDD 2011; Sayeda 2017). At the tourism has come at a high cost to the municipality’s time of this writing, the World Bank is currently natural resources over the last 30 years. The tourism conducting a vulnerability assessment that will address sector constitutes a major share of Cox’s Bazar’s the impact of refugee settlement on Cox’s Bazar’s economy. There are over 220 hotels, motels, and guest environment. There are a few medium-to-large ponds houses, over 154 restaurants, and 54 tour operators within the municipality; of these, Lal Dighi, Gol Dighi, that together employ around 8,600 people (Mamun, and Bazar Ghata Dighi are notable and managed by Hasan, and Hossain 2013). In addition, around 5,000 the municipality authority. These are leased to private people serve as construction workers to build new parties to cultivate fish, and are thus a source of hotels and other facilities, while thousands of others revenue for the municipality. In addition, there are are engaged in informal sectors that support tourism. some manmade institutional ponds within the town, A primary field study carried out for this CEA found such as two ponds on the campus of Hotel Shaibal that seasonal wetlands/low-lying areas were reduced and Motel Upal, that are managed by the Bangladesh by 87 percent from 1989 to 2017. In the same time Parjathan Corporation (BPC), and three ponds period, the study found that sand bar areas have within the cricket stadium. There are about 40 small been reduced by 61 percent, forested areas by 57 ponds within the campus of the Bangladesh Fisheries percent, hill areas under vegetation by 69 percent, Research Institute (BFRI). Nonetheless, many of and tidal wetlands by 44 percent, in a manner highly these natural assets are threatened by unplanned correlated with human-induced land conversion and urbanization. The recent influx of refugees and relief urbanization. Meanwhile, settlements and urban agencies has put further pressure on the natural areas were found to have significantly increased—an resources in and around the town. approximately 235 percent increase that now covers a more than 584 ha built-up area without vegetation. – Environmental issues due to unplanned development Figure 3-5 shows the chronological changes of land and deforestation use in Cox’s Bazar. 49 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh These recent and ongoing urban development – A way forward: Mangroves in Cox’s Bazar and the trends are coming at the expense of the services potential for ecotourism and benefits that the city’s natural ecosystems (forests, mangroves, and wetlands) provide toward In charting a path for Cox’s Bazar to become a urban resilience. Loss and degradation of forests sustainable tourism hotspot, the recent efforts has increased landslide risk, reduced water retention and investments to restore and protect mangroves capacity, increased siltation, and choked up drainage provide a positive example for potential initiatives to canals (including the Bakkhali River). Over the last 10 protect and restore wetlands and forests. Historically, years, around 150 people have died in landslides in mangroves used to grow in intertidal mudflats at Cox’s Bazar town and adjacent areas, and thousands different char areas of Cox’s Bazar districts, and were of others are at risk (Aziz 2017). Unplanned common in Chokoria, Moheshkhali, and Teknaf, infrastructural development has reduced water including in some areas along the Bakkhali River and bodies/wetlands, and eventually the shrinking surface adjacent areas. Mangroves used to support productive water availability will have serious implications. The multispecies fisheries in the Bakkhali estuary (Hena waterlogging of built-up areas within the town not et al. 2007; Rahman et al. 2015). However, due to only affects land productivity, but also poses health anthropogenic disturbances (felling, boating, fishing, risks to locals and tourists from water pollution encroachment, and conversions for aquaculture) and mosquito breeding. Health risks are further mangroves became unable to grow in these areas. compounded when solid wastes are dumped on water- Seddique et al. (2013) reported that no mangrove was logged lands (Rahman, Hashi, and Habib 2014). The traceable in 1989 within Cox’s Bazar Municipality. municipality’s waste disposal system is inadequate, From 2007–10, the DoE started planting and protecting with organic and hazardous wastes deposited in open, mangrove forests in 60.91 ha in Nuniar Chara along poorly controlled dumping sites. During heavy rains, the Bakkhali River adjacent to the Cox’s Bazar airport. wastes are carried downstream to the Moheshkhali The DoE continued to protect mangroves at Nuniar Channel (Bay of Bengal) through the Bakkhali River, Chara and extended mangrove restoration in adjacent negatively affecting the coastal environment, fisheries, areas through projects known as Community-Based and aquatic biodiversity (including mangroves) at the Ecologically Critical Area Management (CBAECAM). intertidal zones at the mouth of the Bakkhali River. This occurred in two terms, from 2011–15 and 2016– 17, with additional funding from the Embassy of the Additionally, lack of surface water availability Kingdom of the Netherlands (EKN) and the Climate causes excessive extraction of groundwater, which Change Trust Fund (CCTF), with technical assistance exacerbates the salinity intrusion. In coastal cities, from the United Nations Development Programme wetlands play a crucial role in recharging groundwater, (UNDP). The DoE also constructed a community and as such, help to maintain aquifers and prevent salt center and watch tower to facilitate increased water intrusion. Based on data from shallow tube wells community engagement and encourage ecotourism. (<50 m in depth), Seddique et al. (2013) located a zone Locals also mentioned the presence of mangroves of higher electrical conductivity (EC) values (>200μS/ along the Bakkhali River, dominated by two species of cm with a maximum of 2200μS/cm) in the western and Bain (Avicennia spp.). DoE officials said that without northern parts of town (Laboni, Suganda, Kalatoli, community management, mangroves could not be Jauitola, Nuniar Chara, and Khurushkul) and some protected from anthropogenic disturbances. isolated parts at the center of town, which indicates the presence of salt water in aquifers. The data also This example of successful mangrove plantation show that salinity moves toward the land. Higher EC demonstrates the importance of engaging the local values were also recorded in deeper wells (a maximum community for eco-tourism promotion in Cox’s Bazar. of 7070μS/cm), indicating that excessive abstraction The forest is being managed by local communities of groundwater is likely the main cause of the saline organized into village conservation groups (VCGs) water intrusion in Cox’s Bazar (Seddique et al. 2013). under various DoE projects that took place from Through the UNDP-supported Coastal and Wetland Biodiversity Management Project (CWBMP). 37. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 50 2007–17. To this end, the DoE supported the VCGs by city-level actors responsible for implementing and providing two boats for ecotourism. The mangroves enforcing urban plans. In Cox’s Bazar, this includes in Nuniar Chara are being colonized by fish, crabs, the Paurashava government, the urban development shrimps, birds, and wildlife, and are taking the shape authority, and the Deputy Commissioner (DC), of a full-grown forest. They provide home for 90 among other institutions. Clarifying mandates and bird species (30 winter migrants), an endangered strengthening capacity and accountability on natural horseshoe crab species, and 80 fish species (Nabi et resource management aspects of city governance al. 2011; DoE 2015b). No comprehensive study has would help to ensure that the gains made under the yet been done to assess the provisioning services that mangrove restoration program are sustainable. this mangrove provides to the local communities. It is believed the mangrove acted as a natural embankment 3.2.3 Environmental Management in the during Cyclone Mora on May 30, 2017. Considering Municipality of Pabna the successful community-engaged restoration of mangroves in Nuniar Chara, the DoE took up similar Pabna is an aspiring town where urbanization is taking initiatives in different sites along the Bakkhali and place at a moderate rate but in an uncoordinated way Showfuldondi Rivers. across institutions. Pabna contains both seasonal and perennial wetlands—the former includes low-lying Institutional support from beyond the DoE and areas that remain inundated for around six months of the year, and the latter consists of river sections, community awareness nonetheless need further beels, and ponds that retain water year-round. These strengthening to sustain the mangroves’ regrowth wetlands influence the town’s livelihood opportunities and scale up the initiative. Besides the existing and ecological importance. The Ichamati River flows sites, it is estimated that around 200 additional ha through the Pabna Municipality. of riverside coastal land could be brought under mangrove restoration and management, which – Emergent environmental issues at the beginning of would further extend the benefits in terms of coastal unplanned development protection, biodiversity, and fisheries. Yet there is a lack of institutional support by the state-level actors Even at its current state of nascent urbanization, to restore and protect mangroves. Although the DoE Pabna is affected by unplanned development and demonstrated success with a mangrove plantation (with lack of environmental management. The primary data the help of the local government and community), collection found that 54 percent of the municipality’s the Bangladesh Forest Department (BFD) has the wetlands have been encroached upon or lost since mandate, and deeper technical expertise, for any 1990 (see Figure 3-6). In 1990 the total wetland area afforestation and reforestation initiative and forest was 568 ha, which by 2017 had been reduced to 264 and wildlife patrolling. ha. Major wetlands loss has been recorded, especially in the section of the Ichamati River that flows through Meanwhile, stronger city planning and management is the middle of the town, where encroachment is taking needed to prevent the mangrove restoration program place on both sides of the river. The study found that from being undermined by further encroachment about 63 percent of the river’s area has been reduced and degradation. Mangrove restoration is challenged over the last 27 years, while the surrounding wetland by ongoing disturbances from cattle grazing (mainly area has been reduced from 38 ha in 1990 to just buffalo), fishing activities, tree cutting, encroachment, 14 ha in 2017. At the field level, in all cases, ponds land conversions, and people’s lack of awareness were found to be smaller than what is recorded by the regarding the benefits mangroves offer. Land municipality, which indicates that these ponds have conversion for aquaculture (mainly shrimp farming), been encroached upon to varying extents. Besides the settlements, and other infrastructures is common municipality-managed ponds, there are more than in Cox’s Bazar. For example, at one corner of the 30 ponds within the municipality that are attached to Nuniar Chara forest, mangroves from a large area seven different institutions and ostensibly managed were cleared and converted to aquaculture farms by and controlled by such agencies. The status of key influential locals. This suggests either a lack of capacity, ponds of Pabna City and pictorial evidence of flooding will, and/or clarity on roles/responsibilities across are presented in Annex D of the background paper. 