Report No. 36945-BD Bangladesh Country Environmental Analysis (In Two Volumes) Volume I: Main Report August 23, 2006 South Asia Environment and Social Development Unit South Asia Region Document of the World Bank TABLEOFCONTENTS ExecutiveSummary ........................................................................................................................ i I EnvironmentalManagement:aKeytoGrowthandPovertyReduction............................. . I1. i I11. EnvironmentalPriorities for Additional Action ................................................................. Selecting Environmental Challenges for Analysis ............................................................. ii IV. ... ii V. EnvironmentalRisks to Health aMajor Contributor to the Burdenof Disease ...............111 ProtectingEnvironmental Quality inDhaka....................................................................... v vi VI1. EnvironmentalGovernance: AnOver-Arching Agenda................................................... VI. NaturalResourcesunder Pressure..................................................................................... . VI11.Conclusion: KeyActions andWorld BankSupport........................................................ vii ... vlii Chapter 1:Context and Objectives .............................................................................................. I. 1 I1. EnvironmentalChallenges to Poverty Reduction............................................................... I11. Objectives ofthe CEA........................................................................................................ The Responseof the Government o f Bangladesh andDevelopmentPartners ...................43 1 IV. Preparationofthe CEA: Scope andProcess....................................................................... 5 V. Structure ofthe Rep0rt........................................................................................................ 5 Chapter 2: EnvironmentalHealth ................................................................................................ I. EnvironmentalHealth: RiskFactors and Costs.................................................................. 7 7 I1. I11. Water Supply and Sanitation ............................................................................................ 10 Air Pollution..................................................................................................................... 16 IV. ReducingExposureto Toxic Pollutants............................................................................ V. EnvironmentalHealth: Recommendations andAreas for World Bank Support ..............20 24 Chapter 3: Management ofWater Quality inDhaka ............................................................... . 27 I1. I Dhaka:aMega-CityunderStress..................................................................................... 27 I11. The Economic and Social Costs ofWater Degradation.................................................... A Triple Threat: Contaminationofthe Air. LandandWater ........................................... 27 IV. Policy andInstitutionalFactorsAffecting Water Quality ................................................ 28 32 V. Responsesto Water Quality Issues inthe Dhaka Area..................................................... V. Water Quality inDhaka: Recommendations and Areas for World Bank Support ...........34 39 Chapter 4: Management of Capture Fisheries .......................................................................... 41 I. The State of Capture Fisheries.......................................................................................... 41 I1. I11. Impacts of Capture Fisheries Decline............................................................................... 46 IV. Capture Fisheries: Recommendations andAreas for WorldBank Support...................... Policies andInstitutions for Capture Fisheries Management ........................................... 48 50 Chapter 5: SustainingSoil Quality ............................................................................................. I ChallengesFacingAgricultureinBangladesh.................................................................. . 53 I1. 53 I11. Evidence ofDeclining SoilProductivity andSoil Quality............................................... Trends inAgricultural Productivity.................................................................................. 54 IV. 57 V. Implications o f Climate Change....................................................................................... Sustaining Soil Quality: Recommendations andAreas for World Bank Support ............62 64 SRDI Soil Research and Development Institute UP UnionParishads STEDs Septic Tank Effluent Disposal Systems WARP0 Water Resource Planning Organization PCB Poly-Chlorinated Biphenyls WASA Water Supply and Sewerage Authority UDCC Upazila Development Coordination WATSAN Water Supply and Sanitation Committee UNICEF UnitedNations Children's Education Fund WHO World Health Organization UNO Upazila NirbahiOfficer WSSD World Summiton Sustainable Development Vice President Praful Patel, SARVP Country Director : Christine I. SACBD Wallich, Sector Director Jeffrey S. Racki (Acting), SASES Sector Manager Jeffrey S. Racki, SASES Task Leader Paul Jonathan Martin, SASES ........................................................ I. Chapter 6: Institutions for EnvironmentalManagement 66 I1. -66 I11. The Ministryo f Environment andForest: Custodian ofthe Environment .......................... The Institutional Context for Environmental Management ................................................ 67 IV. Environmental Management at Sub-National Levels .......................................................... 73 V. Environmental Management inOther Sectors: Incentivesand Coordination...................... 75 80 VI. Role ofthe Judiciary ............................................................................................................ NGOs and Civil Society....................................................................................................... 81 VII. StrengtheningInstitutionsfor EnvironmentalManagement: Recommendations andAreas81 for World Bank Support....................................................................................................... Chapter 7: EnvironmentalConstraintsto Growth Prioritiesfor AdditionalAction . ..........88 I EnvironmentalRiskstoHealth:theNeedtoBetterAddressAirQuality............................ I1. . 89 I11. 90 Natural Resourcesunder Pressure: ProtectingCapture Fisheries........................................ ProtectingEnvironmentalQuality inDhaka: a Focus onWater Quality............................. IV. 90 Environmental Governance: an Over-Arching Concern...................................................... 91 V. Priorities for Additional Action andWorld Bank Support .................................................. 92 Appendices I DhakaEnvironmentProgramme:PrioritizedPortfolioofWaterQualitySolutions . 11 .............................................................................94 I11. WorldBankCountry Assistance Strategy for BangladeshFY06-09: SelectedProducts and Organogram ofthe Department o f Environment 96 Key Environmental Management Outcomes ....................................................................... 97 ListofBoxes 2.1 A Comparative Assessment ofIAPinBangladeshandIndia............................................ 17 2.2 The Successfully Promotion of ImprovedStoves inChina................................................ 18 2.3 Persistent Bio-accumulative Toxics - Lead andMercury EmissionsinBangladesh.........20 2.4 The Stockholm Convention on Persistent Organic Pollutants............................................ 21 3.1 Responsibilities of Government Institutions RegardingDhaka Air Quality...................... 33 4.1 Savingthe Hilsa - ShowingIt Canbe Done....................................................................... 43 4.2 Fisheries Management inthe Sundarbans.......................................................................... 46 5.1 59 71 Functioningof DivisionalOffices ofthe DOE................................................................... Governance inBangladesh................................................................................................. Soil Mapping inBangladesh.............................................................................................. 6.1 6.2 75 6.3 Industrial Policy (1999) - a Glass HalfFull....................................................................... 78 6.4 Environmental Management at LGED............................................................................... 79 6.5 Catalyzing Cross-Sectoral Action - the Case of Diesel Emissions .................................... 80 6.6 Strategic Plan o fthe DOE................................................................................................... 83 ListofFigures 1 The Economic Costs of EnvironmentalDegradation............................................................. v 2.1 8 30 Fisheries Productionbymajor Sub-sector........................................................................... Pollution Hotspots inthe DhakaRiver and Canal System inthe Dry Season..................... Contributing Factors to Environmental HealthRisks ............................................................ 3.1 4.1 42 5.1 55 Productiono fMajor Cereals inBangladesh(1960-2004) ................................................... Growthof Total Cereals Output (In'000 Tons) ................................................................... 5.2 56 5.3 Index of Total Grains Production (1960 = 100)................................................................... 56 5.4 Environmental Concerns ofFarmers ................................................................................... 61 6.1 Public EnvironmentalExpenditures..................................................................................... 76 6.2 Proposed Strengthening of DOE........................................................................................... 83 7.1 The Costs of EnvironmentalDegradation............................................................................ 88 Listof Tables 2.1 Bangladesh: Share of Disability Adjusted Life years (DALYs)Lost by Cause and EnvironmentalContribution .................................................................................................. 7 2.2 Potential Reductions inMortality and Morbidity, andEconomic Savings by Reducing Exposure to Environmental Health Risks .............................................................................. 9 3.1 Water Quality inthe Riverand Canal System aroundDhaka. 2003-2004........................... 31 3.2 RiverCommittee Proposals for Water ResourceManagement inDhaka............................ 35 4.1 EstimatedPhysical and FinancialLoss due to Declining Production.................................. 48 6.1 Trends inEnvironmentalExpenditure ................................................................................. 77 References..................................................................................................................................... 98 Volume I1 TechnicalAnnex: . HealthImpactsofAir andWater PollutioninBangladesh ACKNOWLEDGEMENTS We would like to thank the staff of the Ministry o f Environment and Forest for their guidance and support inthe preparationo f this report. This report is the product of a team managed by Paul Martin and including Poonam Pillai, Sameer Akbar, Priti Kumar, William Collis, M. Khaliquzzaman, Bilqis Hoque, John Carter, Enamul Haque, John Gaunt, Anwarul Islam and Mainul Huq. Helpful advice and contributions were received from a number o f colleagues across the World Bank including Richard Damania, Adriana Damianova, Susmita Dasgupta, Kseniya Lvovsky, David Meerbach, Khawaja Minnatullah, Mohinder Mudahar, Stefan0 Pagiola, S.A.M.Rafiquzzaman, Suphachol SuphachalasaiandRonaldZweig. Valuable guidance was provided by the peer reviewers, Carter Brandon, Ani1 Markandya and Emesto Sanchez-Triana. Assistance with document preparation was providedby Vinod Ghosh. The report was prepared under the overall guidance of Jeffrey Rack, Acting Director, South Asia Environment and Social Development Department, and Christine Wallich, Country Director for Bangladesh. Executive Summary I.EnvironmentalManagement:aKeytoGrowthandPovertyReduction 1. Bangladeshhas achieved steady economic growth o f almost 5% annually over the last decade, andwhile halfthe population still lives inpoverty, this represents an improvement .from 59% in 1990. Bangladeshhas also demonstrated significant success in achieving the human development targets o f the MillenniumDevelopment Goals (MDGs). Inmakingfurther progresstowardspovertyreductionandhumandevelopmentgoals, however, environmental challenges to natural resource productivity and humanhealth will become increasingly important. 2. Although the total burdeno f disease inBangladeshi s comparable to other South-East Asian countries with highmortality rates, the share attributable to respiratory infections and diarrhoeal disease, both associated with poor environmental conditions, i s significantly higher. Environmental healthrisks are also increasingrapidly as a result o f industrialgrowth, which i s the fastest inSouthAsia, and urbanization, which i s occurring at double the rate o f India and Pakistan. Almost all future population growth, forecast to be some 100million over the next fifty years, i s expectedto occur inurban areas, underliningthe growing importance o f addressing urbanand industrial contamination. 3. Withpopulationdensity among the highest inthe world, pressure onnatural resources inBangladeshi s necessarily high. Two-thirds o fthe land area i s under crops, the highest proportion in South Asia. Cropping intensity i s also the highest inthe region, having increasedby 25% over the last thu-tyyears, and surveys provide evidence that agricultural inputsare imbalanced andnutrient miningis occurring. The share oflandareaunder forest cover i s the second lowest inthe region, with natural forest cover halving since the 19603, and most natural forests now significantly degraded. Protected areas cover the smallest share o f any country inSouthAsia, and pressure on wetlands and aquatic life i s a particular concern. As detailed inthe Country Water Resources Assistance Strategy,' water quality and quantity are key determinants o f outcomes inmany sectors o f the Bangladeshi economy, with bothunder pressure from industrial, urbanand agricultural growth within the country and upstream. Bangladeshi s highly vulnerable to the projected impacts o f climate change, which will increase the already highrisk o fdisasters, exacerbating existing vulnerabilities bothto flooding and drought, and threatening agricultural productivity incoastal areas that face increasing salinity. 4. While emphasizing that economic growth i s essential to reduce poverty, Bangladesh's National Strategy for Accelerated Poverty Reductioncautions that "A careful balancing act mustbe orchestratedwhere economic growth i s maximised without compromising environmental protection. ..''.2 The Strategy explicitly recognizes boththe dependency o f the poor on natural resources, and the vulnerability o f the poor to environmental healthrisks. This Country Environmental Analysis (CEA) reinforces the message that the linkages inthe balancing act work inbothdirections: not only can economic growth compromise environmental protection, but environmental degradation threatens World Bank, 2005 National Strategy for Accelerated PovertyReduction, 2005, Section 5.H i economic growth. Together, the environmental impacts considered inthis report account for economic losses equivalent to more than 4% of GDP, and these costs are felt most severely bythe poor. 11. SelectingEnvironmentalChallengesfor Analysis 5. This CEA is intendedto assist the Government, civil society and development partners of Bangladesh inidentifylng and addressing critical environmental constraints to sustainable, poverty-reducing growth. The initial set o f issues chosen for analysis was selectedjointly by the Ministryo f Environment and Forest (MoEF) and the World Bank based on their relevance to growth and poverty reduction, as well as a consideration o f the value of new analysis. These criteria led to a focus on five priority issues inthe CEA, as follows: 0 environmental risks to humanhealth; 0 protection o f water quality inDhaka; management of capture fisheries; 0 sustaining soil quality; and 0 strengthening institutions for environmental management. These selected topics do not constitute an exhaustive list o f environmental issues in Bangladesh. Urbanenvironmental degradation, for example, extends beyond Dhaka; but withits population expected to grow fivefold inthe next fifty years, the capital is clearly a priority, andprovides lessons relevantto other cities. Similarly, natural resource concerns extend beyondthe selected priorities of capture fisheries and soil quality, with forest management a prominent pending issue, as is adaptation to climate change. 6. Initial analyses of the selected issues were considered during a series of consultative discussions with key stakeholders, held inDhaka inDecember, 2004. Subsequently, the draft CEAwas discussed inJuly, 2005, at a workshop inDhaka convened byMoEF, and inauguratedby the Minister of Environment and Forest. The final version of the CEA reflects the agreements reached duringthe workshop, andprovides recommendations for more effective environmental management ineach o f the five selected priority areas. 111. EnvironmentalPrioritiesfor AdditionalAction 7. The estimated economic losses associated with the sources o f environmental degradation selected for analysis inthe CEA amount to more than 4% of GDP. The relative shares of the principal sources are indicated inFigure 1, below. Within the set of issues selected for analysis, a number of concerns are being addressed throughinitiatives that are already underway or planned, and a few pose risks that are relatively less pressing inthe near term. The following three issues emerge, however, as priorities currently receiving insufficient attention given their relative significance: 0 the threat o f indoor andurban air pollutionto humanhealth; 0 the need to better control urban and industrial effluent inDhaka; and, the continuing decline of capture fisheries. 