51 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - 3-6: LAND USE MAP OF PABNA MUNICIPALITY, 1990/2017 Source: Developed by World Bank consultants and CNRS. The rapid, unplanned development is not only monsoon season, many poor households used to catch causing waterlogging within the city, but the famous fish in the seasonal wetlands in Salgaria, Shibrampur, Ichamati River is dying, threatening livelihoods and other low-lying areas within and adjacent to and ecology. Within Pabna Municipality are five Pabna Municipality, but wetlands loss has reduced settlement areas where waterlogging is causing these opportunities. Locals report that various significant problems, particularly during monsoon resident and migratory bird species are no longer months: Salgaria Gorosthanpara (southwest), visiting the seasonal wetlands during winter. A large Choto Salgaria (southeast), Jogipara, Dilalpur, and 15-acre khas wetland called Poddaya Kole (a section of Shibrampur. Reduction of seasonal wetlands also the Padma River that got separated due to shifting of affects agricultural production, particularly in winter the main river course) is a closed wetland. The upazila (of boro rice); reduces open spaces; and threatens administration leases it out to fishers’ cooperatives wetland biodiversity, including fisheries. During for fishing purposes, as per the MoL’s 2009 Jolmohal Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 52 Policy. However, the leaseholder reported that several fact that the Wetland Conservation Act says that no drains from the town fall into this wetland, polluting wetland, private or public, within the urban areas can the water and killing the fish. Many households use be converted or filled up without permission from this wetland’s water and are affected by the pollution. the appropriate authorities. While the land is under the MoL’s jurisdiction, the DoF has the mandate – A way forward: Ichamati restoration and institutional to manage fisheries in wetlands and rivers, and the coordination Pabna Municipal Corporation is tasked with providing urban services, including solid waste management, Community support and engagement is needed maintenance of urban drains, etc. To ensure effective to restore the Ichamati River. The river is officially implementation of the Wetland Conservation Act owned by the MoL and managed by the BWDB, in Pabna, the following needs to be strengthened: which constructed sluice gates at the river’s mouth the capacity of the DoF as the technical expert; the to control flooding in the town. The people of MoL on land ownership monitoring; the DC on land Pabna have been protesting to demand the river’s leasing; and the Pabna Municipal Corporation on excavation and to free it from encroachment. On July effectively provisioning urban services to keep solid 10, 2017, BELA served a legal notice to 19 different waste and effluents out of wetlands and to maintain government departments, including the Secretary drainage systems. of Land, Secretary of the MoEFCC, Secretary of the Ministry of Water Resources, Director General of 3.2.4 Madhabdi and Narshingdi—A Tale of Two the DoE, Director General of the BWDB, Deputy Cities Commissioner of Pabna District, Police Super of Pabna, and Executive Engineer of the BWDB. A strong Madhabdi and Narshingdi provide a useful civil society platform called the Ichamati Rakkahay comparison for understanding the roles and Committee often advocates for the river’s restoration importance of city decision making, visionary and tries to make citizens and the administration leadership, and effective stakeholder collaboration aware of the importance of urgently evicting grabbers. in steering development and environmental The Pabna district administration has been laying the management outcomes. While a detailed analysis of groundwork to evict the illegal grabbers of the river urban environmental challenges was not completed by drawing up a list of them, but at the time of this for these cities, the focus on institutions aims to writing they had not yet been evicted—thus the fate complement the previous case studies’ deeper dive into of the river remains undecided. If awareness-building the environmental challenges of rapid urbanization. continues and institutional support and planning is These two neighboring Paurashavas north of Dhaka strengthened, it is expected that the dying river can have experienced contrasting development paths, be restored. although they are located close to each other, which is discussed further below. More broadly, institutional coordination and strengthening is needed to effectively implement – Madhabdi: An environmental management success the Wetland Conservation Act of 2000 and restore story wetland-based livelihoods. The MoL, DoF (under the Ministry of Fisheries and Livestock, MoFL), and Madhabdi Paurashava has experienced rapid Pabna Municipal Corporation are the three key industrialization and growth since the 1990s. The institutions for protecting and restoring Pabna’s growth was fueled by industries including textiles wetlands. The current execution of relevant laws (hand looms and power looms that supply products and policies seems ineffective, as several ponds and to Aarong), spinning mills, and dyeing and printing. low-lying areas (including khals) are encroached and Currently there are about 30 textile establishments used for settlements and urban infrastructure. Field around the Paurashava, and more upstream. observation shows that a number of private ponds According to Paurashava officials, there are currently have been filled up, all khals have been converted about 27,000 registered voters and a very high to narrow drains, and low-lying areas within the population density of about 30,000 people/sq. km. municipality are being filled up. This is despite the However, there is a large daily influx of about 50,000– 53 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 60,000 people from surrounding areas. With growth and having continuous, strong-willed local leadership of 8.1 percent/yr for 2001–11 (BBS 2014), land values can turn the tide of unplanned urbanization and have been increasing rapidly. Currently there are 9 pollution. Local business owners and associations wards (covering about 5 sq. km) and this is expected to have an important role to play in these efforts. expand to 12 wards (covering around 6 sq. km), likely Motivating them and encouraging key players to take in the north-south direction. the initial steps toward environmental stewardship can yield large dividends in urban renewal and tangible The city lacks an official Master Plan but benefits improvements in urban environments. from active civic engagement in town management. A Master Plan was developed for Madhabdi under the – Narsingdi: A contrasting development path LGED’s Important Towns Project in 2015; however, it was never gazetted. Madhabdi has a Town-Level In contrast to Madhabdi’s growth story, Narsingdi is Coordination Committee (TLCC), which has 50 a slow placed city with inadequate synchronization members consisting of councilors, teachers, doctors, between planning and development. There are no and so on. There are also smaller Ward Committees major industries within the Narsingdi Paurashava that review and approve development works in the area, although some are located several kilometers Paurashavas. For the past five years, solid wastes have upstream. One reason for the lack of industrial been collected by NGOs through annual tenders. growth is the city’s relatively higher industrial holding tax imposed, compared to neighboring Madhabdi. Yet The city’s development has been heavily influenced while free from major polluting industries, Narsingdi by notable mayoral leadership and an engaged lacks an urban Master Plan, which has resulted in business community, which have worked together slow but disorganized growth; the Paurashava area is to rehabilitate the river (locally known as the expected to expand from the current 10.3 sq. km to Brahmaputra) and manage pollution. The mayor, about 30 sq. km. With weak capacity at the Paurashava who served from 2011–16, set out a vision for the level, the city has failed to pace urban service provision town after the river is rehabilitated; his successor with land development. A Drainage Master Plan has has continued to implement this vision, and a 3-D been developed, and BDT 12 Crore (US$1.4 million) model was also created to help citizens see the plan. has been invested in drains. However, some of the The mayor was able to convince key commerce and town’s drainage outlets are under threat from land industry associations (Banik Samity and Dyeing development. Narsingdi collects about 75 tons of solid Owners’ Association) to come forward and help clean waste daily across the city but lacks a sanitary landfill, up the river. These business representatives have disposing of wastes in an open dumping site. put forward BDT 1 Crore (US$0.12 million) to help clean up the river. Within a period of one month, the The differences between Madhabdi and neighboring Paurashava managed to clear about 250 m of the river Narsingdi point to the importance of strong (out of a total target of 2,500 m) from solid wastes, leadership, civic awareness and engagement, a clear sludge, and encroachment. The Paurashava plans to vision, public-private collaboration, and strong install two drains on either side of the river to intercept governance to achieve positive environmental 27 outfalls that are currently polluting it. The drains outcomes. Stakeholders also noted Madhabdi’s will be connected to a treatment plant, which will then political stability and sense of law and order as strong discharge the treated water back into the river. A key contributing factors to nurturing an environment turning point in this rehabilitation initiative happened that enabled solid collaboration between businesses when an influential local citizen agreed to knock and city government. Stakeholders noted that even down a portion of his own six-story building that had during national political turmoil in 2014, markets and encroached onto the river bank. Seeing this example, businesses continued to operate normally. other influential businessmen also began to cooperate with the mayor and Paurashava officials. 3.2.5 Mymensingh—A University Town The example of Madhabdi shows that short-term The case of Mymensingh highlights a city where investments in town planning, setting a clear vision, development pressure is not as acute as in other urban Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 54 areas, due to the town’s historical nature and the by three laws passed in 2009: the City Corporations benefits from being close to Dhaka. Mymensingh is an Act; the Municipalities (Paurashava) Act; and the old town, first established in 1859. It currently consists Union Parishad Act. These acts have provisions that of 21 wards and covers an area of approximately allow the local authorities (e.g., the City Corporations, 21.73 sq. km. Although the 2011 census recorded a Paurashavas, and Union Parishads, respectively) to population of around 258,000 people, according to the develop urban area plans, with support from the Paurashava officials the current population is about UDD and LGED or a relevant urban development 500,000. The Mymensingh Strategic Development authority. For cities with development authorities, Plan (MSDP) includes the Paurashava and 10 unions, overlapping mandates are particularly problematic, covering an area of 292 sq. km. Although Mymensingh especially with regards to development control, as both is being given administrative importance, the town the City Corporations and development authorities grows more like a university town than a business have the mandate to evict or demolish buildings that hub. The city’s proximity to Dhaka means that many do not follow approved plans or are deemed unsafe. residents own and work in businesses and industries A simple solution in these cases could be to transfer all in and around Dhaka. Hence, Mymensingh residents powers for enforcing urban plans to the development have good employment opportunities, but the city authority with the provision of adequate resources and does not face the pollution externalities of industrial empowerment. Another solution could be to empower development. the City Corporations and the municipalities. Since these entities have staff down to the ward or union Mymensingh