11 inrednirhthese three Fisheries 2 5% Psllutron 2% Share of GOP Share by Source IV, E ~Risksto Health: a ,Ilajor C~ ributor lo the Burdenof ~ ~ ~ Disease ~ ~ sks couldrcsult in .". I l t Improving Air Quality 10. Importantefforts are underway to address a range o f environmental health concerns inBangladesh,inparticular throughtheTotal Sanitation Campaignandavarietyofwater supplyinitiatives. IndoorAir Pollution (IAP) remains almost entirely ignored, however, and urban air quality continues to deteriorate, despite atemporary improvement following the 2003 banontwo-stroke three-wheelers inDhaka. This report estimates that the respiratory infections and diseasecausedbypoor air quality, both indoor andurban, may contribute up to 10%o fthe total burdeno f disease, equivalent to the diarrhoeal diseasecausedby inadequate access to safe water, lack of sanitation andpoor hygiene. Reducing Exposure to Indoor Air Pollution 11. Inhalingsmoke from burningbiomass canhave bothtemporary andpermanent consequencesfor health, andrecognition o fthe health impacts o f IAPi s growing worldwide. Poor households inBangladesh dependheavily on wood, dung and other traditional fuels for cooking. As a result, the health impacts o f IAP are significant, estimated to account for as much as 8% o fthe total burdeno f disease. Further evidence for concern i s providedby a recent World Bank study, which detecteddangerously highconcentrations o fparticulates in indoor air for manypoor households inBangladesh. Particularlyhighlevels o f exposure to IAPwere recorded for womenandchildrenunderfive. 12. Opportunities should be explored to integrate efforts for the mitigation o f IAP into existing programs through the provision o fboth cleaner technologies and public information. Better ventilation and longer outdoor time for children may reduce IAP exposure, but achieving suchbehaviour change will require Government support for a public education effort explaining the healthbenefits. While support for cleaner fuel and cooking technologies may include a subsidy, at least ininitial stages, the longer term goal should beto establish demandfor the provisionof suchtechnologies bythe private sector. The World Bank plans to provide further technical assistanceto explore sustainabledeliverymodels for the information and technology necessaryto reduce exposure to IAP. Expanding Efforts to Manage UrbanAir Quality 13. Upto 10%ofrespiratory infections and diseaseinBangladeshmaybe attributable to urbanair pollution. While the problemi s most severe inDhaka, bothbecauseair quality i s worse andmore people are exposed, air pollution i s a growing concern inother major cities. Measurements inDhaka indicate that particulate matter i s the most significant pollutant, and mobile sourcesremainthe priority for emissions control. Unless there i s amuch stronger program o f actions than at present, encompassingmajor secondary cities as well as Dhaka, urbanair pollutionwill continue to worsen inline with the projected rapidrate o f urbanization and rising incomes. Suchactions should focus on gross diesel polluters, fuel quality, andthe expansion o f air quality monitoring bothwithin the capital andto other cities. To help develop and implementsuch aprogram, the World Bank will continue to provide support for the Air Quality Management Project, andpossibly a follow-up operation. iv V. ProtectingEnvironmentalQualityinDhaka 14. The environment o f the capital city faces the triple threat o f air pollution, inadequate solid waste management, and contamination o f surface water. While initiatives are underway to better manage air quality and solid waste, little has yet been done to improve water quality, identified as a priority for World Bank engagement inthe BangladeshCountryWater Resources Assistance Strateg~.~The total economic cost o fthe poor management o f water resources inDhaka i s estimated at US$670 million annually, includingimpacts on human health, as well as industrial and natural resourceproductivity. Unless prompt action i s taken, these costs will continue to rise inline with Dhaka's continuing rapid growth, which suggests that the city may double inpopulationby2015, potentiallymakingit the fourth largest city in the world. Giventhat economic activity inDhaka contributes about one-fifth o f the nation's GDP, environmental constraints to growth inthe capital constitute a national priority. TheImpacts of Deteriorating Water Quality 15. Dhaka surface water is invery poor condition, especially inthe dry season when dilution o f contaminants i s drastically reduced. There i s only one sewage treatment plant at Pagla which i s currently operating below capacity because o f sewerage system failures, and few industries operate effluent treatment systems. Almost all the waste from humans, industry, andmillions o ffarm animals, alongwith tonnes o fpesticides and fertilizers, make their way into Dhaka's surface water untreated. As a result, many sections o fthe rivers and canals inthe city and surrounding areas are biologically dead duringthe dry season, with most o f this water unfit for any humanuse and likely to be dangerous to livestock. A particular concern inthe dry season i s the highlevel o f ammonia inthe raw water usedby the SaidabadWater Treatment Plant, threatening the plant's ability to treat water to drinking quality standards. All Dhakaresidents are impacted to some extent by deteriorating water quality, butthe most vulnerable are the poor, who have few options for accessing clean water andlittle ability to move away from offensive locations next to pollutedponds, canals, and rivers. Improving Water Quality: a Strategic Framework and Promoting Compliance 16. Interventions to improve the quality o f surface water inDhakaneed to fit within an integrated strategy addressing water quality and supply, sanitation, and flood management, all as part o f the broader urbanplanningframework. Poor environmental quality cannot be addressed by environmental authorities alone, but will require cross-sectoral coordination. An important element o fthe strategic framework will also be public provision o finformation to raise awareness o f the causes and impacts o fpoor water quality, and to build support for the necessary investments andregulatory enforcement. Industrial discharges mustbe reduced ifsurface water qualityistobeimproved, whichwillrequire stricter enforcement of environmental clearance conditions and effluent standards. Greater regulatory and societal pressure will also stimulate demand for low cost waste minimization initiatives, which could be provided as part o f a broader programo f compliance promotion. World Bank, 2005 V Investing in Waste Treatment 17. Improving the quality o f surface water inand around Dhaka will require significant public andprivate investment. The rehabilitation o f the existing sewerage and drainage system i s alone projectedto cost about US$lOO million. Attracting private resources will require predictable andtransparent enforcement, as well as the recovery o f costs for urban services. Inresponse to the Government's request, the Bank i s helpingprepare a project to improve water supply, sewerage, sanitation and storm water drainage services inDhaka. A proposed separate initiative to strengthenthe management o fwater resources will supplement these investments with support for low cost solutions targeting industrial effluent. Environmental compliance initiatives will form components o fboththese projects, as well planned support for private sector development. VI. NaturalResources under Pressure 18. Withpopulationdensity amongthe highest inthe world, pressure on natural resources inBangladeshi s necessarily high. Two-thirds o f the land area i s under crops, the highest proportioninSouth Asia, and the share under forest cover i s the second lowest inthe region. Deforestationinthe 1980's averaged 3.3% per year, and in 1989 the Government issued a moratoriumon felling innatural forests which continues to date. Official figures indicate a net rate o f reforestation o f about 1% annually duringthe 1990's, but the major areas o f natural forest remain significantly degraded. Protected areas cover the smallest share o f any country inSouthAsia, although pressure on biodiversityi s close to the regional average, with approximately 17%o f mammal species and 4% o f bird species under threat. 19. Agriculture accounts for some 21% o f GDP, and the ability o f soil to sustain agricultural productionis an issue o f national concern. Declines inrice yields insome areas o f Bangladeshinthe mid-1990s ledto a decline insoil productivity being inferred. Analysis o fmore recent data indicates, however, that yield trends are stable or increasing, andthat earlier assessments were influencedby a period inwhich yields were below trend. Consequently it does not appear that agricultural production i s declining as a result o f a reduction insoil productivity. There remain causes for concern, however, including evidence that fertilizer inputsare imbalanced andnutrient miningi s occurring, which suggest that greater attention to the monitoringo f soil quality is warranted. Capture Fisheries: the Threat of Co.llapse 20. Bangladesh's fisheries are estimated to provide two-thirds o fthe country's animal proteinneeds, which i s twice the regional average andthe seventhhighest inthe world. Capture fisheries and associated wetlands play a particularly important role inthe nutrition and welfare o fthe poor. There i s general consensus, however, that inland and coastal capture fisheries are indecline. Threats include losses o f floodplain habitat due to agriculture and urbanization, lost connections along critical fishmigrationpathways, significant reductions in dry seasonriver flows, over-fishing, andrapidly increasing industrial, human and agricultural pollution. Almost 30% o f all inlandfish species are insome danger o f extinction, and there i s a fear that the inlandmajor carps, IndianSalmon and other coastal inshore fisheries, may be indanger o f collapse. The consequences o f a collapse would impact every citizen, but in particular the poor. vi Reversing the Decline 21. As with allbiological systems, recovery o fthe capture fisheries ispossible ifpolitical will combines with good management. By late 2004 a remarkable recovery o f Hilsa was seen, most likely as a result o f Government management activities. The actions neededto reverse the decline o f Bangladesh's capture fisheries are reasonably clear, and a framework for their implementation i s providedby the Government's draft InlandCapture Fisheries Strategy. Within this framework, the key priorities to ensure the sustainable productivity o f capture fisheries are (i)protecting dry seasonwater flows; (ii) establishingboth large and small sanctuaries; (iii)developing and implementingfisheries management regulations; (iv) adoption o f an Integrated Coastal ResourceManagement framework; (v) enhanced monitoring o f fisheries; and (vi) reducedbarriers to the import o f fish. The development o f this strategy was supported by the World Bank through the Aquatic Biodiversity Conservation Project and the FourthFisheries Project, and the Banki s preparedto provide &her assistance to support implementation o f the strategy and to strengthen community management o f fisheries. The Bank i s also preparedto support the development o f a strategic action plan for the management o f marine and coastal resources inthe Bay o f Bengal, for which an ecosystem approachwould be adopted to foster regional collaboration inaddressing the transboundary issues. VII. EnvironmentalGovernance:An Over-ArchingAgenda 22. Across all o f the issues examined inthe CEA, an over-arching theme that emerges i s the need to improve environmental governance to strengthen incentives for behaviour and investments that lead to better environmental quality. The most important governance elements to support such incentives are access to environmental information, transparency and consultation for accountable decision-making, adequate institutional capacity for credible enforcement, and economic policies that promote improved environmental performance. Access to Environmental Information andAwareness of Environmental Risks 23. The current paucity o f environmental information and understanding inBangladesh constrains decision-making at all levels. At the household level, for example, greater awareness o fthe risks o f indoor air pollutioncould significantly reduce exposure through simple changes inbehaviour. Nationally, the sustainable management o f capture fisheries requires informationon necessary dry season flows, and the monitoring o f soil productivity depends on the development o f appropriate indicators o f soil quality. Greater accessto environmental information and understanding o f the impacts o f degradationwill also create demand for environmental investments. Public investment inthe necessary infrastructure to protect water quality around Dhaka will require strong civil society support, basedon an understandingo f the costs o f inaction. Private investment to control pollution will require public pressure for compliance, basedon informationregarding sources o f pollution and their performance. Transparency and Consultationfor Accountable Decision-Making 24. Transparency and public consultation are essential elements o f environmental decision-making, strengthening the accountability o f environmental institutions and thereby buildingtheir credibility. There is considerable scope to introduce greater transparency and vii broaden consultation inenvironmental management inBangladesh, not least inthe core function o f reviewingEnvironmental Assessments (EAs). At the local level, for example, the issuance o fNo Objection Certificates could be subject to consideration by an open meeting o f the UnionParishad, and at the national level all EA information should be publicly available, with high-riskprojects presented for public review. Institutional Capacityfor Credible Enforcement: Strengthening the Role of theDOE 25. As the credible threat o fregulatory enforcement is centralto environmental governance, so too is the establishment o f the institutional capacity to deliver such enforcement. For this reason, implementation o f the Department o f Environment's (DOE'S) Strategic Plan i s essential to strengthen environmental governance inBangladesh, as it will provide the DOEwith the resources andincentives it needs to fulfil its mandate. Despite its critical andwide-reaching mandate, the DOEcurrently receives less than 1% o f MoEF's annual budget, which itselfi s less than 0.5% o f the Government's total revenue and development budget. Inadditionto a significant increase inresources, a key element o f the Strategic Plan i s the creation o f civil service cadre positions for DOEstaff, which will do muchto improve the quality o f applicants and strengthenincentives for staffperformance. Implementation o fthe Strategic Planwill also allow the DOEto bringmore environmental cases to court, which is essential to buildthe credibility of the Government's environmental intentions. Stronger environmental enforcement capacity i s also necessary outside the DOE, particularly for sustainable management o f natural resources. The recent success o f the Department o f Fisheries inprotecting the hilsa, for example, serves to demonstrate the potential effectiveness o f regulatory enforcement inensuring the long-termproductivity o f the nation's capture fisheries. Economic Policies and Incentivesfor ImprovedEnvironmental Performance 26. While information and regulatory enforcement help establish incentives for improvements inenvironmental quality, these are most effective when combined with supportive economic policies. For example, the reduction o f duties and other barriers on the import o f fishwould increase supplies, andthereby reduce the intensity o f the exploitationo f Bangladesh's capture fisheries. An important element inthe battle to curb urbanair pollution will be to ensure that the sulphur content o f importeddiesel is reducedto 500 ppm, reflecting the economic cost o fthe health damage caused by lower quality hel. Economic incentives can also be usedto complement regulatory approaches to improve environmental management. Inthe case o f industry, there i s scope for this to be achieved through the promotion o f waste-minimization and eco-labelling initiatives. While this would primarily attract export-orientated businesses, particularly inthe garment manufacturing and aquaculture sectors, consideration could also be given to the promotion o f an eco-label for the domestic market. VIII. Conclusion:KeyActions andWorld BankSupport 27. The economic losses resulting from the environmental impacts considered inthis report are equivalent to more than4% o f Bangladesh's GDP. Among these impacts, three sources o f environmental degradation stand out as currently receiving insufficient attention given their relative significance: (i) indoor and urbanair pollution, (ii) degradation o f the water quality inDhaka, and (iii) the decline o f capture fisheries. The economic losses viii associated with these three concerns alone may amount to more than 2.7% o f GDP. The report proposes a set o f actions ineach o fthese areas, and also identifies a series o f measures that could be taken to strengthen environmental governance, which forms an overarching constraint to improved environmental management across all issues. While the report estimates the economic losses associated with the environmental impacts considered, it does not provide a benefit-cost or cost-effectiveness analysis o f the proposed mitigatingactions. It will be important to examine the costs o fthe proposed actions inmore detail as an element o f the follow-up work ineach o f the priority areas. The proposed actions are summarized below, with an indicationo fpotential World Bank support ineach area. Reducing Exposure to Air Pollution 28. Key actions to reduce exposure to indoor andurbanair pollution include: Integrate the mitigation o f IAP into existing energy and public health programs through the provisiono f both cleaner technologies andpublic information; Support a public education effort on IAP explaining the health benefits o fbetter ventilation and longer outdoor time for children; Promote cleaner fuel and cooking technologies, with the aim o f establishing demand for private sector provisiono f suchtechnologies inthe longer term; Expandurbanair quality management activities, focusing on gross diesel polluters, fuel quality, and the extension o f air quality monitoringwithin Dhaka and to other cities. The World Bank plans to provide technical assistance to explore sustainable delivery models for the information andtechnology necessary to reduce exposure to IAP. The Bank will also continue to provide support for the Air Quality Management Project, and possibly a follow- upoperationto expandurbanair quality management activities. Improving Water Quality in Dhaka 29. Key actions to improve water quality inDhaka include: Develop an integrated framework to address water quality and supply, sanitation, and flood management inDhaka; Provide public informationto raise awareness o f the causes and impacts o fpoor water quality; Support stricter enforcement o f environmental clearance conditions and effluent standards; Provide technical assistance for low cost waste minimizationinitiatives, as part o f a broader program o f compliance promotion; and Invest inwater supply, sewerage, sanitation and storm water drainage services, as well as low cost solutions targeting industrial effluent. The Bank i s preparing to support investments inwater supply, sewerage, sanitation and storm water drainage services inDhaka. A proposed separate operation to strengthenthe ix management o fwater resources would supplement these investments with support for appropriate industrial effluent treatment technologies, as well as environmental compliance initiatives. This support will draw on planned analytical work and technical assistance to identify policies for more effective management o f industrial pollution and the promotiono f cleaner productioninthe Greater Dhaka area. Reversing theDecline of Capture Fisheries 30. Key actions to reverse the decline o f capture fisheries include: Establish and ensure minimumdry seasonwater flow requirements for capture fisheries. Establishbothlarge and small scale sanctuaries for protection o f capture fisheries. Develop and implement fisheries management regulations. Adopt an Integrated Coastal Resource Management framework. Enhancemonitoring o f capture fisheries. 0 Reduce barriers to the import o f fish. The Aquatic Biodiversity Conservation Project (closed in2005) andthe FourthFisheries Project (closing in2006) were supported by the World Bank, and among other achievements ledto the development o fthe Government's draft inlandcapture fisheries strategy. The Bank i s preparedto provide further assistance to support the implementation o f this strategy and to strengthen community management o f fisheries. Inaddition, the Bank i s also preparedto support regional collaboration to develop a strategic action plan for the management o f marine and coastal resources inthe Bay o f Bengal. Strengthening Environmental Governance Key actions to strengthenenvironmental governance include: ImplementDOE'S Strategic Plan. Create cadre positions for DOEstaff. Make environmental assessments and informationrelated to the environmental clearance process publicly available, includingthrough the internet. Mandate public consultation on environmental assessments o f highrisk projects. Require consideration o fNo ObjectionCertificates at open meetings o f Union Parishads. Delegate responsibility for environmental clearance o f less polluting facilities to local authorities. Publishanational environmental scorecard annually. Publishthe environmental performance o f selected high-priority industrialfacilities. Provide DOEwith legal assistance inbringingenvironmental casesto court. X Giventhe availability o f technical assistance resources for DOE,the most important role for the World Bank will be to help address the revenue budget implications o f the Department's Strategic Planthrough the Bank's dialogue with the Ministry o f Finance and the ongoing program o f development policy lending. The needto implement the DOE'S Strategic Plani s reflected inthe policy matrix for the series o f Development Support Credits supported by the World Bank, and will continue to be incorporated infbture development policy lending discussions. World Bank support for the strengthening o f local government provides an additional avenue to increase consultation and accountability for environmental decision- making at this level. 32. The technical assistance, investment and budget support operations discussed above are reflected inthe World Bank's Country Assistance Strategy (CAS) for the periodFY06- 09. Appendix I11provides a summary o fthe keyproducts, and indicates the principal environmental management outcomes associated with each. Such initiatives will complement the investment support and technical assistance being providedby other development partners to strengthen environmental management inBangladesh. 33. The Government's strong commitment to the MDGs i s reflected inthe National Strategy for Accelerated Poverty Reduction, and achievement o f two o f the MDGs in particular i s closely dependent on improvements inenvironmental management. Meeting the target for reduction inchild mortality under Goal 4 will require continued reductions in environmental health risks, particularly those leading to respiratory infections anddiarrhea, which together account for about a quarter o f under-five deaths. Meetingthe targets to ensure environmental sustainability under Goal 7 will require renewed effort to strengthen environmental governance, reversethe loss o f natural resources, and reversethe degradation o f urban environmental quality. While the Government has made important strides towards these targets, this report highlights a number o f sources o f environmental degradationthat merit greater emphasis. Initiatives to undertake the key actions summarized above will not only bringBangladeshcloser to achieving its targets under the MDGs, but will significantly contribute to the removalo f environmental constraints to poverty-reducing growth. xi Chapter 1:Context and Objectives I. EnvironmentalChallengestoPovertyReduction 1. Despite poor initial conditions, a widespread perception o fpoor governance, confiontational politics, andvulnerability to natural disasters, Bangladeshhas achieved steady economic growth o f4 5 % annually over the last decade. At the same time, annual populationgrowth hasbeen reducedfiom 2.5% inthe 1980sto 1.7% since 1990. As a result, annual per capita GDP growth has increasedfrom 1.6% inthe 1980sto 3.7% in2004, although this i s still below the regional averageo f 5.0%. While halfthe population still lives inpoverty, this representsanimprovement from 59% in1990, andwiththe country self- sufficient infood grains, food security has also improved, even for the very poor. 2. Bangladesh has also demonstrated significant success inachieving the human development targets o fthe Millennium Development Goals (MDGs). Primary school enrolment has risen to 98%, with enrolment rates now slightly higher for girls than boys. By 2000, infant and child mortalityrates hadbeen significantlyreduced to 30 and 60 per thousand live births,respectively. With the secondlowest infant mortality rate and third lowest child mortality rate inthe SouthAsia Region, Bangladesh i s set to meet the MDG target o f a two-thirds reduction by 2015 over 1990 levels. Inreaching this target, however, and inmakingMher progresstowards other poverty reductionandhuman development goals, over-coming environmental challengesto humanhealth and natural resource productivity will become increasingly important. 3. The linkages between environmental degradation and poverty are explicitly recognized inBangladesh's National Strategy for Accelerated Poverty Reduction, which emphasizesboththe dependencyo fthe poor onnatural resources, andthe vulnerability o fthe poor to environmental health risks. The Strategy highlights a number o fnatural resource issues as beingo fparticular concern to the poor, including the degradation o f agricultural land, andthe unsustainableuse ofcommon resources suchas fisheries. Among the environmental healthrisks to which the poor are exposed, the Strategy identifies both indoor and outdoor air pollution, drinkingwater contaminated bacteriologically and with naturally- occurring arsenic, as well as a growing burdeno ftoxic waste from urban, industrialand agricultural sources. While recognizing that economic growth i s essentialto reduce poverty, the Strategycautions that "A careful balancing act mustbeorchestratedwhere economic growth i s maximisedwithout compromising environmental protection...''.4 Environmental Health Risks: a Major Contributor to theBurden of Disease 4. While the total burdeno f disease inBangladesh is comparable to other South-East Asian countries with highmortalityrates, the share attributable to respiratory infections and disease i s about one thirdhigher thanthe average for these countries, and the proportion causedby diarrhoeal disease is almost double the average. Since both are associatedwith poor environmental conditions, the relativelyhigherprevalence o frespiratory infections and diarrhoeal diseasehighlights the importance o f focusing attention on environmental quality in Bangladesh. Inadditionto these traditional environmental healthrisks, Bangladesh i s also National Strategy for Accelerated PovertyReduction, 2005, Section 5.H 1 faced with rapidly increasing industrial and urban environmental health risks. Not only i s Bangladesh experiencing the fastest industrial growth rate inSouth Asia, but the rate o f urbanization between 1990 and 2000 was double that o f India and Pakistan, and the share o f the urbanpopulation living inslum conditions i s the secondhighest inthe region. Almost all fbture populationgrowth, forecast to be some 100 million over the next fifty years, i s expected to occur inurban areas, underliningthe importance o f addressing urban and industrialcontamination. This report estimates that environmental health risks may account for as much as 22% o f the total burden o f disease inBangladesh. Natural ResourceProductivity under Threat 5. Withpopulationdensity approaching one thousandpeople per square kilometre, among the highest inthe world, and growing at 1.7% annually, pressure on natural resources inBangladeshisnecessarilyhigh. Two-thirds ofthe landarea isunder crops, the highest proportion inSouth Asia, and the share under forest cover i s the second lowest inthe region. Protected areas cover the smallest share o f any country inSouthAsia, at less than 0.5% o fthe total area compared with an average o f nearly 8% for Asia as whole, although pressure on biodiversityi s close to the regional average, with approximately 17% o f mammal species and 4% o fbirdspecies under threat. Pressure onwetlands and aquatic life is a particular concern inBangladesh, as boomingurbanandindustrial growth leads to landreclamationand pollution, and fishing effort increases to meet growing demand, with fishcontinuing to provide more than halfthe animal protein inthe national diet. 6. Agriculture accounts for some 23% o f GDP andmore thanhalf o ftotal employment, so the ability o f soil to sustain agricultural production i s an issue o f national concern. Cropping intensity inBangladeshi s the highest inSouthAsia, having increasedfrom below 140% to more than 175% over the last thrty years5 as the introductiono f short duration cereal varieties and winter irrigation facilitated double- and triple-cropping. Pressure on agricultural land i s further intensified by urbanization and infiastmcture development, as a result o f which the cropped area i s declining at about 1% annually. To support this intensity o f cultivation, rates o f fertiliser application are the highest inthe region;6 nevertheless, surveys and soil tests provide evidence that agricultural inputsare imbalanced and nutrient miningis occurring. 7. Bangladeshhas limited natural forest cover, at about 10% o f land area, down from 20% inthe 1960s. Large areas o f the Chittagong HillTracts have been degraded, the Sundarbans mangrove forest is indecline, and most partso f the plain land Sal forest are now shrub lands. The deforestationrate inthe 1980's was 3.3% per year, butin 1989the Government issued a moratoriumon felling innatural forests which continues to date. As a result o f this banand social forestry initiatives, official figures indicate a net rate o f reforestation o f about 1%annually duringthe 1990's. The moratoriumalso stimulated private sector timber production, which now accounts for over 80% o f localtimber marketed inBangladesh, andsatellite imagery suggests asmuchas 35% oflandareahas 10% or more tree cover o f all types, includingprivate plantations. Bangladesh Bureau of Statistics. Cropping intensitycalculated as gross sown area divided by the cultivated area. FAO, 2001. Measured as kilograms ofnitrogen, potashandphosphateper hectareof cropland. 2 8. As detailed inthe CountryWater Resources Assistance StrategyY7water quality and quantity are key determinants o f outcomes inmany sectors o fthe Bangladeshi economy, from industryand transport, through agriculture and fisheries, to humanhealth. About 80% o f renewable water i s received from transboundary inflows, and as the lower riparian, Bangladeshi s impactedbyupstream diversions and abstractions that reduce water availability duringthe dry winter months, andbyupstream discharges and runoffthat degrade the quality o f water entering the country. Water quality and dry season flows are further impairedby industrial growth andurbanization within Bangladesh, with particularly significant impacts on fisheries, inlandwater transport and drinkingwater supply. Vulnerability to Climate change 9. Bangladeshi s highly vulnerable to the projected impacts o f climate change, as these are likely to increase the already highrisk o f disasters, and exacerbate existing vulnerabilities. Global warmingwill cause changes such as higher temperatures, sea level rise andchanging rainfall patterns, as well as more abrupt effects, such as an increase inthe intensity and frequency o f extreme events such as floods, storm surges and cyclones. An increase o f one degree centigrade inoceantemperature could increase tropical cyclone intensity by as much as lo%,* while temperature alterations associated with climate change are already affecting the rate o f snowmelt inthe Himalayas, which i s expected to lead to increasedflooding. It i s predicted that by the year 2030, an additional 14%o f the country will become extremely vulnerable to floods, and currently vulnerable areas will experience higher levels o f flooding. Indeed, significant areas may be permanently inundated.' At the same time, some areas o f the country maybe at greater risk o f drought and food insecurity duringthe dry season, and agricultural productivity incoastal areas maybe compromised by increasing salinity. While climate change does not form a focus o fthis report, the scope and scale o f Bangladesh's vulnerabilityto climate change demand that assessment o f the associated risks and planningfor adaptation remain a priority for M e r work, buildingon the recently completed National Adaptation Programme o f Action." 11. The Responseof the GovernmentofBangladeshandDevelopmentPartners 10. The needto protect the quality o fthe environment has beenrecognized since the birth o f Bangladesh, with the Water Pollution Control andWildlife PreservationActs being establishedin 1973, shortly followed by the Environmental PollutionControl Ordinance. It was not until 1989, however, that a separate Ministrydealing exclusively with environment was created, drawing together the Forest Department from the Ministry o f Agriculture, and the Department o f Environmental PollutionControl (renamed the Department o f Environment) from the Local Government Division. 11. Following the creation o f the Ministryo f Environment and Forests (MoEF), the Government took a number o f important policy steps to guide the strengthening o f environmental management, starting with the development o f the National Conservation Strategy in 1991,and shortly followed by the adoption o fNational Environment Policy in 1992, the National Forest Policy in 1994, and the National Environment Management Action '*WorldBank, 2005 WorldBank, 2000 BCAS andDOE,2001 loMoEF, 2005. 3 Plan(NEMAP) in 1995. At the same time, the needto broaden the institutional framework for environmental management was recognised, leading to the creation o f the National Environment Council in 1993, which i s headedby the Prime Minister and i s designed to provide guidance on environmental issues to line Ministries. 12. Buildingonthese policy andinstitutional foundations, an enablinglegal framework was created, anchored inthe Environmental Conservation Act o f 1995, and elaborated inthe Environmental Conservation Ruleso f 1997. Mechanisms for enforcement o f these provisions were strengthened through the Environment Court Act o f 2000, and have since been clarified through a series o f amendments to the EnvironmentalConservation Act and Rules. Followingthe development o f the NEMAP,the late 1990's also saw concerted efforts bydevelopment partners to prepare a series o foperations designed to support the strengthening o f environmental management inBangladesh. Among the larger donor- supported initiatives implemented by MoEF were the Sustainable Environment Management Programme supported by UNDP, the Sundarbans Biodiversity Conservation Project supported by ADB, the BangladeshEnvironmental Management Project Supported by CIDA, and the Air Quality Management Project supported by the World Bank. As inother areas o f Bangladeshi public life, civil society has also exerted an important influence on environmental decision-making, with a range o fNGOsnow actively addressing both `green' and `brown' environmental issues. 