municipality is currently in the level, their mandates should be broadened as elected process of transitioning from Paurashava to a City city/municipality governments; they should have the Corporation governance model, which is expected to sole authority to protect, rehabilitate, and sustainably increase its town planning manpower. However, city manage urban wetlands. administrative capacity is lagging in the meantime. The future City Corporation is expected to cover an Clarifying responsibilities should be accompanied area of about 94 sq. km, or about a third of the MSDP by building capacity and streamlining record- planning area. In the meantime, the Paurashava keeping systems. In the short term, all copies of government faces many classic challenges of mid-sized necessary records could be kept with the local cities in terms of service provision. The Paurashava is government authorities. In the medium term, such responsible for solid waste management, but there are records (especially of new applicants) should be kept some technical and manpower capacity constraints. in a digital system that can be readily accessed by all The existing dumping site has another 10 years relevant agencies. operational capacity if managed properly, according to officials. The city also has a separate composting The Economic Zone Act of 2010 was an important facility for organics that is jointly managed by the milestone for facilitating more rational industrial Paurashava, the DoE, and a private operator. The zoning and planning. At the same time, agglomerating city is also planning a new landfill site and plans to industries into SEZs may also herald new challenges in terms of managing their cumulative environmental increase its investments in solid waste management. impacts, which these institutions need to plan for and monitor. Land use zoning in urban areas is normally 3.3 PRIORITIES FOR ACTION covered under the Master Plans developed by local government authorities. Despite having such plans in Institutional reforms are needed in urban urban areas, industries have continued to grow in most governance, particularly to clarify overlapping cities in a largely unplanned manner, resulting in the mandates in urban planning and implementation. encroachment of wetlands and forests, degradation of Lack of such clarity is currently contributing to waterways, and heightened exposure of residents to poor environmental management outcomes and emissions, effluents, and other wastes from factories. creating issues with waterlogging, encroachment, The situation is even worse in peri-urban and rural deforestation, groundwater extraction, urban areas where there are no such plans. In 2010 the flooding, and more. Towns and cities are governed government enacted the Economic Zone Act, which 55 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh aims to locate industries in specially developed 24 (Paurashavas). For example, clause 15a requires areas around the country, and would also ease land- City Corporations to set up biodiversity management related problems faced by potential local and foreign and monitoring committees chaired by the mayor investors. The act provides a legal basis for establishing that include a DoE representative as a secretary. The economic zones throughout the country for industrial committees are tasked with preparing a Register of development, led and managed by BEZA. As zones Biodiversity and including details of different uses for get developed, it will result in more organized use biological materials; supporting the implementation of land for industry and urban growth, as well as an of an NBSAP; raising awareness; identifying and opportunity to bring better balance to agricultural protecting biodiverse hotspots; and estimating damages land use by restricting economic zones to areas that caused to biodiversity. Similar arrangements are also are less suitable for agriculture. Dhaka is the clear- mandated at the Paurashava level. Furthermore, the cut example of this concern, with a concentration of act stipulates that alternative livelihood arrangements proposed SEZs around the city, especially toward its should be arranged at the local level for communities northern end. On the one hand, this can be beneficial in which biodiverse resources are affected. Although for the city, as the existing industries can move to this decentralized approach is welcomed, its practical the new SEZs. However, with the concentration of implementation will be difficult without strengthening SEZs around Dhaka, there is a chance of increased local authorities’ manpower and technical capacity, as environmental impacts, especially in the waterways well as that of DoE field offices. around the city. Therefore, this situation needs to be carefully managed—in terms of siting requirements/ The above analysis highlights that more attention zoning, environmental and pollution management needs to be paid to environmental management, infrastructure (like CETPs) and thresholds, and and that implementation of the 1997 ECR should natural hazard risk mitigation/flood vulnerability— be ensured to manage urban development not only and monitored as SEZs are developed in the coming in big cities like Dhaka but also in municipalities years. like Pabna. Madhabdi is a success story of river restoration, and shows how citizen and private sector Building local governments’ capacity to enforce engagement play a critical role in urban management. environmental acts and regulations pertaining to The recent iconic lake restoration projects in natural resources is also critical for achieving urban Dhaka at Hatir Jheel, Gulshan, and Banani Lake eco-development. For example, the Bangladesh demonstrate that city governments can effectively Biodiversity Act of 2017 mandates local urban take action to integrate environmental management institutions to play an active role in conservation; into urban development. The next chapter identifies however, to effectively implement the act, proper areas of policy enhancement, institutional reform, rules need to be developed and the local authorities and investment. While this chapter summarized need to be strengthened if they are to fulfill their key institutional-level interventions drawn from the mandated roles. This act has specific directions for case studies, the next chapter will discuss investment urban areas under clauses 15 (City Corporations) and options. For more detail, see the background paper, “Towards and Clean and More Resilient Cities.” 38. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 56 CHAPTER 4. A WAY FORWARD Over the last decade, Bangladesh has improved its i. Enhancing environmental policy and institutions policy regime and systems for environmental and at the national level pollution management. Since 2006, when the World ii. Enhancing environmental management at the Bank’s first CEA for Bangladesh was published, local/city level the country has made tangible progress in further iii. Strengthening the enforcement and accountability developing environmental policies, guidelines, and regime legislation. This progress toward mainstreaming the iv. Leveraging market-based instruments to protect environmental agenda across government is especially the environment and unlock green financing apparent in the country’s national development, v. Promoting RECP as a tool for reconciling environment, and climate change strategies, as well as environmental performance with competitiveness in specific enhancements to the legal framework for vi. Harnessing the power of public pressure pollution control, management, and accountability. Some industry-specific initiatives for scaling up cleaner i. Enhance environmental policy and institutions production practices have also gained momentum. at the national level Yet much more needs to be done to arrest the stark Additional reform measures should be considered effects of pollution and environmental degradation to complement ongoing updates of core policies, on people’s health and economic productivity. regulations, and standards. These include: Achieving Bangladesh’s objective to reach upper- middle-income status through cleaner and more i. Require the public disclosure of all environmental resilient growth will depend on further developing information related to facilities and development and strengthening a range of complementary policies projects subject to ECC. and systems for environmental protection, urban ii. Strengthen EQS based on a rigorous review and development, and industrial management. This is public consultation, which could be informed by a even more critical for Bangladesh than for most other background paper that clearly justifies proposed countries at a similar income level due to its uniquely changes. high population density and vulnerability to climate iii. Strengthen the legal and institutional framework risks. Moreover, institutional reforms and capacity for hazardous material management, based on building will be key in all areas to ensure effective data collection and analysis to better understand implementation of adopted strategies and policies. the issue. Based on the analysis in this CEA, priorities for reform and investment should include the following: 57 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Significant institutional reform is also required to MoI, MoC, and Ministry of Textiles and Jute. For enable the DoE to effectively achieve its environmental industrial zones, such units should be set up both management mandate. The department needs to at headquarters in BEPZA/BEZA and at the zone be modernized and decentralized, with much better level. information systems and a much larger local footprint iv. Train officials at the relevant institutions on outside Dhaka. Priority should be given to areas/cities environmental management. with the highest levels of pollution. In particular, deploying more DoE staff to existing and additional It is equally critical to launch a concerted effort by field offices (based on a needs assessment) is necessary several ministries and agencies, the private sector, to improve environmental management. There is and civil society. Industrial and urban development also a need to provide better incentives to attract and are complex, multisectoral subjects that require retain talented and competent professionals, possibly coordination between different public and private by instituting a cadre system and elevating the most stakeholders. The government should actively engage senior position—DG, currently at the Additional with other ministries/agencies and the private sector Secretary level—to match the rank of equivalent by leveraging existing platforms for PPD and creating positions in other major departments (e.g. the Forest new ones where they are missing. Department at the MoEFCC, whose head has the rank of Secretary). Within the DoE, compliance and ii. Enhance environmental management at the enforcement staff should be separated to distinguish local/city level and elevate core priority functional areas. There is also a need to increase the DoE’s overall budget allocation Institutional reform is needed in local governance, and approved headcount to allow it to effectively particularly to clarify overlapping or overlooked conduct enforcement. In addition, the revenue base mandates in urban planning and implementation. could be diversified (see the later section on market- For example, responsibility for constructing and based instruments). maintaining drainage in Dhaka is split among multiple agencies. These functions should be consolidated Mainstreaming environmental management under the DSCC and DNCC, which are mandated for and green development across all relevant line solid waste management. The capacity of both DCCs ministries and agencies is essential to creating an (north and south) should be strengthened as elected enabling environment for sustainable growth. In city governments; they should have the sole authority particular, enhancing systems and capacity to manage to protect, rehabilitate, and sustainably manage the environmental issues is needed among the