111. Objectivesof the CountryEnvironmentalAnalysis 13. The Government o f Bangladesh's commitment to the MDGsrequires it to take action to address a range o f environmental challenges, inparticular to reduce environmental health risks and to ensure the environmental sustainability o f economic growth. As described above, significant progress has beenmade inestablishing the policy, institutional and legal framework necessary to strengthen environmental management, and a number o f initiatives have been successfully implemented, such as the elimination o f leaded gasoline, the phasing- out o f two-stroke three-wheelers from the streets o f Dhaka, and the banon thinpolythene bags. More broadly, however, practice lags behindthe Government's good environmental intentions. 14. The Country Environmental Analysis (CEA) i s intendedto support the Government inmoreeffectively addressing the environmental challenges to poverty-reducing growth. The process o fdeveloping the CEAhelpedpromote recognition inthe National Strategy for Accelerated Poverty Reductiono f the linkages between environmental degradation and poverty. Buildingon this recognition, the objective o fthe CEA i s to help reduce environmental constraints to economic growthby recommending measures to (i) reduce the environmental healthrisks borne by the poor, and (ii) promote more sustainable management o f the natural resources on which the poor depend. As well as informing Government decision-making, these recommendations are designed to guide the support providedby development partners, including the World Bank's programo f technical assistance, investment operations, and development policy lending. 4 IV. Preparation of the CEA: Scope andProcess 15. The CEA was jointly developed by MoEF and the World Bank, beginning with a review of environmental priorities for poverty-reducing growth. Based on this initial scoping exercise, it was agreed that the CEA should focus o n the following five priority areas: 0 environmental health; 0 surface water quality inDhaka; 0 capture fisheries; 0 soil quality; and 0 institutions for environmental management. The selection of these priority environmental concerns was based not only on their relevance to povertyreduction, but also considered the additional value o f further analysis, and the scope for subsequent action. Regarding the management of forest resources, for example, a Forestry Sector Review was recently completed", and while state-owned forests are locally important for poverty reduction, about 80% o f local timber marketed inBangladesh originates from village or private lands rather than Government forestsI2, a fact reflected in satellite imagery showing forest cover to be four times that of official ~tatistics.'~ 16. An initial analysis of existing andproposedpolicies as these affect the identified environmental priorities, and an assessment of the institutional capacity for environmental management inthese areas, was discussed during a series o f consultative discussions with key stakeholders, held inDhaka inDecember, 2004. The analysis was refinedbased on these discussions, and the draft CEA was discussed inJuly, 2005, at a workshop inDhaka convened by MoEF, and inaugurated by the Minister o f Environment and Forest. The workshop was extremely valuable inframing the final version of the CEA, which reflects the recommendations arising fromthe working sessions. V. Structure of the Report 17. The following chapters of this report present the analysis o fthe policy and institutional factors affecting management o f the five priority environmental concerns selected inscoping the CEA, as follows: 0 Chapter 2 - Environmental Health; 0 Chapter 3 - Management o f Water Quality inDhaka; Chapter 4 - Management of Capture Fisheries; Chapter 5 - Sustaining Soil Quality; Chapter 6 - Institutions for Environmental Management ; Chapter 7 - Environmental Constraints to Growth: Priorities for Additional Action. 11Bangladesh Forest Department, The Forestry Sector Review Report, 2004. Intercooperation, Review o f Wood Marketing inBangladesh, June 2002. 13World Resources Institute, 2005. The difference between official statistics and satellite imagery o f forest cover for Bangladesh is twice the average for Asia. 5 Eachchapter concludes with recommendations for actionby key stakeholders to strengthen environmental management. Priority areas for future World Bank support are identified in the final chapter, based on an assessment o fthe constraints to growth and povertyreduction imposed by the selected sources o f environmental degradation, as well as consideration of the coverage o f current initiatives to strengthen environmental management. 6 Chapter 2: EnvironmentalHealth 18. Since being launched in2000, the Millennium Development Goals (MDGs) have become the most widely accepted measure of development efforts, and the Government o f Bangladesh is committed to achieving the targets embodied inthe Millennium Declaration by 2015. The health-related goals include the target of reducing infant and child mortality by two-thirds by 2015 from their levels in 1990. It is estimated that inBangladesh about one- fifthofthe total burdeno fdisease maybe associated withenvironmental factors (see Table 2.1 below). Two ofthe top three causes o f deathand sickness inBangladeshare respiratory illnesses and diarrhoeal disease, bothof which are strongly associated with the quality of the environment, and both o f which have particularly significant impacts on the health of children. Management of these environmental risks presents an importantdevelopment challenge, h t h e r compounded by widespread exposure to naturally-occurring arsenic, the growing significance of health risks posed by the pollution resulting from rapid urban and industrial expansion, and the increasingly intensive use of chemicals inagriculture. I. EnvironmentalHealth:RiskFactorsandCosts 19. The estimated shares of the top five causes of death and disease inBangladesh, plus cancers (malignant neoplasms), as measured inDisability Adjusted Life Years (DALYS)'~, are shown inTable 2.1. Table 2.1: Bangladesh-Shareof Disability Adjusted Life Years (DALYs) Lost by Cause and EnvironmentalContribution Cause I Yo I Environmental Factor I Share of Cause I Share of Total Sources: Streatfield (2001), Murray and Lopez (1996), Lokuge et a1(2004), WHO (2002), World Bank staff. (a): Disease burden due to arsenic levels >50 ppb, estimatedby Lokuge et a1(2004). May include portions o f the burden o f disease listed under other causes. While the total number of D A L Y s lost per capita is comparable to the average for countries with highrates of adult and child mortality inSouth-East Asia", the share ofthe total burden o f disease attributable to respiratory infections and disease is about one third higher than the average for these countries, and the proportion caused by diarrhoeal disease is almost double 14 Estimated by Streatfield (2001), based on the Indiansubcontinent pattern provided inthe Global Burden o f Disease study, with adjustmentsfor Bangladesh. DALYsare calculated as the present value o f the future years o f disability-free life that are lost as the result o f the premature deaths or cases o f disability occurring ina garticular year. WHO, 2002. 7 the average. The Table also indicates the estimated contribution o f environmental factors, bothas a share o f each cause and as percentage o f the total burden o f disease. 20. Some 16.5%-22% o f the total burden o f disease i s attributable to environmental health risks associated with (i) poor indoor andurbanair quality leading to higher rates o f respiratory infections and disease, (ii)lack o f access to safe water combined with low levels o f sanitation and hygiene, resulting inelevated rates o f diarrhoeal disease, (iii) chronic exposure to toxic contaminants from agricultural and industrial sources, increasingthe risks o f certain cancers, and (iv) exposureto elevated levels o f naturally-occurring arsenic in drinkingwater, contributing to a range o f conditions, includingavariety o f cancers, heart disease, diabetes and non-malignant respiratory disease. The estimated contribution o f these factors to the burden o f disease imposedby environmental health risks i s summarized in Figure 2.1 below. Figure2.1: ContributingFactorsto EnvironmentalHealthRisks Share of EnvironmentalHealth Risks 2%, [ID Indoorair pollution HUrbanair pollution 0 Lackof safewater and sanitation Agro-industrial toxic Arsenicosis 21. Environmental healthrisks inBangladeshare dominated bythose contributing to the highrates o f diarrhoeal disease. Globally, it is estimatedthat 90% o fthe diarrhoeal disease burden i s related to poor sanitation and lack o f accessto cleanwater and safe food16,with more than 90% o f this burden being borne by children. Inthe two-week periodbefore the 2004 BangladeshDemographic and Health Survey (BDHS), 8% o f childrenunder five were reported to have suffered diarrhoea, rising to more than 12% inthe most vulnerable 6-23 month age group. The secondmost significant set o f environmental healthrisks are those contributing to respiratory infections and disease, either through exposureto smoke from cooking inthe home or air pollutioninurban areas. These sources contribute to acute respiratory infections inchildren and chronic lung disease inadults, estimated to account for 36%-60% o f all respiratory infections and disease inBangladesh. Inthe two-week period before the 2004 BDHS, 20% o f childrenunder five were reported to have suffered a respiratory illness. The third environmental health risk identifiedinTable 2.1 i s exposure to highlevels oftoxic chemicals, which can leadto anincreasedriskofcertain cancers, particularly those relatedto renal and gastric functions, as well as those o f the skin and blood. l6WHO, 1997. 8 Malignant neoplasms are estimated to account for about 2.0% of the total burdenof disease inBangladesh. Ifbetween5%-25% o fthese cancers are attributable to acute andchronic exposure to pesticides and industrial contaminants inthe environment, this would suggest that up to 0.5% of the total burden of disease i s due to toxic agro-industrial pollution, equivalent to the share attributable to malaria. 22. The extent o f the environmental health risk posed by naturally-occurring arsenic in groundwater is only beginning to be understood. Tubewell testing indicates that some 29% o fthe population o f Bangladesh i s exposed to water with unsafe levels o f arsenic (Le. in excess o f 50 ppb), and some 38,000 potential cases of arsenicosis have been identified.17 Limited information on arsenic intake and the epidemiology of arsenicosis makes it difficult, however, to estimate associated rates of sickness and mortality. Using dose-response data from studies carried out inTaiwanese populations, ithas been estimated'* that about 0.4%o f the total burden o f disease inBangladesh may be attributable to exposure to arsenic levels in drinkingwater inexcess o f 50ppb. This estimate includes a range o fcancers, heart disease and diabetes considered to be attributable to arsenic, but does not include non-malignant respiratory disease, which recent work indicates may result from ingestion o f arsenic.l9 Further doubt over the extent of the arsenic threat was cast by the 2004 BDHS, which tested the water that surveyed households were drinkingo n the day of interview. Almost half of the households that reported getting their drinkingwater from red-marked tubewells (Le. those previously found to have levels o f arsenic inexcess of 50pbb) didnot have unsafe arsenic levels intheir drinkingwater. To some extent this may reflect tubewell switching, but also may indicate that either arsenic levels vary over time, or that there were errors inthe testing and markingof tubewells, or may reflect the possibility that ironinthe water may have reduced arsenic levels duringwater storage. 23. The death and disease caused by poor environmental quality imposes an economic cost associated with reduced quality of life, lost productivity, and health care costs. These costs can be reducedthrough investments to limit exposure to environmental health risks. An indication ofthe potential scale of such savings is provided inTable 2.2. prevent exposure above 50ppb I Total I 644 1755 I 1.3 - 3.5 - Source: M.Khaliquzzaman,2004. ~ ~~ BAMWSP, 2004 Lokuge et a1(2004) Mazumder et a1(2000) 9 24. As Table 2.2 shows, the estimatedbenefits o freducing exposureto indoor andurban air pollution by 20%-80%, o f providing universal access to improvedwater sources and sanitation, and o f interventions to prevent exposure to levels o f arsenic indrinkingwater in excess o f 50ppb, amount to 1.3%-3.5% o f GNI.20 11. Water Supply and Sanitation 25. The statutory responsibility for the water supply and sanitation sector lies with the Ministryo fLocal Government, RuralDevelopment andCooperatives (MoLGRD&C). Its Local Government Division (LGD) i s responsible for policy making, planning, financial mobilizationand allocations, framing o frules and regulations, as well as monitoring and evaluation. The Department o f Public HealthEngineering (DPHE) i s responsible for planning, designing and implementing water supply and sanitation inrural andurbanareas, except the cities o f Dhaka and Chittagong. The LocalGovernment Engineering Department (LGED) undertakeswater and sanitationrelatedactivities inmunicipalities (Pourashavas) and with City corporations on a project basis. 26. City corporations are responsible for drainage, solidwaste management, and maintenance o fwater supply and sanitation systems installed by DPHEor LGED. Dhaka WASA i s responsible for water supply, sub-surface drainage and sewerage, while Chittagong WASA deals only with water supply. The statutory responsibilities o f Pourashavas include provision, operation and maintenance o f water supply, solid waste management and sanitation, but most have limited technical and organizational capacity, and rely on DPHEor LGEDfor design and construction. Water Supply and Sanitation Committees (WATSAN Committees) have been established inUnionParishads (UPS),and are playing a key role in sanitation, incollaboration with Upazila Development Coordination Committees. Policies, Strategies and Plans: Recognizing the Needfor Action 27. The National Strategy for Accelerated PovertyReductionincludes sanitation and safe water inthe seven-point medium-term strategic agenda, with the specified goals beingto (i) reduce the number o fpeople who do not have access to safe water (26%) or sanitation (66%) byhalfby2006, (ii) waterborne morbidity andmortality, (iii) the number o f reduce reduce people subject to arsenic contamination, and (iv) ensure accessto sanitary community latrines invillages, bazaars, mosques and schools, withparticular attention to women's needs. 28. The mainpolicies guidingwater supply and sanitation are the National Policy for Safe Water Supply and Sanitation 1998 (NPSWS&S) and the NationalWater Policy (NWP). Bothpolicies include the goal o f ensuring that all people have access to safe drinkingwater. The NPSWS&S states that all people should have access to safe drinking and cooking water and sanitation services at an affordable cost, and emphasizes participatory planning and management, as well as decentralization and devolutiono fresponsibilities to the local level. The policy also provides for variations inthe extent o f cost recovery for water supply and 20The estimates o f sickness avoided and savings for indoor air pollution andurbanair quality cannot be directly compared (Le. cases o f sickness are not equivalent to DALYs). Ifthe same approach were used, the results for indoor air pollution would be four to five times greater thanthose for urbanair quality, which i s broadly inline with the difference in estimated rates of death from these two sources o f risk. 10 sanitation investments depending on local conditions and the level o f expenditurerequired to provide access to safe water. 29. The NPSWSS hasbeensupplementedbythe NationalPolicy for Arsenic Mitigation 2004 and Implementation Plan(NPAM&IP). This establishesthat villages inwhich more than80% oftubewells arearsenic-contaminated are eligible for emergencyresponsesupport. Underthe emergencyresponse, at least one safe water source is to beprovidedwithin a reasonabledistance or for every 50 families, with no capital cost contributionrequiredfrom theusers. 30. A NationalSanitation Strategy hasbeendrafted, settingthe goal of achieving 100% sanitation coverageby 2010. According to the Strategy, 100% sanitation requires (i) no open defecation, (ii) hygienic latrines available andusedby all, (iii) maintenance o f latrines proper for continual use, (iv) improvedhygienic practices, and (v) proper management o f solid waste. The guidelines for achieving these goals specify that sanitation i s primarilyabout health and social values, creating and sustaining demand, behaviour change, and an approach that i s gender sensitive, placing communities at the center o f decision-making, with subsidies providedonly for the poorest. 31. Water supply and sanitation i s includedinthe NationalHealthPolicy, National Education Policy andNational Environment Policy, buthas too often comprised disparate project activities without reference to a guiding framework. Recently, however, the Government has approved a Water Supply and Sanitation Sector Development Framework, intendedto guideplanning, coordination andmonitoring with a focus onthe devolutionof authority to local government institutions, user participation, economic pricing, gender sensitivity, and partnerships betweenthe public andprivate sectors, andNGOs. TotalSanitation: Realizing the Full Health Benejts of Clean Water 32. One o f Bangladesh's greatest successeshasbeento achieve near total access to drinking water that i s largelymicrobiologically safe, with 86% o fthe populationdrinking water from handpumps, and 10% connectedto pipedwater. Despite the impressiveprogress inincreasingaccessto cleanwater, slow progressinsanitation coverage, combinedwithpoor hygienehabits, hasheldback the expectedhealthgains. Significantly, the child mortality rate indistricts where less than a quarter o fhouseholdshave access to a sanitary toilet i s nearly40% higher than districts inwhich morethanone-half o fhouseholds have sanitation access.21Nationally, some 30%-40% ofthe population has access to a sanitary latrine.22 In rural areas, only 30%-35% o fthe populationhas such access, and while this total reaches 60%-75% inurbanareas, a recent surveg3found that only 17% o furbanhouseholds are satisfied with the quality o f sanitation services. 33. The goal of achieving total sanitation by2010 was announcedin2003 bythe Government as the objective o fthe Total Sanitation campaign, since when an increaseo f 15% innational sanitation coverage i s claimed. This ambitious program has been launched basedon the experience gained during integrated water supply, sanitation and social mobilizationprograms inthe mid-nineties. With strong political support, aNational 21World Bank(2005) 22PRSP (2004) 23GHK(2003) 11 Advisory Committee under the MoLGRD&C and aNational Task Force under the Secretary o f MoLGRD&C have been formed, with sanitation Committees formed at all levels o f local government. 34. The focal point o f the Total Sanitation campaign is the UP inrural areas, andWards inMunicipalitiesandCities. The Government has earmarked20% ofUpazillas' Annual Development Program(ADP) allocation for improving sanitation coverage. Ofthis, 75% i s to be used to procure sanitary latrines for distribution to the hardcore poor, and the remaining 25% i s to be used for promotionalactivities. Planning and decisions are approved at the Upazilla Development Coordination Committee following guidelines providedby LGD.The assignment o f subsidized latrines to the hardcore poor i s basedon lists preparedby the Ward Sanitation Committee using data fi-om the 2003 national sanitation survey, with the productiono f latrine components being contractedout to private producers at the Upazila or UP level. 35. Recognizing the public health nature o f improvements insanitation, community-wide performance-based incentives for sanitation coverage have been introducedunder the Total Sanitation program, consisting o f additional resources for those UPS(Tk. 0.2 millionAJnion) and Upazilas (Tk. 0.5 million/Upazilla) that have achieved 100% sanitation. Inthe first round o f awards, 95 UPS,4 Pourashavas and 5 Upazilas were rewarded for achieving total sanitationby February, 2005. A guideline i s beingpreparedby LGD on the use o f the awarded funds, focusing on further social mobilization to sustain the sanitary achievements. This forms part o f a phasedapproach, emphasizing eliminationo fopen defecation andthe use o f hygienic latrines by all inthe current first phase, followed by improved sanitation technologies and further social mobilizationto sustain improvements inthe subsequent phase. While there remainquestions about the independence o f the process, the Total Sanitation 2010 program incorporates a comprehensive monitoring system involving data collectionby WATSAN committees, checked and approved quarterly by district Sanitation Secretariats o f DPHE, combined with follow-up surveys to be conducted in2005,2008 and 2010. 36. The Government's commitment to Total Sanitation i s an essential step towards addressing the single most significant environmental threat to the nation's health, and merits the full support o f development partners and civil society. The combination o f improved sanitationtechnologies with the community-wide promotiono f hygienic practices will help realize the full healthgains achievable as a result o f near-universal accessto clean water. Studies inrural Bangladeshhave demonstratedthat integrated water, sanitation andhygiene intervention can reduce diarrhoeal diseases among childrenby 25%24,and a recent international comparison o f water, sanitation and hygiene interventions found that sanitation interventions can reduce the risk o f diarrhoeal disease by a third.25 Meeting the TotalSanitation Goal 37. Successful achievement o f the goals o f the Total Sanitation campaign will entail overcoming a number o f challenges, however, not least o f which i s the allocation o f sufficient resources. The PRSP estimates the cost o f achieving total sanitation at about 24Aziz et a1(1990) 25Fewtrell et a1(2005) 12 US$450 million26,equivalent to about US$30 perhousehold currently without sanitation. While this level o f investment may be more than sufficient for the provisiono f simplepit latrines (estimated to cost on average about $14), rehabilitationand expansion o fmunicipal sewerage systems to meet the needs o f Bangladesh's burgeoning urbanpopulationwill require resources o f at least this magnitude. The rehabilitationo fDhaka's existing sewerage and drainage system i s alone projected to cost about $100million. 38. Sanitation activities inurban areas have been slower than rural initiatives, and will require additional attention ifthe Total Sanitation 2010 goal i s to be realized, particularly regarding the technologies beingapplied. EveninDhaka, only about 27% o fthe population i s connected to the public sewer system. The most common sanitation technologies inurban areas are pit latrines and septic tanks, butindensely populated areas, pits fill too fast andthe effluent from septic tanks flows into open drains, making on-site sanitation options inappropriate for such settings. While the long-termaim mustbe to extendthe public sewer system inurbanareas, there are manynew and expanding developments, as well as existing slums, that will not receive trunk connections inthe foreseeablefuture. There i s a clear need for the development o f alternative solutions, including, for example, the use o f Septic Tank Effluent Disposal Systems (STEDS), which would combine household septic tanks with small-bore connections to low-cost community effluent treatment facilities. 39. Seasonal flooding posesan additional technological and social challenge to the achievement of total sanitation. Floodingto a greater or lesser extent i s an annual event in Bangladesh, and mustbe considered inthe development andpromotion o f sanitation technologies inflood-prone areas. Flood-waters spreaddisease and contarninate water supplies, causing rates ofdiarrhea to increase some seven-fold duringthese episodes. Latrines become a highpriority especially for women inshelters and affectedhouseholds duringfloods. When askedto prioritizetheir needs duringfloods, 60%-70% ofwomen named latrines as their number one concern.27 To the extent possible, pit latrines should be constructed with concrete lining inproperly compacted earth above flood levels, but such measureswill not bepossible inall locations. To achieve the goal o fyear-round sanitation, consideration mustbe givento providing temporary or permanent latrines inshelters or refuge sites adequateto meet the sanitary needso fthe affected community during floods. Arsenic: Threatening Safe WaterAchievements 40. Since the 1970's, extensive awarenessandmotivation, technological and financial efforts have beenundertakenby civil society, Government and development partners to change drinking water practice away from microbiologically-contaminated surface water to clean groundwater. As a result, there are now some 11milliontube wells installed in Bangladesh, supplying microbiologically clean drinkingwater to morethan90% o fthe population. However, widespread contamination o f groundwater with naturally-occurring arsenic has reduced the percentageo fthe population with access to safe water to about 73%. According to the national survey conducted byDPHE, some 29 millionpeople are exposed to arsenic contamination exceeding 50ppb, and 49 millionto levels exceeding 1Oppb. Inthe face o f significant technological andinstitutional challenges, the responseto arsenic 26PRSP, December2004, p. 179 27B.Hoqueet a1(1997) 13 contamination has been slow, and concern i s growing that a switch back to surface water sources will lead to an increasedrisk o f microbiologicalcontamination. 41. Ithas beenestimatedthat atransitionback to untreatedsurface water sources suchas unimproveddugwells or ponds could meanan increase inthe risk o f diarrheal disease by 20%.'* Switchingto a safe but more remote tubewell may also increase such riskby reducing the quantity o f water used inthe household, as may the use o f arsenic filtration systems, as higher levels o f microbial contamination have been found infilteredwater than in the tubewells from which it was taken.29 Based on a comparison o f these risks, it i s calculated that arsenic mitigationinterventions providedto households exposed to levels o f arsenic inexcess o f 50pbb needto achieve at least a 77% reductioninarsenic-related morbidity andmortality to result ina net reduction inthe overall burdeno f disease. This conclusionunderlines the importance o f targeting arsenic mitigation interventions at households exposed to highlevels o f contamination, and ensuring that such interventions significantly reduce arsenic exposure without increasingthe risk o f waterborne disease. Rising to theArsenic Challenge: Technology Choices and the Role of Piped Water 42. The NationalPolicy for Arsenic Mitigation (2004) sets the goal o f providing access to safe water for drinking and cooking inarsenic-affected areas, givingpreference to surface water over groundwater as a source. Despite this preference, the Government i s supporting investments indeep tube wells inmany arsenic-affected and coastal areas. Intervention studies o f people's chosenwater options have indicatedthat deep tube wells and pipedwater systems are inhighdemand and have performed satisfactoril?'. Conversely, significant concerns remainregarding the microbiological safety o f alternative options, such as dug- wells and Pond-Sand Filters (PSFs). Household rainwater technologies are growing, but the technology i s costly, and the supply seasonal.31 A few arsenic removal options have been recently approved by GOB and are undergoing further action research. Operation and maintenance (O&M) are important determinants o f appropriate technologies. One o f the mainfactors associated with the success and highdemand for tube wells has beenthe low O&M requirements. Incontrast, PSFs andmost arsenic removal systems require regular cleaning, and the operational performance o f rainwater harvesting systems and dug-wells i s seasonally variable. 43. The needto matchthe service levels o f household shallow tube wells with either surface water, which requires treatment, or deep tube wells, which entail higher levels o f investment, argues for the promotion o fpipedwater systems where feasible, as these spread investment costs while maintainingwater delivery at the household level. Inturn, the development o fpipedwater systems requires arsenic mitigationto be addressed as part o f a broader program to improve water supply service levels, with important roles to be played by local governments andthe private sector. A recent World Bank study o f arsenic contamination inSouth and East Asia suggest that this challenge presents the opportunity to transform government agencies fkom providers o f services to facilitators assisting local governments to help themselve~.~'The BangladeshWater Supply ProgramProject 28Lokuge et a1(2004) 29Sutherland et a1(2002) 30B.Hoque et a1(2003,2004) 31Arsenic Policy Support Unit (2004) 32World Bank (2005~) 14 implementedbyDPHE with World Bank assistance supportsthe scaling-up ofthe provision o f safe water inrural areas and small towns, promotingprivate sector participation inthe provision o fpipedwater systems. Project fhds cover 50% o f capital costs, with the remainder borne bythe sponsor andusers. The goal i s to provide 450 villages with finctioning pipedwater supply schemes, providing multiplehouse connections for wealthier households, yardstandpipesfor middle-income households, and shared standpipes for poor households. 44. More thanhalfthe urbanpopulationhas access to pipedwater supply. The four large cities, Dhaka, Chittagong, Khulna andRajshahi havepipedwater systemsthat serve 70%, 55%, 51%and 40% o fthe populationrespectively. Inaddition, 100ofthe over 250 municipal towns have pipedwater systems. These systems primarily serve the urbancore, with peri-urbanand slum populations continuing to rely on tube wells. Urbanareas will require major investment to meet the growing demand for water, inadditionto significant improvements incost recovery inorder to meet operation andmaintenance costs. That municipal water supply inBangladesh canbe financially viable hasbeen demonstrated through the District Towns Water Supply and Sanitation Project, where all buttwo o fthe 18 municipalities generatedprofits before depreciation, and three generatedprofits after depreciation. Eveninslum areas, 100%o fwater bills have beenpaidwhenNGOs were involvedintheir management. Although there i s room for improvement incollections, both the DhakaandChittagong Water Supplyand SewerageAuthorities (WASAs) are able to cover operating, maintenance, depreciation and financing costs from user fees. Regulatory Roles and Private Sector Services: Partnershipsfor Safe Water Supply 45. As noted inthe BangladeshCountryWater ResourcesAssistance Strategg3, improved service levels inwater supply will require greater involvement o f local governments, the private sector and civil society. As well as supporting higher levels o f investment, the private sector canprovide services for operation, maintenance, billing and collection. To ensurethe quality o fthese services, the Government should be supported inits plansto establish anindependent regulatory framework to supervise andmonitor performance, forming an element inthe broader transformation o f government agencies from service providers to facilitators and regulators. 46. Inadditionto enhancingthe quality ofservice, achievement ofthe Government's goals for the supply o f safe water will require an expansion o f service coverage to better reach disadvantaged social groups. The potential o flocal governments to assist inattaining this goal has been demonstratedthrough pilot initiatives inwhich UPScontrol and manage funds, transferred directly to theminthe form of annual block grants. Further support for the supply o f safe water should continue to emphasizethe role o flocal governments inthe planningandmanagemento fwater services. 47. An essentialregulatoryrole inthe provisionof safe water is the monitoringof drinkingwater quality. While the arsenic crisis stimulated animpressivenationwide initiative to test tube wells for contamination and to strengthenthe analytical capabilities o f DPHE laboratories, there is not yet a systematic, quality-controlled program to regularlytest public and private drinkingwater sources. Effortsto develop a water quality surveillance 33World Bank (2005b) 15 system are urgentlyrequired, combining monitoringby service providers, public provisiono f information, andthe setting and enforcement o f standards by a regulatory body, a role that could potentially be filled by DPHE or DOE. Water Supply and Sanitation: A Good Investment 48. The PRSP states that water supply and sanitation will be recognized as a separate sector inthe next Three Year Rolling Plan, and projects that US$4.9 per capita will be requiredto meet water supply and sanitation goals, implyinga total cost o f some US$650 million. As Table 2.2 indicates, the economic value o f the health benefits achievable through universal provision o f improved water sources and sanitation may amount to US$740 million annually, suggestingthat the proposed level o f investment would pay for itselfwithin one year. 111. Air Pollution 49. Respiratory infections and disease account for a greater share o f death and sickness in Bangladeshthan diarrhoeal disease, and as Table 2.1 indicates, up to two-thirds o f these health outcomes may be associated with environmental factors inthe form o f either Indoor Air Pollution(IAP) or poorurbanair quality. Indoor Air Pollution: A Serious Health Hazard 50. Recognition o f the health impacts o f IAP i s growing worldwide.34 Inhaling smoke from burningbiomass can have bothtemporary and permanent consequences for health. Notable among these are chronic bronchitis among women and acute lower respiratory infections among children, especially pneumonia. Worldwide, it i s estimatedthat about 60% o f deaths caused by air pollution are among children under five as a result o f exposure to smoke from dirty cooking fuels.35 There i s also moderate evidence associating solid fuel use with a range o f further healthoutcomes, including cataracts andblindness, tuberculosis, asthma, adverse pregnancy outcomes, and possibly heart disease.36 51. Poor households inBangladeshdepend heavily on wood, dung and other biomass fuels for cooking. As a result, the healthimpacts o f IAP are significant, estimated to account for as much as 8% o f the total burden o f disease, as shown inTable 2.1. These estimates were supported by a recent World Bank study7,which detected dangerously high concentrations o fparticulates inindoor air for many poor households inBangladesh3*, implyingwidespread exposureto a serious healthhazard. Particularly highlevels o f exposure to IAP were recorded for women, childrenand adolescents o fboth sexes, and these were especially serious for childrenunder five. 52. Fuel choice significantly affects indoor pollution levels, with natural gas and kerosene being cleaner thanbiomass fuels. The World Bank study inBangladeshfound, however, that household-specific factors apparently matter more than fuel choice in 34WHO, 2002 35World Bank, 1999 36Smith, 2000 37Dasgupta et al, 2004 38Concentrations of 300 ug/m3or greater were common inthe samples analyzed for the study. 