institutions urban wetlands within Dhaka City. This will help avoid responsible for urban and industrial development. inter-agency conflicts that contribute to destroying, Recommendations include: rather than protecting, wetlands in urban settings. The overlapping mandates of different institutions i. Promote environmental sustainability and cleaner should also be coordinated for smaller cities, such as production in land use planning and financial, Pabna. industrial, and import/export policies. For example, the Ministry of Planning can integrate Integrated urban planning is necessary for liveable a Strategic Environmental Assessment (led by city development. The UDD and the MoHPW have the MoEFCC), to zone and demarcate areas for made a 20-year Master Plan (2011–31) for Cox’s industry across the country in environmentally Bazar Municipality and adjoining areas, taking into appropriate locations, and require comprehensive consideration the town’s rapid urbanization. Being a EAs before clearing any new zones. coastal and disaster-prone city, the plan needs to adopt ii. Amend the 1980 BEPZA Act to mandate a “ridge to reef ” approach to coastal town planning, environmental compliance requirements, as whereby planning covers detailed area development, already provided for in the 2010 BEZA Act. from hilltops to hill slopes, to plans on the coast, where iii. Create an Environmental Management Cell/Unit the land and water meet; and considers hydrology, in relevant ministries and agencies, such as the ecology, economy, and society, including the current Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 58 and potential impacts of climate change and coastal iii. Strengthen the enforcement and accountability hazards. Furthermore, aligning the plan with relevant regime international treaties, such as the Sendai Framework and the Paris Agreement, as well as with the SDGs, There is scope to increase accountability, trust, will facilitate green growth, protect ecosystems, and and deterrence in the environmental enforcement safeguard biodiversity. Cox’s Bazar has a high potential regime. It is necessary to replace what appears to be to transition into an eco-city. ad hoc application of the polluter pays principle with a transparent, rule-based system that can serve as an A major effort is needed at the local/city level to effective deterrent to polluters. These rules should clarify institutional arrangements and strengthen specify a system of progressive fines that should vary capacity to more effectively implement and enforce with the level of violation and the type/size of industry. adopted policies and plans. While Bangladesh has In line with best international practice, repeated made good progress in terms of developing policies violators should be penalized at progressively higher and acts, implementation is often limited, resulting rates with an effective provision for closure, if repeated in unplanned urban and industrial development. For violations continue. Such rules could be complemented example, although several low-lying areas at the Dhaka with (i) realistic and scientifically grounded emission/ City periphery are designated as WRAs and FFZs, discharge and ambient environmental quality these are being rapidly filled up and converted (such standards; (ii) an option to develop a monitorable as Ashulia’s low-lying area). Short-term investments and time-bound compliance plan when the current are urgently required to improve governance and technology is unable to meet the standard and a new transparency. RAJUK is making some effort in this investment is needed; and (iii) the operationalization direction; it introduced a digitization system to provide of a funding stream dedicated to environmental land use clearance and design approval. RAJUK is remediation. also piloting an online land use clearance system. A comprehensive information management City Corporations need to assess solid waste system with automated monitoring for compliance management options, with a view toward exploring and enforcement would help reduce the cost of appropriate models for private sector involvement and enforcement and improve its effectiveness. Existing public-private partnerships. In larger cities or urban information management systems can be enhanced to agglomerations in particular, solid waste management become more comprehensive, serving as a database must become a viable business proposition if the to track all ECC holders, their compliance and private sector is to play a larger role. There is also a monitoring requirements, monitoring data, renewal pressing need for regional waste management facilities, timelines, past violations and penalties applied, and including those that handle hazardous wastes that so on. The system should, to the extent possible, be contaminate soil and increase health costs, as discussed accessible online and available to the public; this will in Chapter 1. The underlying policy regime will need help increase polluters’ accountability. The portal to be improved to make better waste management could also receive automated monitoring data from options viable and financially sustainable. industrial clusters and large industries, and track grievances or complaints related to environmental Better planning and increased investments in management issues on specific facilities or projects. secondary cities could relieve the concentrated pressure on Dhaka. For secondary towns such as Outside experts should be used to support Pabna that want to continue growing, and in which environmental clearance processes and compliance urbanization is taking place at a moderate rate, monitoring to supplement DoE’s staff capacity. long-term investments are needed to develop the The proposed 2017 ECR contains a provision for infrastructure in a planned way that takes into account constituting a clearance committee in the DoE to land space and use, such as seasonal and perennial decide on Red category projects. It is recommended wetlands. that the committee involve outside experts to 59 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh assess Red category projects and issue location and Bangladesh should consider introducing fiscal environmental clearances. The DoE should also instruments for promoting green growth. In develop an accreditation system and outsource particular, the environmental surcharge for heavy compliance monitoring to accredited consulting firms. polluters and the carbon tax proposed in recent years could be reexamined. Such taxes could be applied A more effective environment court system would gradually and designed in ways that address efficacy help hold polluters accountable. Internationally, the and competitiveness, based on best international concept of easy access to a fair, equitable, timely, and practices. Revenue-neutral environmental tax reform, inexpensive justice system has been recognized as an which aims to offset new taxes on environmental important facet of environmental governance.39 The “bads” by reductions in existing distortive taxes on system in Bangladesh has proven its usefulness, but production factors such as capital and labor, could could be enhanced by: be one option to explore. Tax credits or subsidies for green investments and innovation could also be i. Amending the Environment Court Act of 2010 to used temporarily, although they should be carefully allow direct public access to the courts; and considered to avoid inefficient, costly, and opaque use. ii. Setting up environment courts in more districts, Another way to reduce the cost of green technologies prioritizing those facing the most severe could be to reduce customs duties for environmental environmental degradation and pollution issues. products (e.g., chemical products) and technologies (e.g., solar panels). iv. Leverage market-based instruments to protect the environment and unlock green financing To maximize impact, sources of funding for environmental management should be diversified. Making growth sustainable will require ensuring While the DoE’s budget needs to be increased, it can that the private sector and markets direct more be complemented by other revenue sources—for resources toward greener activities and investments. instance, by fees for clearances and reviews, and other As a complement to the adoption and enforcement services. Bangladesh could also consider establishing of environmental regulations, getting price signals a national trust fund dedicated to conservation right for resources and using fiscal instruments to and environmental management. International internalize environmental externalities would help experience shows that such funds can be very effective minimize resource use and pollution from production when supported by an adequate governance and and consumption. Moreover, Bangladesh can build management structure (see Box 4-1). As mentioned on results achieved thus far to scale up financing for earlier, environmental taxes and charges could also green investments. be leveraged to fund environmental management activities. Adequately pricing key resources, such as water and energy, is essential to foster their efficient use. As It will be essential to scale up financing for green previously argued, an effective groundwater licensing investments. Almost a decade after the BB introduced and metering regime is key to ensure efficient water use its first green scheme, there is an opportunity to take by industries. The introduction of load-based charges stock of progress to date on green finance and to on discharged pollutants may be also considered. identify remaining obstacles on both the supply and Likewise, reducing fossil fuel subsidies to industries demand sides. Detailed analysis is needed to assess would promote energy efficiency and accelerate the the scope for increasing green commercial lending, shift toward cleaner energy sources. including to finance RECP investments by SMEs in 39. Article 9, Convention on Access to Information, Public Participation in Decision Making and Access to Justice in Environmental Matters, 1998, Johannesburg Principles on the Role of Law and Sustainable Development (adopted at the Global Judges Symposium, Johannesburg, South Africa) August 18–20, 2002, and Principle 10, Rio Declaration on Environment and Development; Agenda 21, in Report of the United Nations Conference on Environment and Development, Rio de Janeiro, UN Doc. A/CONF.151/26/Rev.1 (Vol. 1), Annex II (1992), Chapter 8, Paragraph 2. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 60 Box 4-1. International Experience with National Environmental Funds Environmental funds (EFs) have been established in many developed and developing countries worldwide. Such funds have proven to be a valuable policy instrument to foster conservation, environmental management, and/or climate mitigation/adaptation. Specific names and purposes vary, but an EF can generally be defined as an “independent legal entity and investment vehicle to help mobilize, blend, and oversee the collection and allocation of financial resources for environmental purposes.” Key elements of EFs include their legal, governance, and financial structures, their resource mobilization strategy, and their grant delivery modality. Although different legal and governance models are possible, the experience shows that leaving fund management responsibility to an entity independent from government is essential for transparency and efficiency. However, government representatives often sit on EFs’ governing bodies. A good example of an EF focused on pollution control is Poland’s National Fund for Environmental Protection and Water Management (NFOSiGW),a which is the largest institution that finances environmental protection projects in the country. The national-level NFOSiGW was established as an independent entity in 1989 and functions in coordination with 16 regional funds, which were also granted legal personality in 1993. In addition, communal and district funds are controlled by local governments. The national and regional funds are funded through earmarked revenue from high pollution charges and fines. NFOSiGW is also used as a channel for European and other foreign funds allocated to environmental protection. The national and regional funds independently select projects to be supported through concessional loans and grants. Between 1989 and 2012, outlays from the national and regional environmental funds exceeded PLN 62 billion (around US$16.8 billion), mostly for air and water pollution control projects. More details on EFs’ key design elements, sample documents, and case studies can be found in the Environmental Fund Toolkit put together by the Conservation Finance Alliance,b as well as from UNDP.c Notes: a. For more information, see the National Fund for Environmental Protection and Water Management, https://nfosigw.gov.pl/en/nfepwm; b. For more information about the Environmental Fund Toolkit, see the Conservation Finance Alliance, http://www.conservationfinancealliance.org/ environmental-funds-toolkit/; c. For more information about environmental funds, see the UNDP, http:// www.undp.org/content/sdfinance/en/home/solutions/environmental-trust-funds.html. priority polluting industries, using a full range of v. Promote RECP as a tool for reconciling instruments (e.g., credit risk guarantees). Beyond environmental performance with competitiveness commercial lending, green bonds are a powerful tool with which to tap into private capital markets Mainstreaming RECP among polluting industries can to finance larger green infrastructure development help reconcile better environment performance with projects; these have generated interest in Bangladesh. competitiveness. The adoption of RECP can be scaled The GoB could support this by introducing a policy up by having both industry and government address and institutional framework on green bonds. Finally, several gaps related to awareness and technical and enhanced coordination between the BB and the DoE is financial capacity. Awareness campaigns on the scope needed to increase synergies between green financing of RECP and the benefits for SMEs—showcasing on promotion activities, environmental policy, and the actual cases—will help convince more firms to move promotion of cleaner production. toward greener production. In addition, collaboration 61 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh with technical institutions and industry associations on shuttering coal plants in major cities and reducing the cleaner production technologies should be enhanced. number of new cars allowed to be registered in Beijing and other metropolitan areas. Bangladesh could consider establishing a dedicated technical institution to identify, demonstrate, and Education programs and raising awareness about promote cleaner technologies, following the model the value of the environment and its function of Cleaner Production Centers adopted in many in urban setting is critical to effectively engage countries. While pilot initiatives exist, most industries citizens. It is important to make urban communities, need more support in terms of knowledge about including children, more aware of the value of clean technologies and capacity building to actually natural resources and the importance of including, implement such technologies. A technical platform protecting, and managing wetlands and their is needed to help industries until these technologies functions in urban settings. To this end, relevant become the norm. Such mandate could be taken up agencies should organize events and programs on by an existing institution or a new one, with several what citizens can do, and develop and disseminate possible institutional models. various educational materials on wetlands’ values, functions, and management. To foster private investments in clean technologies, PPD needs to be strengthened among government, Enhanced disclosure and accessibility of data on industry, and financial institutions. Coordination environmental degradation and pollution is key to between the public and private sector is critical to empowering citizens. As mentioned earlier, it would strengthen environmental sustainability and promote be important to disclose all environmental information private investments’ resource efficiency. Based on related to facilities and development projects subject early success in the textile sector, such dialogue should to ECC—including IEEs/EIAs summarized in the local be promoted across all industries. language, and ongoing compliance monitoring and enforcement data. vi. Harness the power of public pressure Key recommended actions, summarized earlier, History shows that pressure from the public has often have been prioritized in terms of a timeframe for been a key factor to push polluters and regulators to implementation (short vs. medium term), as well as improve environmental management. Pressure from potential level of impact. The prioritization was based citizens, especially those in the rapidly expanding on consultation and the results of assessments. Table middle class, has been a major driving force for 4-1 was prepared to highlight immediate steps the change in tackling pollution in various countries, such government can take to start tackling environmental as China. In 2013, citizens’ outrage over Beijing’s issues, while at the same time emphasizing the need hazardous air quality forced the central government for medium-term policy and institutional reforms to act. It declared a “war against pollution” in 2014 and investments to ensure sustainable urban and has since taken important measures, such as environmental management. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 62 TABLE - 4-1: KEY RECOMMENDED ACTIONS Key Message Action Impact Timeline Responsibility i. Enhance As part of the 2017 ECR update, require public High Short DoE environmental disclosure of all environmental information related policy and to ECC or otherwise mandated under ECA institutions at Strengthen EQS based on a rigorous review and High Short DoE the national public consultation level Strengthen the legal and institutional framework Medium Medium DoE for hazardous material management DoE institutional reform: Increase the DoE’s High Medium MoF, DoE overall budget allocation and approved headcount; deploy more staff to field offices and open additional field offices DoE institutional reform: Separate compliance High Medium DoE and enforcement staff and distinguish/elevate core priority functional areas, institute a cadre system, and elevate the DG to the Secretary level Mainstreaming environment: Promote High Medium MoP, MoC environmental sustainability and cleaner production in land use planning and financial, industrial, and import/export policies Mainstreaming environment: Amend the 1980 High Short BEPZA BEPZA Act Mainstreaming environment: Create an Medium Medium MoI, MoC, Environmental Management Cell/Unit in relevant MoTJ, ministries and agencies BEPZA/BEZA Mainstreaming environment: Train officials at High Short MoEFCC, relevant institutions on environmental management DoE Coordination: Leverage existing platforms for PPD High Medium DoE, MoI, and create new ones as needed and MoC in collaboration with business associations ii. Enhance Institutional reform: Clarify mandates in urban High Medium City environmental planning and implementation governments management Promote integrated city development planning High Medium City at the local/city by integrating natural resources into cities’ wider governments level spatial planning Strengthen capacity at the local/city level Medium Medium City governments Solid waste management options need to be High Long City assessed to find appropriate models for private governments sector involvement and public-private partnerships Invest in secondary cities Medium Long City governments 63 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Key Message Action Impact Timeline Responsibility iii. Strengthen Modernizing enforcement: Develop a Medium Short DoE the comprehensive information management system enforcement Modernizing enforcement: Replace ad hoc Medium Medium DoE and enforcement with a rule-based system accountability regime Use outside experts: Involve experts in Medium Short DoE proposed ECC clearance committees, develop an accreditation system, and outsource compliance monitoring to accredited consulting firms Environment court system reform: Amend the Medium Medium MoEFCC Environment Court Act of 2010 to allow direct public access and set up environment courts in more districts iv. Leverage Energy/water use: Establish tariffs and metering to High Medium Relevant market-based incentivize resource efficiency institutions instruments in charge of to protect the tariffs environment Introduce financial instruments to green High Medium BB in and unlock industries (need further analysis to identify exact collaboration green financing instruments) with private banks, the DoE, business associations Diversify sources of funding for environmental High Medium MoEFCC management Green financing: Analyze existing financial Medium Short BB in mechanisms to identify bottlenecks and options for collaboration improvement with private banks, the DoE, business associations Green financing: Develop a financing scheme to High Medium BB in facilitate commercial financing of RECP investment collaboration by SMEs in polluting sectors with private banks, the DoE, business associations v. Promote Technical support to firms: Strengthen technical High Medium DoE, MoI, RECP as a tool institutions and/or establish new center(s) to MoC, for reconciling identify, demonstrate, and promote cleaner technical environmental technologies institutions, performance business with associations, competitiveness academic community Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 64 Key Message Action Impact Timeline Responsibility PPD: Strengthen dialogue between government, High Short DoE, MoI, industry, and financial institutions on opportunities and MoC in for and constraints to cleaner production collaboration with business associations Review and update RECP-related policies to ensure Medium Medium DoE, MoI, effective implementation (e.g., include resource and MoC in input standards in ECC approval, etc.) collaboration with business associations Awareness campaign on RECP scope and benefits High Short DoE, MoI, targeting SMEs and MoC in collaboration with business associations vi. Harness the Effectively engage local communities and relevant High Short City power of public stakeholders in city development planning governments pressure processes Support education and awareness raising to Medium Medium MoE, NGOs, empower citizens etc. Transparency: Disclose all environmental High Short DoE information related to facilities and development projects subject to ECC 65 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh REFERENCES Abedin, S. B., and Z. B. Rakib. 2013. “Generation and Quality Analysis of Greywater at Dhaka City.” Environmental Research, Engineering and Management 2 (64): 29–41. ADB (Asian Development Bank). 2010. Managing Hazardous Wastes, by David W. J. Green. Technical assistance consultant report, Hong Kong. Ahmed, M. K., S. Islam, S. Rahman, M. R. Haque, and M. M. Islam. 2010. “Heavy Metals in Water, Sediment and Some Fishes of Buriganga River, Bangladesh.” International Journal of Environmental Research 4 (2): 321–32. 