16 determining indoor concentrations o f harmfulparticulate matter, withthe choice of cooking location, construction material, and ventilation practices being particularly important. These factors were also found to be significant ina similar study conducted inIndia (see Box 2.1). Inaddition, theBangladeshstudyfoundgreatvariationduringtheday, withparticulate concentrations duringpeak cooking periods exceeding those duringthe least smoky part o f the day by a factor o f 50 or more. There was little variationwithin households, however, implyingthat exposureto dangerous indoor pollution levels is not confinedto cooking areas. Box 2.1: A ComparativeAssessment of IAPinBangladeshand India Two recently completed studies* measured exposuresto indoor air pollution inrural settings inIndia and Bangladesh. Both studies provided quantitative informationon concentrations and exposure to fine particulate matter for a variety o fhouseholdfuels and conditions. Both studies strengthen evidence that cooking with clean fuels reduces exposure to fine particulates compared to coolung with solid fuels, but there are significant differences betweenthe two countries. In particular, concentrations inIndianhouseholds using solid fuel are up to 9 times higher than concentrations inthose using gas, whereas the difference is only two-fold inBangladesh. Consistently across the studies, fuel choice, coolung location andventilation factors were found to be strongly associated with kitchen and living area concentrations. The India study, however, finds that fuel choice is the dominant factor, whde the results for Bangladesh highlight the role o f ventilation as being more significant ininfluencing IAP levels. Together, the studies indicate the need for multiple interventions to reduce exposure to IAP, ranging from improvements inhousing design and ventilation, to provision o fbetter stoves that vent smoke outside the house, inaddition to efforts aimed at accelerating the adoption o f cleaner fuels. (*World Bank, 2002; Dasgupta et al, 2004) Changing Behaviour, Technology and Fuels to ReduceExposure to Indoor Air Pollution 53. The health impacts o f IAP can be mitigatedthrough the use o f cleaner fuels, improvedefficiency inbiofuel use, and improvedventilation. The policies necessary to promote these changes are cross-sectoral, affecting fuel pricing and distribution, small business development, andhealth education. The use o f cleaner forms o f energy, such as natural gas, kerosene and electricity, depends both on household income and the price o f cleaner fuels relative to biofuels. As biofuels are more expensive inurbanareas, where cleaner energy i s cheaper, the use o f cleaner forms o f energy i s higher inBangladesh's towns andcities, particularly among households with a per capita income over US$2.00per day. In rural areas, however, there i s little likelihoodo f the widespread use o f cleaner fuels inthe new future. 54. International experience indicates that household concentrations o f fine particulates can be reducedbelow 200 ug/m3through the use o f a well-maintained improved stove.39 While a number o fpilot programs to promote the use o f improved stoves have been undertaken inBangladesh4', these have not resulted intheir widespread adoption. Despite such efforts, limited information i s still a significant impediment to adoption o f cleaner, more efficient stoves. Ofthe households sampled inthe World Bank study, only 15% regarded improved stoves as a viable option, either because they hadnot heard o fthem or because they 39K.b e d ,et al, 2005 40For example, by the BangladeshCouncil for Scientific and Industrial Research(BCSIR). 17 didnot think they were locallyavailable. Evenamong families that hadconsideredthe option, however, improved-stove use was limited because o f concerns about convenience or initial investment cost. Carefbl assessmento f successful improved stove programs inother countries (see Box 2.2) may provide valuable lessons for the development o f a more effective approach inBangladesh, particularly regarding the need to simultaneously stimulate demand and create an effective private sector response. ~ ~~ Box 2.2: The SuccessfulPromotionof ImprovedStovesinChina Inthe early 198Os, the Chinese government organizedthe world's largestpublicly financedinitiative to improve stoves, the National Improved Stoves Program (NISP), wbch aimed to provide ruralhouseholds with more efficient biomass stoves, andlater withimproved coal stoves. The primaryobjective o f the NISP was to relieve pressure on biomass, rather than to reduce ID,and consequently it was runby the Ministryo f Agriculture (MOA).By the end o f the f r s t phase ofthe program, 130 million improved stoves hadbeeninstalled, and pressure onbiomass had easedinmost parts of the country. Inthe secondphase, during the early 199Os, the MOAprovided support for stove manufacturers and energy service companies. Inthe final phase, fiom the mid-1990s onwards, support for the stove industrywas replaced with extension services and certification systems to standardize stoves. The development and dissemination o f improved stoves is now left mainlyto market actors, with some local government oversight. Based on household surveys, by the end o f the 1990s about 55% o f China's 236 million rural households had improved biomass or coal stoves. These surveys also c o n f i i e d that the use o f improved stoves resulted inreduced indoor concentrations o f fme particulates, and that the prevalence o f childhood asthma and adult respiratory diseasefell withthe use ofimprovedstoves. (Source: Xiliang and Smith, 2004) 55. The World Bank study suggests, however, that poor rural families may not have to wait for clean fbels or improved stoves to enjoy significantly cleaner air, as some households already experience relatively clean conditions, even when biomass hels are used. Since these arrangements are already within the means o fpoor families, the scope for cost-effective improvements may be larger than i s commonly believed. Simple changes inventilation characteristics o f housing (including construction materials, space configurations, cooking locations, and the placement o f doors and windows), as well as ventilation behavior (keeping doors and windows open after cooking) canproduce large improvements inthe quality o f indoor air. For children ina typical household, pollution exposure can be halved by increasing their outdoor time from three to five hours per day, and concentrating outdoor time duringpeak cooking periods. Since better ventilationand longer outdoor time for children are affordable and acceptable for poor families inBangladesh, and may reduce IAP exposure to much safer levels, promotiono f these simple changes i s strongly recommended for immediate action. Given the current low level o f awareness o f the consequences o f IAP, however, achieving such behaviour change will require a concerted public education effort aimed at explaining the health benefits o f reducing exposure to smoke from biohels. UrbanAir Quality: Targeting GrossPolluters 56. Upto 10% o frespiratory infections anddisease inBangladeshmaybe attributableto urban air pollution, as indicated inTable 2.1. While the problem i s most severe inDhaka, where air quality i s worst andthe most people are exposed, air pollutioni s a growing concern inother majorcities. MeasurementsinDhakaindicate that particulatematter isthe most 18 significant pollutant, especially fine particulates that cause the most severe healtheffects. The effect i s seasonal, however, with particulate concentrations falling within acceptable levels duringthe summer rainy season. Currently, other pollutants rarely exceed standards for ambient air quality. 57. A first important step inaddressing urbanair qualitywas taken with eliminationo f leaded gasoline in 1999. A further significant improvement inthe quality o f air inDhaka was achieved through the banon two-stroke three-wheelers (known as baby-taxis) instituted inJanuary, 2003, whichreducedambient concentrations offine particulate matterbyabout one-third. Nevertheless, concentrations o fparticulate matter inDhakaremainhigh, exceeding national standards on more than 100 days o f the year, and the gains achieved through the baby-taxi banare being rapidly eroded, inparticular through rising emissions from the growing fleet o f diesel vehicles providing public transport. 58. To reduce concentrations o fparticulate matter, measures needto be taken to improve the quality o f fuel and to curb emissions fkom gross mobile and industrial sources. More specifically, the sulphur content o f importeddiesel should meet international specifications (Le. not exceeding 500ppm), and initiatives to control emissions should focus on gross diesel polluters, particularly trucks andbuses. Reducing fuel sulphur content will reduce emissions fkom the existing diesel vehicle fleet41, as will improvedmaintenance and operation. In addition, lower diesel sulphurwill allow the effective use o f cleaner engine technology, which should be promoted through fiscal and regulatory incentives for vehicle upgrades once cleaner fuel i s available, especially for fleets o f diesel vehicles operating within Dhaka. To get the full benefit o f diesel s u l k reduction, it will be necessary to upgrade the bus fleet to Euro-I1or higher equivalent standards. Alternatively, bus fleet renewal using CNG as fuel may be pursued, as emission levels o f dedicated CNGbuses correspond to Euro-I11or better. 59. Initiatives aimed at reducing emissions from industrial sources shouldbe based on assessments o ftheir relative contributions to the particulate load. To the extent possible, such efforts should draw on win-win solutions that provide energy savings incombination with emissions reductions. Such an approachwill not only help buildprivate sector support, but also raises the possibilityo freceiving carbon financing for reducedgreenhouse gas emissions. The DOEhas largely succeeded inpromoting the use o f 120 ft. highstacks for conventional brick kilns across the country, which has helped reduce local pollutant concentrations. This i s an interim solution, however, and the Government has adopted an initiative with UNDP support to promote energy-efficient brick kilntechnology for the reduction o f emissions from these sources. 60. To target emission reductionefforts, monitor their effectiveness, and buildthe necessary public support for such initiatives, it i s essential to sustain and expand the monitoring o f ambient air quality. Currently this i s conducted ina limited fashion only in Dhaka, but should be extendedto other major cities, as well as to provide better coverage in the capital. While other criteria pollutants should be covered, the primary focus should remainparticulates, particularlythe respirable fraction, and greater consideration should be given to the potential role o f the private sector inproviding the technical services required for data collection. 41Gwilliamet al, 2004 19 IV. Reducing Exposure to Toxic Pollutants 61. Withthe fastest industrial growthrate inSouthAsia (averaging 7.1% per year from 1990-2003, compared with 5.9% for the region as a whole42), andrapid intensification inthe use o f agro-chemicals (pesticide consumption doubled between 1994 and Box2.3: PersistentBio-accumulativeToxics - 200143),the impacts o f toxic chemicals Lead andMercuryEmissionsinBangladesh on humanhealthand the environment in Bangladeshare an increasingly Two o fthe inorganic PBTs o fgreatest concern in important concern. Ofthe various toxic Bangladesh are lead andmercury. The electrical chemicals, Persistent Bio-accumulative apparatus and supplies sector is the largest generator o f lead inBangladesh, which includes Toxics (PBTs) that degrade slowly and lead-acid storage battery producing units, as well as accumulate inliving organisms are o f wire and cable producing plants locatedprimarilyin particular concern, While a number o f Dhaka, Chittagong, Khulna andKushtia. Other inorganic PBTs, particularly heavy sectors with potentially significant lead emissions metals, merit increased consideration in include the iron and steel, andthe tile and ceramic Bangladesh(see Box 2.3), a particular manufacturing sectors. Paper andpulp facilities class o f PBTsknown as Persistent release significant amounts o fmercury into the atmosphere, and important among these are the Organic Pollutants (POPs) has attracted KamafuliPaper MillandKarnafuliRayon Complex special attention, bothnationally and (Omar et al, 1985). internationally. 62. POPsare highly stable organic compounds producedbothdirectly andas by-products o f a range o f economic activities, inthe agriculture, health, industry, energy and mining sectors, among others. All persist for years before breaking down, and travel great distances through various media from their point o f origin, accumulating inthe tissue o f most living organisms, via food, water and the air. Worldwide, the known effects o f POPS(particularly DDT)include their role inthinningeggshells infish-eating birdsandreductions intheir reproductive rates. POPs have also been linked to cancer and reproductive abnormalities, while their effects on reproductive andnervous system disorders are also well established. 63. Twelve have been singled out under the StockholmConvention for urgent action and control based on their usage and emission characteristics (see Box 2.4). As a signatory to this Convention, which came into force inMay 2004, Bangladeshi s now faced with the challenge o f establishing sustainable POPsmanagement practices and cost-effective solutions for their replacement and safe disposal. The dimensions o fthis challenge were indicated inthe recently completed World Bank South Asia Regional Strategy on and other analyses46that point to a number o fpotential sources o f POPs, such as rapidly increasingpesticide use, a range o f manufacturing industries, and anunregulated ship- breaking sector. 412005 World Development Indicators 43DepartmentofPlant ProtectionWing, Bangladesh.Citedin Meisner, 2004 44The pesticidesaldrin, chlordane, DDT, dieldrin, endrin, heptachlor, mirex andtoxaphene, the industrial chemicalshexachlorobenzene(HCB) andpolychlorinated biphenyls (PCB), and dioxins andfurans which are unintendedbyproducts of combustion and industrial processes 45Issues and Options inAddressing the Objectives of the Stockholm Convention on PersistentOrganic Pollutants inIndiaandtheSouthAsiaRegion,April 2004 46Report on PesticideHotspots inBangladesh, September 2004; FinalReport on Industrial Pollution: Sources andImpactsGISDatabaseSeptember 2002 20 Box 2.4: The Stockholm Conventionon PersistentOrganicPollutants The Stockholm Convention on Persistent Organic Pollutants was ratified inMay 2004. Some of the key objectives o f the Conventioninclude: Eliminate production and use o f specific pesticide POPs: aldrin, chlordane, dieldrin, en&, heptachlor, hexachlorobenzene, mirex, andtoxaphene. 0 Restrict production anduse o f DDT indisease vector control inaccordance with WHO guidelines; 0 Develop strategies for identifying stockpiles ofPOPs andproducts containing POPs; 0 Manage and dispose POPs wastes inan environmentally sound manner 0 Develop remediation programs for POPs contaminated sites 0 Manage PCBs inan environmentally sound manner andby 2025, take action to remove fiom use PCBs found above certain thresholds; Develop andimplement an action planto identify the sources andreduce releases o f POPS byproducts. Promote the use o f Best Available Techniques (BAT) andbest environmental practices. Pesticides -a Continuing Source of POPS? 64. InBangladesh, POPspesticides were completelybannedfor use inagriculture from 1997, although most were bannedmuch earlier in 1985. Their continueduse has been reported47,however, possibly attributable to cross-border transfer, continued local formulation, inadequate product labeling and farmers' lack o f i n f ~ r m a t i o n .Significantly ~ ~ highpesticide levels havebeenfoundinthe food chain. A study ofpesticideresidues in Mymensingh andDinajpur districts indicated the widespread presence of DDT and its metabolites inwater, soil and rice plant samples49. Ina survey undertakenby the World Bank5', the use o f two POPs (heptachlor and endrin) was reportedby farmers inthe districts of Comilla, Chittagong, Dhaka, Rajshahi andMymensingh. DDT, at levels well above the WHO guideline, has beenfound ina number of samples of surface and groundwater taken in Banglade~h.'~Direct evidence o f human exposure has been providedthroughthe identification o f DDT inthe breast milk o f mothers incoastal areas where dried fish are widely consumed.52 Analyses o f dried fish conducted in 1998 found the presence of DDT (allegedly used inthe curing process), insome cases at exceptionally highlevels presenting a hazard for humanc o n ~ u m p t i o n ~although more recent work suggests alternative chemicals ~ , are now beingused.54 Additionally, significant risks from pesticide POPs are posedby a number o f contaminated sites that are likely to require remediation, such as the closed DDT plant inthe BCIC Chemical Complex inChittagong, and obsolete stocks inseveral agricultural pesticide godowns inKhulna, Chittagong and Bogra districts, as well as the DOH warehouses inChittagong, together amountingto about 500 MT. 47Awal, 2001, SUNS 1998, SOS-arsenic.net, 2004, Toxic Link,2004 48Ramaswamy, 1992 49Alam et al. 1999, andMatinet a1 1998, cited inHossain, 2005 50Meisner, 2004 51Malek et a12002, cited inHossain, 2005 52Personalcommunication with Dr ShahadatHossain, Institute o f MarineScience, Universityo f Chittagong, Bangladesh 53Khan1998. The use of DDT indrymgfish was first reportedinBangladeshbythe Aquatic ResearchGroup, Institute of MarineSciences, Chittagong University 54 DOE POPSProject 21 Manufacturing -a Variety of Likely POPs Sources 65. An estimation o f sector-wise pollutionbasedon applying standardpollution coefficients to manufacturing data for B a n g l a d e ~ hidentifiedthe following the industrial ~ ~ sectors to be o f greatest concern (i) steel, (ii)industrial chemicals, (iii) (iv) textile cement, dyeing and finishing, and (v) pulp and paper. Among the POPs produced bythese sectors, PCBs are estimatedto pose the gravest risks, and the most affected districts are Chittagong, Naryanganj, and Dhaka, which together account for an estimated 90% o f the POPs generated bythese sectors. The principal modes ofPOPs generationinthese sectors are as follows: steel - scrap from the ship-breaking industry,used as raw material inthis sector contributes to the formation o f dioxins and furans, and even possibly PCB; chemicals - the main sites are the old DDTplant inChittagong and a privately- owned owned caustic soda facility, producing elemental chlorine and other chlorine basedproducts; cement - POPs are releasedinthe kilno f clinker-producing cement plants, two o f which exist inBangladesh; textiles -textile and leather plants contribute more than 20% o f the total dioxins and furans emissions due to usage o f chlorinated chemicalss6,or dioxin-contaminated dyestuffs.57 The textile plantslocated along the Dhaka-Chittagong economic corridor and the leather plantslocated inHazaribagh (Dhaka) are hotspot areas; pulpandpaper the use o fchlorine and chlorinated compounds inbleaching andde- - inkingprocesses causes dioxin and furancontaminationo f effluent from this sector, possibly one o f the largest sources o f dioxins and furans inthe country. 