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Paris: UNESCO. http://unesdoc.unesco.org/images/0023/002318/231823E. pdf. 71 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh ANNEX A KEY ACHIEVEMENTS IN THE DEVELOPMENT OF BANGLADESH’S ENVIRONMENTAL LEGAL AND REGULATORY FRAMEWORK SINCE 2006 Since 2006, there has been growing attention paid The MoEFCC recently published its Country to environmental issues in Bangladesh’s governance Investment Plan (CIP) for the 2016–21 period. The principles and strategic plans; notably, the government CIP was developed through a consultative process has adopted the SDGs. In 2011, the Constitution of and reflects relevant policies, plans, strategies, Bangladesh was also amended to highlight the state’s and laws. The CIP has four pillars: (i) Sustainable role in conservation and environmental management. Development and Management of Natural Resources; As Article 18A states, “The State shall endeavor to (ii) Environmental Pollution Reduction and Control; protect and improve the environment and to preserve (iii) Adaptation and Resilience to, and Mitigation of, and safeguard the natural resources, biodiversity, Climate Change; and (iv) Environmental Governance, wetlands, forests and wild lives for the present and Gender, and Human & Institutional Capacity future citizens.” Building. The CIP identified 14 programs and 43 subprograms under these four pillars. The total The government’s Seventh Five-Year Plan also stresses financing required was estimated at US$11,679,500, of the importance of both strengthening institutions which US$4,713,000 has already been allocated, and for improved environmental compliance and the remaining US$6,966,500 requires gap financing. enforcement as well as promoting and scaling up The programs under Pillar 2 had the largest amount the emerging experience in greening manufacturing of gap financing (US$2,610,600). industries to support economic growth targets by 2021 (see Annex B). Pillar 2 programs include: (i) Reduced Industrial Pollution; (ii) Reduced Municipal and Household The country is also in the process of updating its Pollution; and (iii) Reduced Pollution from Agriculture National Environmental Policy; at the time of this and Other Sources. Some of the priority investment publication, the draft policy had been approved areas in these programs include: (i) establishing by the National Environmental Council and would treatment units for toxic and hazardous wastes soon be considered by the Cabinet, after which it through public-private partnerships; (ii) creating will be gazetted. The new draft makes important industrial parks with CETPs; (iii) offering incentives/ improvements over the 2013 policy, especially in benefits for industries to adopt zero-discharge policies; the following key areas related to industries and (iv) adopting fiscal measures to discourage pollution clean production: focus on industrial development and encourage the use of clean technology; (v) (section 3.15); management of chemical substances conducting real-time online monitoring of ETPs; and (section 3.22); and environmentally friendly (vi) improving municipal and medical waste, as well economic development, sustainable production, and as e-waste management. Pillar 4 programs include: consumption (section 3.24). (i) an improved legislative, regulatory, and policy framework; (ii) improved stakeholder participation At the same time, there have been several additional and gender equity in the EFCC sectors; and (iii) rules and legislations related to environmental improved organizational capacity and processes for management, such as (but not limited to): the evidence-based decision making. Some of the priority Environment Court Act (updated in 2010), the Wildlife investment areas in these programs include building Conservation and Security Act (2012), the Brick the capacity of legislators; establishing a biodiversity Manufacturing Control Act (2013), the Bangladesh cell, a chemical management cell, and a 3R cell Water Act (2013), the Ecological Critical Area Rules in the DoE; piloting community-based pollution (2016), and the Bangladesh Biodiversity Act (2017). control enforcement at seven demonstration sites; Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 72 strengthening measures for implementing EIAs (e.g., At the time of this writing, the government was also engaging a panel of experts to review EIAs); adopting in the process of finalizing and gazetting a revised measures to enhance the DoE’s enforcement, version of the 1997ECR, which is discussed further in monitoring, and surveillance capacity; increasing Section 2.1 and Annex B. public participation in environmental hotspots; and developing a monitoring and information system for Additional new environmental laws passed since 2006 the most polluting industries. are outlined in the table below. TABLE - A-1: ENVIRONMENTAL LAWS PASSED SINCE 2006 Name of Act Public Procurement Act, 2006 Chemical Weapons (Prohibition) Act, 2006 Padma Multipurpose Bridge Project (Land Acquisition) Act, 2009 Fish Feed and Animal Feed Act, 2009 National Institute of Biotechnology Act, 2010 Bangladesh National Scientific and Technical Documentation Center (BANSDOC) Act, 2010 Fish Hatchery Act, 2010 Bangladesh Tourism Restricted Area and Special Tourism Zone Act, 2010 Bangladesh Tourism Board Act, 2010 Bangladesh Gas Act, 2010 Bangladesh Economic Zone Act, 2010 Real Estate Development and Management Act, 2010 Compulsory Use of Jute Packets for Goods Act, 2010 Quick Increase of Electricity and Fuel Supply Act (Special Provision), 2010 Environment Court Act, 2010 Bangladesh Climate Change Trust Act, 2010 Balu Mahal & Soil Management Act, 2010 Plant Quarantine Act, 2011 Dhaka Elevated Expressway Project (Land Acquisition Act), 2011 Animal Slaughter & Meat Quality Assurance Act, 2011 Science & Technology Development Trust Act, 2011 Bangladesh Agricultural Research Council Act, 2012 Bangladesh Atomic Energy Regulator Act, 2012 Wild Animals (Conservation & Protection) Act, 2012 Disaster Management Act, 2012 Sustainable & Renewable Energy Development Authority Act, 2012 Bangladesh Water Act, 2013 National River Conservation Act, 2013 Payra Port Authority Act, 2013 Hilly Chittagong Development Board Act, 2014 DNA Act, 2014 Bangladesh Hotel & Restaurant Act, 2014 Metro Rail Act, 2015 73 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Name of Act Bangladesh Energy & Electricity Research Council Act, 2015 Formalin Control Act, 2015 Bangladesh Oceanographic Research Institute Act, 2015 Atomic Energy Plant Act, 2015 Payra Port Authority (Land Acquisition) Act, 2016 Cox’s Bazar Development Authority Act, 2016 Petroleum Act, 2016 Bangladesh Bridge Authority Act, 2016 Railway Property (Illegal Settlement Elimination) Act, 2016 Bangladesh Investment Development Authority Act, 2016 Tea Act, 2016 Bangladesh Biodiversity Act, 2017 Jute Act, 2017 Bangladesh Development Research Institute Act, 2017 Bangladesh Atomic Agricultural Research Institute (BINA) Act, 2017 Bangladesh Agricultural Research Institute (BARI) Act, 2017 Bangladesh Jute Research Institute Act, 2017 Bangladesh Road Transport Authority Act, 2017 Bangladesh Rice Research Institute Act, 2017 UPCOMING POLICIES, LAWS, RULES, • Draft National Environmental Policy • Draft Clean Air Act AND GUIDELINES • Draft (updated) Environment Conservation Rules • EIA guidelines for the following sectors: cement, At the time of this writing, the following important coal mine, industries, roads and bridges, gas environmental policies and rules were in the process downstream, gas upstream, pharmaceuticals, and of being developed and approved: textiles Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 74 ANNEX B KEY OBSERVATIONS AND RECOMMENDATIONS FOR THE DRAFT 2017 ECR There are some operational limitations in the 1997 ECR, most of which are addressed in the proposed 2017 ECR (draft). An account of these differences and key recommendations are provided in Table B-1. TABLE - B-1: COMPARISON BETWEEN THE 1997 ECR AND 2017 ECR (DRAFT) ECR 1997 ECR 2017 (draft) Comments and Recommendations Industry categorization: Green, Industry categorization: Green, The current practice for Orange-A, Orange-B, and Red. Yellow, Orange, and Red. If an EA requirement for non- There was no direction for industry is not listed in any of the listed industries or projects is industries or projects that did not categories, the DG of the DoE determined on an ad hoc basis. fall under these four categories. will decide on its category and A formal structure will now be EA requirement via committee established. recommendation. There is no requirement for This has not been addressed in the Requiring ECC at the SEZ/ ECC at the zone level for special new rules. EPZ level would ensure that an industrial zones like SEZs and alternatives analysis is carried out EPZs; only at the individual before siting the zones, and would industry level. also allow for effective capturing of cumulative impacts, which are not normally adequately assessed or mitigated through industry-level IEEs/EIAs. While the requirement that This has not been addressed in the EA for non-industrial projects is potentially polluting industries new rules. under the same umbrella as the renew their ECC every year is 1995 ECA. Therefore, a specific justified, it may not be suitable direction for ECC renewal for such for certain non-industrial projects projects would be useful. (including, for example, bridges, roads, or dams). This creates ambiguities in the application of the 1997 ECR. 75 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh ECR 1997 ECR 2017 (draft) Comments and Recommendations Public participation or The proposed 2017 ECR has This is a very important and consultation is not a condition in set new clauses detailing the positive amendment to the the 1997 ECR; however, the DoE requirement and nature of public ECR. Public consultation has prefers the proponent to engage consultation to be conducted for now become a legally binding in public participation during EIA Red category projects. There is prerequisite to obtain ECC. preparation, as stated in the "EIA a requirement in schedule 15 to However, the DoE could do more Guidelines for Industries" (DoE consult with stakeholders during in this regard by mandating public 1997). project planning and feasibility to disclosure of the EIA report’s draft the ToR for the EIA and to findings. Opportunities for the state whether the ToR approved by public to review the EIA report the DoE has been used to prepare are under the discretion of the the EIA. Public consultation has DG of the DoE. The DoE does been made mandatory (and is not officially disclose EIA report therefore legally binding) for findings publicly on its website project proponents to obtain site unless project implementing and environmental clearance. agencies do so either on their own There is now a requirement accord or because they are subject to involve DoE officers in the to disclosure requirements of public consultation process donor agencies. and to conduct national-level consultations for large/nationally important Red category projects. According to the 1997ECR, the The new ECR has addressed The DoE is already practicing DoE approves site clearance for this issue specifically for Red a similar procedure for the project before issuing the category projects. Article 13 environmental clearance in recent ECC, which is done after the EIA mentions that an EIA approval times, although the new rules are report has been reviewed. As (including a resettlement plan not yet effective. As a first step, per the 1997 ECR, the project and public consultation report) is they issue an EIA approval before proponent is allowed to develop required to obtain site clearance, site/environmental clearance. Only the land on the project site when and subsequently environmental when they are convinced that the site clearance is issued. This clearance. As a result, the analysis the project proponent has taken means that the proponent is of alternatives will have to be all pollution control measures allowed to invest resources to carried out a priori in order to do they issue the ECC. The new some extent before the EIA is obtain site clearance. rules therefore codify this existing approved and the ECC is issued. practice. This undermines the importance of the ECC, and any analysis presented in the EIA (or any analysis of alternate sites) would only exist to justify the site already selected for the project. This greatly diminishes the value of any analysis of alternatives. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 76 ECR 1997 ECR 2017 (draft) Comments and Recommendations The DoE has no procedural The proposed ECR offers detailed This is a useful amendment as it provision for registration and no procedural provisions for enlisting will encourage the development requirement for consultants’ or consultants and consulting of a competent private sector consulting firms’ qualifications. firms that would be competent for carrying out EAs. The role to prepare EIAs/IEEs/EMPs. of enlisted firms can be further Procedures have been laid out for expanded to environmental the selection criteria, qualification monitoring activities where the requirements, and eligibility of DoE may delegate these firms such consulting entities. to carry out environmental monitoring on their behalf. Did not have a guideline for EIA Schedule 15: A guideline for EIA In Bangladesh, consultants usually preparation. preparation is provided. prepare EIA reports based on sectoral guidelines, donor agency, guidelines, and so on. However, a unified framework for preparing EIAs will always be helpful. DoE officials are not involved in In the proposed ECR, DoE The new ECR will certainly seek verifying project information after officials need to verify project/ additional commitments from the the project proponent applies for industry information and the project proponent in applying environmental clearance. adoption of pollution control environmental safeguards to their measures by making site visits. For projects. But it also demands Yellow, Orange, and Red category additional oversight on behalf projects, the DoE verifies the of the DoE. This might require project location shortly after the additional staff for regulatory application is submitted for site purposes. clearance. When the site clearance is issued and after the project proponent finishes construction, the DoE official visits the site again to verify the conditions and EMP commitments (i.e., ETP installation), and based on that, environmental clearance is issued. For Red category projects, the DoE official is also invited to attend public consultation meetings. 77 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh ANNEX C COMPARISON OF THE DOE’S ORGANIZATIONAL STRUCTURE WITH THOSE OF OTHER COUNTRIES Figure C-1 shows Bangladesh’s DoE organogram. It is important to notice that Air Quality Management and Climate Change are the only functional directorates. However, the current structure does not have specialized entities that are responsible for other priority environmental issues, including water or soil pollution, and management of chemicals. Also, while Environmental Clearance and Monitoring and Enforcement are separate directorates, the staff under them are not separate, which can potentially result in an unclear division of responsibilities and limited accountability. FIGURE - C-1: ORGANOGRAM OF BANGLADESH’S DEPARTMENT OF ENVIRONMENT Director General Additional Director General Headquarters Divisional /Regional Office Director Director Director Director Director Director Director Director Director (Climate Change (Natural Resources (Administration) (Environmental (IT) (Air quality (Planning) (Monitoring and (Legal) and International Management) Clearance) management) Enforcement) Convention) Director Director Director Director Director Director Director Director Director Director Chittagong Chittagong (Metro) Chittagong (Lab) Dhaka (Regional) Dhaka (Metro) Dhaka (Lab) Rajshahi Khulna Sylhet Barisal (Regional) District Office District Office District Office District Office 1. Deputy Director- Cox’s Bazar 1. Deputy Director- Dhaka 1. Deputy Director- Rangpur 1. Deputy Director- Jessore 2. Deputy Director-Chittagong 2. Deputy Director- Gazipur 2. Deputy Director- Rajshahi 2. Deputy Director- Kushtia 3. Deputy Director- Feni 3. Deputy Director- Narayanganj 3. Deputy Director- Bagerhat 4. Deputy Director- Noakhali 4. Deputy Director- Manikganj 5. Deputy Director- Chadpur 5. Deputy Director- Narsingdi 6. Deputy Director- Comilla 6. Deputy Director- Munshiganj 7. Deputy Director- Brahmanbaria 7. Deputy Director- Tangail 8. Deputy Director-Maymensingh 9. Deputy Director- Faridpur In contrast with Bangladesh’s DoE, Malaysia’s Department of Environment and Thailand’s Pollution Control Department are largely structured around functional areas (see Figures C-2 and C-3). In both of these cases, specialized divisions are responsible for managing air quality, water pollution, and hazardous substances. These agencies show potential organizational arrangements from which the DoE could draw and customize as needed to fit the Bangladeshi legal and administrative structure and requirements. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 78 FIGURE - C-2: ORGANOGRAM OF MALAYSIA’S DEPARTMENT OF ENVIRONMENT Director General Deputy Director Deputy Director General General Integrity Unit Legal Unit (Development) (Operations) Assessment Water and Marine Division Division Strategic Hazardous Communications Substances Division Division Environmental Air Institute Division Information Enforcement Technology Division Division Administration and Finance State Governments Source: Based on information from the DoE website at https://www.doe.gov.my/portalv1/en/tentang-jas/struktur-organisasi/bahagian-ibu-pejabat. 79 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - C-3: ORGANOGRAM OF THAILAND’S POLLUTION CONTROL DEPARTMENT Director General Planning and Evaluation Division Deputy Director General (3) Legal Division Office of the Secretary Environmental Quality and Laboratory Division Water Quality Management Bureau Inspection and Enforcement Division Air Quality and Noise Management Bureau Coordinating Center for Environmental Law Enforcement Management System Waste and Hazardous Substances Development Group Management Bureau Internal Audit Source: Pollution Control Department, n.d. In the middle to longer term, the GoB might consider establishing separate, specialized agencies with mandates for environmental enforcement and approving environmental licenses, respectively. Countries outside the Asia region—such as Mexico and Peru—provide examples of how these agencies might operate. In Mexico, the environmental enforcement agency PROFEPA has contributed to the environmental sector’s legitimacy by providing efficient, neutral, and unbiased enforcement while eliminating potential conflicts of interest within sectors. This agency can also implement incentives for public-private partnerships to improve environmental management systems and programs to disclose environmental performance indicators that promote demand-driven environmental improvement in the private sector. For 2018, PROFEPA had a staff of 2,242 and a budget of approximately US$52.6 million (GoM 2018). PROFEPA’s organizational structure Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 80 includes specialized units in charge of environmental audits, industrial inspections, and enforcement of laws and regulations governing natural resource management (see Figure C-4). PROFEPA has offices in each of Mexico’s states. FIGURE - C-4: ORGANOGRAM OF MEXICO’S ENVIRONMENTAL ENFORCEMENT AGENCY Environmental Attorney General Deputy Attorney Deputy Attorney Deputy Attorney Deputy Attorney General General of Industrial General of Natural General of Environmental Audit Inspection Resources Legal Affairs General Directorate of General Directorate of General Director of General Directorate of Environmental Impact Federal Crimes against Audit Operations Industrial Technical and Federal Maritime the Environment and Assistance Land Zone Litigation General Directorate General Directorate General Director General Direction of of Inspection and of Control of of Planning and Inspection of Sources Surveillance of Wildlife, Administrative Promotion of Audits of Pollution Marine Resources and Procedures and Coastal Ecosystems Consultation General Direction General Directorate General Directorate of of Environmental of Environmental Forest Inspection and Inspection in Ports, Complaints and Social Surveillance Airports and Borders Participation Representations in States Source: SEMARNAT 2017. Peru provides a second example of institutional separation of environmental enforcement from licensing/ certification functions. Environmental oversight and enforcement is looked after by the Agency for Environmental Assessment and Enforcement (Organismo de Evaluación y Fiscalización Ambiental—OEFA), which was established in 2008 as a specialized agency. OEFA’s organizational structure includes units that focus on environmental oversight policies and strategies, and assessment of environmental quality; it has separate, functional units for energy and mines, productive activities, and infrastructure and services (see Figure C-5). 81 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - C-5: ORGANOGRAM OF PERU’S ENVIRONMENTAL ENFORCEMENT AGENCY Board of Directors Secretary General Management Institutional Planning and IT Office Relations and Public Legal Counsel Office Budget Office Engagement Policy and Environmental Environmental Environmental Environmental Supervision in Enforcement and Enforcement Supervision in Supervision in Incentives Assessment Infrastructure and Strategies Energy and Mines Productive Activities Services Source: OEFA 2017. Meanwhile, in 2012 Peru’s government created the National Service for Environmental Certification of Sustainable Investments (Servicio Nacional para la Certificación Ambiental de Inversiones Sostenibles—SENACE) as a technical agency in charge of reviewing and approving detailed EIAs for projects with a national or regional scope that have potentially significant environmental impacts.40 SENACE’s creation aimed to address citizens’ lack of trust in EIAs, and EIAs’ long and bureaucratic procedures (SENACE 2018a). SENACE’s organization includes two functional units responsible for EIAs of natural resources and productive projects, and for those for infrastructure (see Figure C-6). Law 29,968 dated December 19, 2012. 40 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 82 FIGURE - C-6: ORGANOGRAM OF PERU’S NATIONAL SERVICE FOR ENVIRONMENTAL CERTIFICATION OF SUSTAINABLE INVESTMENTS Board of Directors Secretary General Management IT Office Public Legal Planning and Office Engagement Counsel Budget Strategic Management Environmental Environmental of Environmental Assessments of Natural Assessments of Assessments Resources and Productive Infrastructure Projects Projects Figure C-7 depicts the organogram for the Republic of Korea’s Ministry of Environment. Given that this organogram is for the entire ministry of a high-income country, it should not be directly compared with the DoE. However, the organogram might provide insights into how Bangladesh’s MoEFCC could be restructured in the medium to long term, with increasingly specialized units that can tackle the country’s environmental priorities. In the case of the Republic of Korea, different bureaus focus on functional areas. A relevant example is the Environmental Health Bureau, which includes an Indoor Air Pollution, Noise and Asbestos Division that tackles serious environmental health risks that receive little attention in most middle- or low-income countries. 83 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh FIGURE - C-7: ORGANOGRAM OF THE REPUBLIC OF KOREA’S MINISTRY OF ENVIRONMENT Minister Public Relations Team Media Support Team Spokesperson Communication Support Team Vice Minister Audit and Inspection Division General Service Division Inspector General Environmental Investigation Division Planning and Natural Environment Living Environment Water Environment Coordination Office Policy Office Policy Office Policy Bureau ICT Management Nature Conservation Air Quality Water Environment Division Bureau Policy Bureau Policy Division Emergency and Nature and Ecology Clean Air Watershed and Total Load Safety Division Policy Division Planning Division Management Division Policy Planning Biodiversity Air Quality Aquatic Ecosystem Bureau Division Division Conservation Division Planning & Nature Park Air Quality Water Quality Budget Division Division Management Division Management Division Organization and Environment Assessment Transportation Drinking Water and Management Innovation Policy Division Environment Division Sewage Bureau Division Sustainable Development Environmental Impact Climate Change Drinking Water Strategy Division Assessment Division Policy Bureau Policy Division Legal Affairs and Regulations Resources Circulation Climate Change Sewage Division Reform Division Bureau Strategy Division Environmental Resources Circulation Climate Economy Soil and Groundwater Education Team Policy Division Division Division Waste Resources International Cooperation Management Division Division Resources Climate Change Recycling Division Mitigation Team Waste-to-Engery Environmental Health Division Bureau Environmental Economy Environmental Health Policy Bureau Policy Division Environmental Industry and Environmental Damage Economy Division Relief Division Environmental Research and Indoor Air, Noise and Asbestos Development Division Management Division Integrated Permit System Chemical Policy Division Division Task Force for Water Cluster Chemical Product and Biocides Division Task Force Establishment of Institute of Biological Chemical Safety Division Resource Conservation Source: Ministry of Environment of Korea 2017. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 84 ANNEX D HAZARDOUS WASTES IN BANGLADESH —POLICY NOTE Hazardous waste is waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries. Hazardous waste management in Bangladesh comes under the regulatory purview of the Hazardous Waste and Shipbreaking Waste Management Rules of 2011, promulgated under the ECA of 1995 (amended). Hazardous materials (hazmats) encompass both hazardous wastes as well as useful products of a hazardous nature; they are defined in these rules as materials with physical, chemical, reactive, toxic, inflammable, explosive, or corrosive properties that can damage health or the environment. Hazardous materials are classified into five categories (A–E) based on erstwhile BAGA (the Hazardous Waste Designation Decree of the Netherlands) list of Hazardous Substances in Schedule 3 of the rules, as shown in Table D-1. TABLE - D-1: LIST OF HAZARDOUS WASTE CONSTITUENTS WITH CONCENTRATION LIMITS Category Types of Concentration Limit Substance Class A 20 50 mg/kg (20) Class B 30 5,000 mg/kg (30) Class C 17 20,000 mg/kg Class D 9 50,000 mg/kg Class E - Regardless of concentration limit; classified as hazardous waste if the waste exhibits any of the following characteristics: E1 Flammable: Wastes with a flash point of 65.6 degrees Celsius or below. E2 Explosive: Wastes that may explode under the effect of flame, heat, or photochemical conditions. Any other waste of explosive materials included in the Explosive Act. E3 Corrosive: Wastes that may be corrosive, by chemical action, that will cause severe damage when in contact with living tissue. E4 Toxic: Wastes containing or contaminated with established toxic and or eco-toxic constituents. E5 Carcinogenicity, mutagenicity, and endocrine disruptivity: Wastes contaminated with or containing established carcinogens, mutagens, and endocrine disruptors. Source: Hazardous Waste and Shipbreaking Waste Management Rules of 2011, Schedule 3. The 684 specific hazardous chemicals identified are listed in Schedule 1, and a list of 36 industrial processes that produce 109 different types of hazardous wastes are provided in Schedule 2 of the rules. However, Basel classifications are more commonly used now. Bangladesh is a signatory of the Basel Convention (Secretariat of the Basel Convention 1989) and the Stockholm Convention, but hazardous waste management remains a relatively unpublicized aspect of the country’s industrial development. Bangladesh joined the Basel Convention on April 1, 1993, and its 1996 Import Policy Order banned the import of all sorts of waste. 85 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh Nature and Extent of Hazmat Production and its Fate in Bangladesh Data on hazmats were compiled in the regional technical assistance-supported study by the ADB (ADB 2010) on managing hazardous wastes in Bangladesh, Bhutan, Nepal, and India, in which data were mostly from 2007 or earlier. A more comprehensive review of the production and disposal of hazmats in Bangladesh was carried out by the DoE in 2010 (DoE 2010a). Although the report is dated 2010, it provides projected hazmat data for 2012 in some cases. An important finding of this study is the geographical concentration of the industries that produce hazmats in Bangladesh. It clearly emerged from mapping their locations and overlaying—that is, superimposing—one map with the location of one type of industry upon another until locations for all types of hazmat could be seen at a glance. The exercise showed that the Dhaka and Chittagong regions have the highest concentration of hazardous waste-generating industries. Within the Dhaka region, the largest concentration is in the Ghazipur district, followed by Dhaka, Narsingdi, and Narayanganj districts. Data on hazmats available from different sources are listed in Table D-2. TABLE - D-2: INDUSTRIAL HAZARDOUS WASTE IN BANGLADESH FROM SELECTED SECTORS SN Industry Sector Est. Qty. Solid Year Basel/ USEPA Comments Waste (ton/year) Category 1. Plastic waste2 633,127 2016 - About 51% recycled informally 2. Textiles2 2,810,000 2012 - 3. Medical waste2 19,578 2012 Y1, Y2, H6.2 4. Tannery2 33,502 2012 Y21 5. Pesticide 460 Class 1B, II, III formulation2 (USEPA) 6. Fertilizer 1,248 2012 Y22, Y23 7. ULABsa 3,420 2006 - Quantity is for hard lead recovered; major expansion has taken place in this sector since the report, with 59 battery manufacturing units in the country 8. E-waste (excluding 310,000 2006 - This sector has also shipbreaking)b undergone major expansion in recent years Notes: a. DoE 2010b; b. Islam 2016. It is quite apparent that most of the data are not recent and need updating. It is likely that most of the data are also underestimates, as recent industry growth has not been considered. Some data also do not cover the whole country (e.g., in the case of plastics) and some high pollution sectors have been left out (e.g., paper and pulp, where a number of toxic chlorine compounds are used, or stocks of hazmat from earlier use—e.g., PCBs from the power sector are reportedly around 100,000 tons). Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 86 The nature of hazards in waste is also changing. It has now been more than 50 years since Bangladesh’s building industry started to use PVC pipes in large scale; these are now coming into the waste stream. Burning PVCs can produce dioxin, which is one of the most poisonous substances known to humans. Overall, the quantity of hazmats produced is quite substantial and causing considerable economic externalities, as can be guessed from the examples in other countries. Currently, some hazardous wastes are being recycled in Bangladesh. ULABs are by far the most widely recycled hazardous waste category, with an estimated 90 percent being recycled (SEMP 2006). However, informal ULAB recycling facilities, estimated at more than 1,100 across Bangladesh, are a major source of soil and air pollution, while there are only a few large formal plants with adequate environmental management (SEMP 2006). In a recent survey, reportedly more than 50 sites contaminated with lead have been found. There are reportedly more than 3,000 small factories that recycle plastics and solid waste from the textile sector. Recycling hazardous wastes has a lot of benefits, including reducing the consumption of raw materials and reducing the volume of waste materials. Such treatments also reduce the threat from harmful chemicals. Meanwhile, in many developing countries, including Bangladesh, hazardous wastes that are not recycled are disposed in regular landfills, most of which are not properly designed or secured. This results in considerable amounts of hazardous materials seeping into the ground and entering the natural hydrologic system. Hazmat landfills must have impervious linings to avoid groundwater contamination. In many cases, such wastes are being dumped in rivers and unoccupied or fallow lands, contributing to environmental degradation and health issues. In some cases, they are burned in open fires, producing toxic fumes. Standard global practice for handling hazmats is to process them in treatment, storage, and disposal facilities (TSDFs), where they undergo different treatments to stabilize them before disposal. TSDFs can be equipped to recycle flammable materials (e.g., plastics) into industrial fuels. Some hazardous waste types may be eliminated using pyrolysis in ultra-high temperature electrical arcs, in inert conditions to avoid combustion. This treatment method may be preferable to high temperature incineration in some circumstances, such as in the destruction of chlorinated organic waste types, including PVC, PCBs, and pesticides, expired drugs/antibiotics, and other persistent organic pollutants. A review of the situation in India shows that TSDFs can be sustainably operated in the private sector by charging hazmat-producing industries processing fees, which is actually an application of the polluter pays principle. Considering Bangladesh’s geographical distribution, as noted above, there is a clear need for at least two TSDFs in the country—one each in the Dhaka and Chittagong zones. Going by the Indian experience, a TSDF will need about 50 or more acres of land, which is a major constraint in Bangladesh. According to the Environmental Information System (ENVIS) Centre on Control of Pollution Water, Air and Noise under the Indian Central Pollution Control Board, there are currently 26 general purpose TSDFs in India, all of which are in the private sector, probably under some sort of public-private partnership. As this is a new line of business in Bangladesh, support from the GoB in the form of land allocation and lower cost financing may help kickstart the establishment of TSDFs; this is much needed for both protection the environment and reducing the economic externalities of hazmats. Recommendations In the light of data on hazmat wastes in Bangladesh and other issues discussed above, the following recommendations can be made: 1. Study the current status of hazmat production. The discussions here show major gaps in terms of knowledge about the issue. As such, a comprehensive study to update knowledge on the current status and trends related to hazmats in Bangladesh—including their nature, quantity, treatment, and disposal—is urgently needed. 87 Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 2. Set up common TSDFs. Even without any further study, the need for two TSDFs—one each in the Dhaka and Chittagong regions—can be foreseen. Going by the Indian experience, a public-private initiative with service charges for hazmat processing may be sustainable. As this is going to be a new line of business in Bangladesh, support from the GoB in the form of land allocation and lower cost financing may help kickstart the establishment of TSDFs. Donor support may also be sought to this end. Smaller TSDFs may be needed in industrial estates/EPZs, and feasibility studies for such TSDFs may be conducted. 3. Review and further develop a legal framework. Although the current Hazardous Waste and Shipbreaking Waste Management Rules of 2011 are a good basis for hazmat waste management activities in the country, further development will be needed for the sector’s optimal operation and management. The classification system for hazmat based on BAGA needs to be changed to make it compatible with Basel. Although the DoE advocates the 3R system, it has no clear link to any existing law. Adopting something like the U.S. Resource Conservation and Recovery Act could provide a link to waste generators with the hazardous waste management system. Including some provision of public funds to address legacy pollution clean-up and remediation of closed and abandoned hazardous waste sites, similar to that of the U.S. Comprehensive Environmental Response, Compensation, and Liability Act, may also be useful. Rules for operational guidelines for TSDFs and fee structures may also be needed. As such, it may ultimately be necessary to replace the current rules under ECA to a stand-alone hazmat and 3R law. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh 88 1818 H Street, NW Washington, D.C. 20433 USA Telephone: 202-473-1000 Internet: www.worldbank.org/environment