66. Other industrial sectors that warrant particular attention for the control o f POPS include oil refining and brick-making. Oil refining i s known to produce dioxins, furans and PCBs, andthe same POPs are likely to be generated bythe use o f a range o f dirty fuels in brick-making, includinglignite, tires and h a c e oil. Ship-Breaking -a Potential POPs Hotspot 67. At present, morethan30 ship-breaking yards operate onthe beaches o fChittagong, dismantling some 60-80 large ocean-going ships every year. These beaches constitute the largest ship-scrapping facility for large vessels inthe world, accounting for more thanhalfo f all vessels above 200,000 dwt scrapped worldwide in 1997-98. Dating from a periodwhen PCB-use was widespread, it i s expectedthat many o f these ships contain PCBsintheir paint, cables, waste oil, lubricants and electrical systems, estimated to total some 250-800 kgsper ship.58Activities relating to the ship breaking sector that augment the risk o fdioxin and PCB contamination include unregulated disposal o fwastes (open-air burningo f PCB-based PVC cables), recycling o f waste oil and use o f metal scraps inthe iron and steel industry. An 55M.Huq,2004 56Especially PCP (pentachlorophenol) and chloronitrofen. Das (2005) 57For example dioxazines or phthalocyanines 58Toxics Link, 2004 22 investigation o f soil samples fi-om steel plate reprocessing plants at ship-breaking yards found elevated levels o fPCBs, although these were not detected inadjacent sea sediments.59 Power Sector -a Legacy of PCBs 68. The amount o fPCBs that exist inthe transformers and oil circuit breakers o fthe power sector inBangladesh, as well as the amount that may be stored either for replenishment or as waste, has been quantified as part o fthe draft POPsNational Implementation Plan. While recently-imported equipment i s understoodto be PCB-fi-ee, it i s estimated that older equipmentmay contain some 500 tonnes o fPCBs, with perhaps a further one-tenth o fthat amount instorage or waste containers. Seven PCB-contaminated sites have been identifiedinBangladesh,which mainly includeelectric workshops for transformers and capacitors inGazipur, Bogra, Chittagong, Dhaka and Jessore. Other Signifcant Sources 69. A nurnberofmiscellaneous sectors contribute significantlyto dioxins and furans emissions. These include waste disposal and incineration activities (28%), fossil-fuel power generation andbiomass heating including household heating and cooking (15%) and uncontrolled burning(22%), as reported inthe Draft National Implementation Plan. Institutions and Policies 70. Issuesassociatedwith the management o fPOPSand other toxic chemicals raise a range o f challenges for Bangladesh. As a first step inmeeting these, the registration o f all POPspesticides hasbeenwithdrawn, along with all authorizations for the use o f chlorinated hydrocarbons as pesticides. Inaddition, all nine intentional POPs are bannedinmanufacture, use andtrade, except DDT, for which restricted use for vector control i s permitteduntil safer methods canbe adopted. As a signatory to the Stockholm Convention, Bangladesh i s preparing aNational Implementation Plan (NIP) to develop POPsmanagementpractices and solutions. This exercise i s beingledbyMoEF, which under the Environmental Conservation Act o f 1995 i s responsible for chemical safety, incollaboration with the Department o f Agricultural Extension (DAE) and Bangladesh Power Development Board (PDB) as co- implementing agencies. On the basis o f inventory analysis, infrastructure assessment, and disposal options, the draft NIP proposesa list o fpriority actions, dividedinto short- andlong- term initiatives. The short-term actions focus on buildinginstitutionalcapacity and establishing the policy framework, while the longer term proposals include POPs control action plans. Elements of a POPs Management Strategy 71. The broadelements o f a strategy for strengthening the management o fPOPSwould include the following: establishing dialogue andpartnerships with relevant govenunent agencies and other stakeholders(including industryassociations, bilateralagencies and civil society), since recognition o fthe POPs issue i s at a nascent stage; 59Det Norske Veritas, 2000 23 identifylng POPS-related prioritiesbasedon a soundtechnical understanding o f the chemicals management issues as well as relevant national and international policies; identifylng sustainable intervention programs and policies that deal with cleaning up contaminatedsites or obsolete stockpiles, monitoring o f exposure andeffect, buildinginstitutional capacities and implementing cleaner technologies, among others; and, engaging ininformation dissemination and awareness-raising. V. EnvironmentalHealth:RecommendationsandAreas for World BankSupport 72. Environmental health concerns are multi-sectoral issues, so institutional arrangements are critical to the success o f all initiatives. For any particular initiative, it i s important to identify a lead agency to pushthe agenda and coordinate others effectively. It i s also important to build awareness o f the extent o f the health risks involved, as well as the understandingo f cost-effective mitigationmeasures, inorder to buildbroad-based support for their management. Sanitation 73. The Government's commitment to Total Sanitation is an essential step towards addressing the single most significant environmental threat to the nation's health, and merits the full support o f development partners and civil society. Successful achievement o f the goals o f the Total Sanitation campaign will entail overcoming a number o f challenges, however, not least o f which i s the allocation o f sufficient resources. To achieve the goal o f year-round sanitation, considerationmust also be given to providingtemporary or permanent latrines inshelters or refuge sites adequate to meet the sanitary needs o f the affected community duringfloods. 74. Inurbanareas, while the long-term aimmustbeto extendthepublic sewer system, there are manynew and expanding developments, as well as existing slums, that will not receive trunk connections inthe foreseeable future. For these areas, there i s a clear need for the development o f alternative solutions. Inaddition to the technical assistance providedby the Water and SanitationProgram to the Total Sanitation campaign, the World Bank i s also proposing to provide support for improved sanitation through the planned Dhaka Chittagong Water Supply and Sanitation Project, and the DhakaEnvironment and Water Resource Management Project. Safe Drinking WaterSupply 75. The provision o f arsenic-safe, microbiologically-clean drinkingwater remains a major challenge for Bangladesh. Efforts inthis area should be accelerated, aimed at providing a choice o ftechnologies to meet the varied situations o f the unservedpopulation, targeting arsenic mitigation interventions at households exposed to highlevels o f contamination, and ensuring that such interventions significantly reduce arsenic exposure without increasing the risk o f waterborne disease. 76. Achievement o f the Government's goals for the supplyo f safe water will require an expansion o f service coverage to better reach disadvantagedsocial groups. Urban areas will 24 require major investment to meet the growing demand for water, inadditionto significant improvements incost recovery inorder to meet operation and maintenance costs. Improved service levels inwater supply will require greater involvement o f local governments, the private sector and civil society. To ensure the quality o fthese services, the Government should be supported inits plans to establish an independent regulatory framework to supervise andmonitor performance. As indicated inthe BangladeshCountry Water ResourcesAssistance Strategy,60the World Bankwill continue to be involved inthis sector through both the Bangladesh Water Supply Program Project, the Dhaka Chittagong Sewerage andDrainage Sector Project, andthe proposed Dhaka IntegratedEnvironment andWater Management Project. Indoor Air Pollution 77. Opportunities shouldbe explored to integrate the mitigation o f IAPinto existing programs, for example through rural energy (Ministryo fEnergy), clean cookingtechnologies (including improved stoves andbiogas, with leadership fiom the Ministry o f Science and Technology), andvillage sanitation (Local Government Division). While such initiatives may include a subsidy, at least ininitial stages, these should be targeted towards the sustainableprivate sector provision o f suchtechnologies inthe longer term. 78. Since better ventilation and longer outdoor time for children are affordable and acceptable for poor families inBangladesh, andmay reduce IAPexposure to much safer levels, promotiono f these simplechanges is strongly recommended for immediate action. Giventhe current low level ofawarenessofthe consequenceso fIAP,however, achieving suchbehavior change will require a concertedpublic education effort aimed at explaining the healthbenefits o freducing exposureto smoke from biofbels. One possible mechanism to promote greaterpublic awareness would be to incorporate IAP messagesinthe Total Sanitation campaign. The World Bank could support further exploration o fthis approach through the provisiono fnon-lending technical assistance. UrbanAir Pollution 79. Mobile sourcesremainthe priority for emissions control inurbanareas. Measures aimed at controlling the age o fvehicles needto be assessed, as well as the further promotion o fpublic transport. Dieselvehicles are aparticular concern inDhaka, andthe World Bank- supported Air Quality Management Project has commissioned a study to assessthe options for controlling emissions fiom these sources. It i s clear, however, that the sulfur content o f importeddiesel should meet international specifications (Le. not exceeding 500ppm), andthat initiativesto control emissions should focus on gross diesel polluters, particularlytrucks and buses. More generally, it i s essentialto sustain and expand the monitoringo f ambient air quality. Currently this i s conducted ina limited fashion only inDhaka, but it should be extended to other major cities, as well as to providebetter coverage inthe capital. The World Bankwill continue to support initiativesinthis areathrough the Air Quality Management Project, for which a follow-up operation may be considered. 6oWorld Bank,2005b 25 Persistent OrganicPollutants 80. AlthoughPOPspesticides were completely banned for use inagriculture in Bangladeshfrom 1997, andrecently-imported electrical equipment i s understood to be PCB- free, the health risks associated with POPs are an emerging concern inBangladesh, for which itwill be important to establish dialogue andpartnerships with relevant government agencies and other stakeholders (including industry associations, bilateral agencies and civil society). The identification o f POPS-related priorities must be based on a sound technical understanding o f the chemicals management issues, as well as relevant national and international policies. Once priorities are agreed, interventionprograms may be established for cleaning up contaminated sites and obsolete stockpiles, monitoring exposure and effects, engaging ininformation dissemination and awareness-raising, and adopting cleaner technologies. The World Bank can assist the Government inaccessing global grant resources to support these activities. 26 Chapter 3: Management ofWater Quality inDhaka I. Dhaka:aMega-CityunderStress 81. Dhakai s the eighthlargest city inthe world, with apopulationo f about 12million people inthe Dhaka Statistical Metropolitan Area61(DSMA), accounting for about one third o fBangladesh's urbanpopulation. By 2015, assuming current populationgrowth trends, the DSMAwillhave apopulationofabout 21 million, andmaybethe fourth largest city inthe world.62 InDhakaCity (the metropolitanarea administeredby DhakaCity Corporation, DCC), the populationdensity i s one o fthe highest inthe world, at more than 20,000 people per square kilometer.63 About 4.2 millionpeople live inslum areas, and it is estimated that upto 55% ofDhakaresidents livebelow the povertyline. Most ofthe poor lack access to clean water and adequatesanitation facilities, andmany live insqualid conditions nextto extremely pollutedwater bodies. 82. Giventhe size and growthrate ofthe city's population, andthe significance ofthe DSMAto the national economy (contributing some 20% ofGDP), the host of environmental challenges facing Dhakaconstitute aproblem o fnational concern, meritingparticular attention inthe broader effort to strengthen environmental management withinthe country. 11. A Triple Threat: Contaminationof the Air, LandandWater 83. Chief among Dhaka's environmental challenges are risks to human health and natural resourceproductivity from the poor quality o f air, inadequatemanagement o f solid waste, and contamination o f surface and groundwater inand around the city. While initiatives are underway to better manage air quality and solid waste, little has yet beendone to improve water quality, although the economic costs associatedwith water pollution are estimated to exceedthose attributable to poor air quality and solid waste. 84. Despite important steps inreducing air pollution, particularly through the phasing out o f leaded gasoline and two-stroke three-wheelers, concentrations o frespirable particulate matter inDhaka exceed standards for morethan 100days o fthe year, contributing to an estimated 3,500 premature deaths annually as a result o fpoor air quality inthe city. The economic costs associatedwith death and disease causedbypoor air quality inDhaka are estimated to be inthe order o fUS$500 millionper year. Effortsto addressthis threat continue under the Departmento fEnvironment's (DOE'S) Air Quality Management Project, focusing on reducing emissions from gross polluters (particularly trucks andbuses), improving fuel specifications (particularly reducing sulphur indiesel), and increasing public support for air quality improvement initiatives through monitoring and dissemination o f air quality information. 85. The managemento fsolid waste inDhakaremains amajor challenge. The population o fmore than five millionpeople living within the area covered byDCC produces about 3,500 tomes o f solid waste daily, o fwhich only 42% i s collected and disposed o f at an open, 61Comprising the areas administeredbyDhaka City Corporation (DCC), Dhaka District, Gazipur District, and Narayanganj District 62Lizin, 2002 63BCAS, 2004 27 unlinedlandfill site64. The unsanitary conditions createdby the poor management o f solid waste impose economic costs inthe form o f health impacts, blocked drainage and aesthetic insults. A promisingnew direction has beentaken, however, withthe agreement between DCC andanNGO for privatemanagement o fthe landfill, with carbon financing insupport o f composting and methane recovery being usedto augment the revenue stream. Inaddition, DCC with support from the JICA is preparing a master planfor solid waste management in Dhaka city. 86. Dhakai s surrounded by rivers and inter-connectedwith canals which have always formed a life-line for city residents. Inthe last twenty years, a convergence o funregulated industrial expansion, rural-to-city migration, encroachment o f the rivers, overloaded infrastructure, conhsion about institutional responsibility for the quality o f Dhaka's water bodies, andvery ineffective enforcement o f environmental regulations have all taken their toll on surface water quality. There i s only one sewage treatment plant at Pagla which i s currently operating below capacity because o f sewerage system failures, andfew industries operate effluent treatment systems. Almost all the waste from humans, industry, and millions o f farm animals, along with tomes o f pesticides and fertilizers, make their way into Dhaka's surface water untreated, and a percentage o fthese wastes infiltrate to the groundwater. As a result, pollutant levels inthe groundwater are increasing, and many sections o fthe rivers and canals inthe city and surrounding areas, especially the Buriganga and Sitalakhya, are biologically dead during the dry season, spurringwidespread public concern andprompting reaction at the highest political levels. 111. The Economic and Social Costs of Water Degradation 87. Dhaka surface water i s invery poor condition, especially inthe dry season. For some six months o fthe year, the flow rate o fthe rivers is negligible, oftenwith only a tidal pulse, butthe volume o f effluent enteringthe canal andriver systemremains about the same as duringthe wet season. Consequently, dilution o f contaminants is drastically reducedinthe dry season. As Figure 3.1 shows, the most polluted areas are the Buriganga and Sitalakhya Rivers, Tongi Khal, and the canal system inDhaka East, where very low oxygen levels reflect the breakdowno f organic waste, principally domestic sewage and chemical residues from industry. The highlevels o f oxygen demand inthe Buriganga and Sitalakhya Rivers, in particular, reflect the highdensity o f industries discharging untreated waste into the rivers. Some tidal backflow o f relativelyclean water fkom the Meghna and Dhaleswari Rivers results indilution o f contaminants inthe southernreaches o f boththe Buriganga and Sitalakhya Rivers, as may be seen inFigure 3.1, but the extent o f this positive effect i s limited. 88. The very highammonia levels shown inTable 3.1, particularlyinthe canal system in Dhaka East, inthe BaluRiver, and inthe southernreaches o f the Buriganga River, reflect the discharge o f sewage into these waterways. Most o f this water i s unfit for any humanuse, and i s likely to be dangerous to livestock. Of particular concern inthe dry season are the high ammonia levels inthe raw water usedby the Saidabad Water Treatment Plant, which now threaten the plant's ability to treat the water to drinkingquality standards. The intake for the Saidabad plant i s located at Sarulia, near the confluence o f the Balu and Sitalakhya Rivers, one o f the Dhaka water pollution "hotspots" (see Figure 3.1). Ammonia inthis area increases 64Waste Concern, 2005 28 from about 0.3 mg/linOctober to greater than 10 mg/linMarch-April, which i s twenty times higher thanthe national environmental quality standard for ammonia insurfacewater. Ammonia binds to the chlorine inthe treatment plant, forming mono, di-, andtri- chloroamines, which significantly reduce the bactericidal effect o f chlorine. As a consequence, the chlorine inputsto the processhave to be increased (sometimes from 0.2 ppmto 5 ppm). This increasesthe risk to humanhealth, as well as increasingthe cost o f plant inputsand raising questions about the overall effectiveness o f chlorine treatment. 89. The water qualityproblemis further reflected byhighlevels ofe-coli bacteria, which are indicators o fthe potential for more harmhlbacteria andviruses inthe waterways, including hepatitis viruses, typhoid, dysentery, andvarious other infectious bacteria. Levels o f e-coli bacteria higher than 1O,OOO/ml o fwater have beenrecorded inNorai Khal inthe last six years. All Dhaka residents are impacted to some extent by deteriorating water quality, butthe most vulnerable arethe poor, who have few options for accessingclean water and little ability to move away from offensive locations nextto pollutedponds, canals, and rivers. Inadditionto the lostproductivity andhealthcarecostsassociatedwithwaterborne disease, a recent survey o fhousehold willingness to pay for improved riverwater quality inthe Dhaka area suggeststhat the loss o f amenity associatedwith contaminated surface water amounts to about 0.5% o fthe region's GDP.65 90. Groundwater resources are becoming increasingly polluted. Recent data66on groundwater quality show elevated andincreasing levels o f dissolved solids, both inthe upper (5 to 200 metersbelow surface) andthe lower (below 200 meters) aquifer. The total groundwater abstraction from licensedproductionwells operatedbythe DhakaWater and SewerageAuthority (DWASA) and private (mainly industrial) operators i s around 700 M C M peryear, or 80% ofthe total monitoredwater supplyto Dhakacity. The quantity ofwater abstractedfrom unlicensed wells i s not known, but i s estimated to be significant, since groundwater serves as the main water supply for areas that are not connectedto the water supplynetwork. Consequently, the infiltration ofindustrialeffluents to groundwater has severe adverse impacts on quality o fpotable water suppliesand potentiallyposes a serious risk to public health. This risk has only recently beenrecognized by the responsible agencies, and inresponsea program to monitor groundwater contamination i s being implemented. As more data from this program becomes available, the extent o f groundwater pollution, the impact o fthis pollutiononpublic health, andpossible remediation measures can be identified. 91. More than 80% o fthe DSMA i s still usedfor agriculture and fisheries, butthese activities have declined as pollution has increased. Inpolluted areas, some 45% o f households report persistent lossesinthe productiono frice, andmorethan20% are experiencing productionlosses invegetable crops. Reflectingexperience with the death o f livestock after drinkingriver water, lessthan 15% o fhouseholds inhighlypolluted areas allow livestock to drink river water, compared with more than halfinthe past. It i s estimated that agricultural and fisheries productioninthe DSMAmaybe reducedby about one thirdas a result ofpoor water quality. 67 65Alam et al, 2002 66DWASA andIWM, 2005 unpublished 67BEMP, 2004a 29 Table 3.1: Water Quality inthe River and Canal System around Dhaka, 2003 2004 - (BurigangaRiver) DhaleswariRivers SaidabadBee1 92. A benefit-cost assessment conducted for BangladeshEnvironmental Management Project (BEMP)68 examined the economic costs associated with poor water resource management inthe DSMA. Setting aside the costs associated with inadequate water supply and flood control, the assessmentidentifiedannual costs amounting to some US$400 million linked to poor surface water quality, including lost agricultural and fisheries production (17%), costs to industry(22%), lost amenity (21%), and healthcosts (40%). IV. Policy and Institutional Factors AffectingWater Quality 93. The institutional fi-amework for management o f the city and its environment i s chaotic. There i s a serious problem o f overlappingjurisdiction betweenmany Government agencies, which often leads to inaction. The legislated roles and responsibilities o f Government institutions that have some involvement with Dhaka waterways are summarized inBox 3.1. Currently there isnomechanismfor coordinating the planningand implementation o f the activities and interventions of all these stakeholders. Strategic Management of the Sub-Basin 94. Regardlesso f the choice o ftechnical interventions to improve the quality o f surface water inDhaka, they need to fit within a coherent long-term strategy, which adopts an integratedperspective to the management o f water resources inthe Dhaka regiondrainage sub-basin. Currently there i s no such strategy. The RAJUK Structure Plan(1995-2015), which includes protection o f waterways and floodplains, has largely been ignored inpractice, andis already out of date. Inthe absence o f a single authority having comprehensive responsibility and decision-making power for all water quality andurbanhabitat issues inthe DSMA,reliance mustbeplacedona coordinatingmechanismbetweenthe manyGOB agencies with roles to play. 95. Buildingonthe FloodAction Plan's integratedlanduse study for Dhaka, a strategic approach to the management o fthe sub-basin's water resources would address water quality, water supply, sanitation, and flood management inan integrated fashion. All interventions that deal with water quality will fall under the over-arching policies and directions o f the recently approvedNationalWater Management Plan (2004) and therefore needto be consistent withthe guidingprinciples inthe plan. The N W M P i s a progressive strategy that embraces an increasedrole for stakeholders inmanaging water, and the use o f economic instruments to encourage wise allocation anduse o f water, while assigning a more realistic value to access, treatment, and delivery o f water, and the use o f waterbodies. Compliance Promotion through Prioritization, Institutional Incentives and Waste Minimization 96. Although there are sufficient regulations inplace to control most activities that may have harmful effects on the urbanenvironment, inpractice these are largely ignoredand enforcement i s very weak. Inparticular, the current impunitywith which industrydischarges effluent into rivers and canals mustbe checked if surface water quality i s to be improved, requiring stricter enforcement o f environmental clearance conditions and effluent standards. Recognizing DOE'S limited manpower and technical capability inmonitoring and enforcing BEMP, 2004c 32 environmental regulations, any programo f enhancedregulatory activities mustbe focused on priority sources o f contamination. The institutionalincentives for DOEstaff to strengthen enforcement must be re-examined, basedon a consideration o fperformance indicators, transparency and accountability. Box3.1: Responsibilitiesof GovernmentInstitutionsRegardingDhakaWater Quality Departmentof Environment:UnderMinistry o fEnvironment andForests: enforcement o fenvironmental rules (environmental impact assessment; environmental clearances; effluent standards); setting environmental quality standards for water uses; routine monitoringo fwater quality; technical inputto various GOBcommittees; administration o fthe Open Space and Wetland ConservationAct, 2000 and UrbanWater Body ProtectionLaw, 2001. DhakaCity Corporation:Under Local Government Division(Ministryo fLocal Government, Rural Development and Cooperatives): responsible for handling and disposal o f solid waste; issuance o fbusiness licenses; management o f public green spaces; mosquito control; provisiono fpublic toilets; maintenance o f public bathing and washing locations; surface drainage from roads; maintenance o f some lakes (such as Dhanmondi); control o f markets; operation o fhealth facilities; flood control measures; regulation o f private sources o fwater supply; city planning; now participating inDhaka Good Governance Committee, under Principal Secretary, PMO. Adjacent Districts:DeputyCommissioners, acting under the Ministryo fLand, for Dhaka District; Gazipur District; Narayanganj District: local adrmnistration o f infrastructure and services inthese districts, many o f which have a direct bearing on water flow and water quality; any project, such as waste treatment, that has land requirements will go through the DCs; municipalities andunion parishads inthese districts covered bythe Pourashava and UnionParishad Ordinances (underMinistryo f Local Government, Rural Development and Cooperatives), giving themjurisdiction for waste disposal andpollution management within their boundaries. RajdhaniUnnayanKartipakha(RAJUK):Autonomous bodyunder Ministryof Housing andPublic Works: planning for development and landregulation inurbanareas; jurisdiction for Dhaka City and surrounding areas inGreater Dhaka, including preparation, implementation, andmonitoringofamaster plan; creationofplanned townships, withrelated infrastructure; development control, including approval o f plans for landuse; jurisdiction over GulshanLake; presently completing Detailed Area Plans for Dhaka. DhakaWater and Sewerage Authority: UnderMinistryo fLocal Government, RuralDevelopment and Cooperatives: provision o fpure, safe, and dependable water to Dhaka citizens (including Naranyanganj); regular, safe, continuous disposal o f sewage; operation and maintenance o f drains for stormwater disposal; collection o f fees for these services. Water DevelopmentBoard: UnderMinistryo fWater Resources andFloodControl: planning and implementation o f water-related projects at the national level that involve infrastructure (direction and flow o f water; mostly embankments and flood control); coordination o f implementation o f the National Water Management Plan (withWARPO). Ministryof Land:Register o fgovernment title for land (through Departmento f Survey and LandRecords), including riverbedsand contiguous land; through the Deputy Commissioners, leasing o fthese lands, and eviction, as necessary; administration o f land compensation process for private lands. Departmentof PublicHealthEngineering:UnderMinistryo fLocal Government, RuralDevelopment and Cooperatives: outside the DCC area, responsible for rural water supply; monitoring o fwater quality. BangladeshInlandWater Transport Authority: Under Ministryof Shipping: development, maintenance, and control o f inland water transport and maintaining navigable waterways; involvedinriverbank protection on the Buriganga and demolition o f structures inriver buffer zone; dredging, shpping terminal maintenance, and waste disposal at these facilities. Departmentof Shipping:UnderMinistryo f Shipping: responsible for survey andcertification o fships and boats inthe river system (including seaworthmess and waste management). MinistryofIndustry: Overallpolicy direction for industrial development; arole indevelopment o findustryin specified zones and compliance withpollution control regulations infactory design. 33 97. Inadditionto DOE,there is aclear incentive for DWASAto beinvolvedto agreater extent inthe enforcement o f environmental compliance, since DWASAbears the increasing costs o fwastewater and drinkingwater treatment as a result o f indiscriminate effluent disposal. Stricter enforcement o f effluent standards would also help stimulate demand for alternative approaches to waste treatment that may reduce industry's operational costs and increase productionefficiency, as well as bringingenvironmental benefits. Inresponse to this demand, technical assistance for waste minimizationinitiatives could be providedas part o f a broader programo f compliance promotion. Building Support through Consultation, Transparency and Participation Evenwithout additional enforcement activities, international experience has demonstratedthe power o f enhanced monitoring when the results are disclosed, and the environmental performance o f individual facilities i s publicly recognized. There i s significant scope for DOEto adopt such an approach, focusing on priority sources o f contamination, and applying "e-government techniques to make the results o f environmental monitoring and decision- " making as transparent as possible. Increasedtransparency would also strengthen the role o f community groups and NGOs in the organization o f Dhaka environmental management initiatives. NGOs are already making valuable contributions to the improvement o f the Dhaka environment, for example through trials with composting and slum improvement projects, and their participation must be welcomed and recognized to build the community support required for stronger regulatory action. Attracting the ResourcesRequired 98. The resources required to address Dhaka's environmental challenges will be significant, with estimates rangingup to US$ 8 billion over 20 years.69 Maintenance and expansion o f the urbaninfrastructure has been neglected, and major overhauls are now required. Mobilizing resources o f this scale will require private sector participation, in addition to the support of development partners. Attracting private investment, evenmore so than development assistance, will require institutional reformthat provides strategic direction and clarity o f roles, and supports the recovery o f costs for urban services as well as the transparent enforcement o f regulations. V. Responsesto Water QualityIssuesinthe DhakaArea 99. The deteriorating condition o f the Buriganga River inthe mid-1990s stimulated the "Save the Buriganga" movement, a collaboration o f various Government agencies and NGOs. Most o fthe effort focused onpublic awareness, processions, monitoring o fthe Dhaka canal and river system, and destruction o fbuildingsthat encroached on the Buriganga River. More recently, the Prime Minister reactivated the River Committee, which reported in January, 2004, listing a series o fproposals that deal with water supply, flow, and water quality (see Table 3.2). 69BEMP, 2005a 34 Table 3.2: River Committee Proposals for Water Resource Management inDhaka7' Brola0sal;ol.I4iW-ve Flood RetentionPonds in Concept more or less defunct; many o fthe proposed flood retention ponds have RANKDhaka Structure Plan been filled in; this concept is not being actively pursued by any GOBagency; RANKrecently startedwork onDetailedArea Plansfor Dhaka. EasternEmbankment cum Includedinthe Prime Minister's River Committee Report (January, 2004), this By-Pass Road was recently passed over by the Planning Commission; concerns about highcost, (WDB andDWASA) technical complications, andpotentialnegative environment effects; has recently been re-activatedbecause o f the 2004 flood; undergoing technical feasibility analysis and environmental screening. Augmentation o f Flow inthe These various initiatives included inthe Prime Minister's River Committee Buriganga River, Circular Report; augmentation of flow still requires more analysis (potential problems with Waterway Project (WDB and upstream water abstraction andnegative environmental effects); circular BIWTA) waterways project partially completed (not fully funded, but a recent announcement o f additional US$ 10million GOBfunds for walkways and barriers); preventiono f river encroachment has involved occasional demolition o f structures on the Buriganga River. Saidabad Water Treatment Fundingfor Phase2 being sought (now being consideredbyDANIDAand Plant (DWASA) SIDA); ongoing issue with ammonia contamination and excessive algae inwater supply; DWASA favours movingthe Sarulia intake up the SitalakhyaRiver (this i s controversial); other options include an ammonia scrubber at Saidabad or an intake on the Meghna RiLer ( a long-term solution). North Dhaka Sewage Includedinthe Prime Minister's River Committee Reuort: DWASA has had Treatment Plants difficulty securing financing; small "footprint" multi-storey sewage treatment (DWASA) plants (Bangkok model) promoted duringrecent consultations inDhaka. Upgrading the Pagla Sewage Some o fthis work has been undertaken by DWASA, with JICA funding; Treatment Plant; Extending however, stalled due to lack o f full funding; infrastructure division at World Bank the DWASA Sewage is actively considering this initiative. Network Moving the Hazaribagh Included inthe Prime Minister's River Committee Report; BSCIC has purchased Tanneries to Savar (BSCIC) some landinSavar and 200 plots are beingprepared, but the tannery industry i s still lobbying GOBfor financial subsidies to support the move, and proper environmental management facilities are not clearly documented; very high priority initiative. Common Effluent Treatment Still only a concept; LGRD has asked for more technical details and cost analysis Plants (CETP) for Industry from the Bangladesh University o f Engineering andTechnology; could also to be (DOE) supportedby a proposed constructed wetland near Norai Khal, for Tejgaon industries, and common reedbeds for textile industryclusters; ongoing experimentation with waste minimization, settling ponds, andreedbeds for the textile industryinNarsingdi, a collaboration o f BEMP, DOE,and textile industry associations -this has produced positive results showing technical effectiveness andcost efficiencies; recent interest incombining CETPs with constructed wetlands ina "hybrid" system. Dhaka SolidWaste Includedinthe Prime Minister's River Committee Report; JICA has been Management undertaking design work over the last year; Waste Concern has been (DCC) experimenting with small composting facilities and is proposing larger-scale composting andmethane recovery at Matuail; full funding still being sought. 100. Subsequently, the consultative processfor the DhakaEnvironment Programme (an initiative o fMoEF)resulted ina portfolio ofpotential solutions to address water quality issues inDhaka. The solutions were clustered according to key issues, summarized below, in order ofpriority (highestto lowest - see Appendix Ifor details): 70As o fJanuary, 2005, updated from BEMP, 2003 35 improvement o f water supply; treatment and disposal o f sewage; treatment and disposal o f industrialeffluent; handlingand disposal o f solid waste; flood management, dredging, and improving river navigability; management o f household liquidwaste; management o f ship oily waste; improving aesthetics and opportunities for recreation; controlling agricultural runoff. Investment and Institutional Strengtheningfor improved Water Supply and Sanitation Services 101. The supply o f safe water and treatment o f sewage are the clear responsibility o f DWASA and require major overhauls o f infrastructure, as well as significant investment in new distribution and collectionnetworks and treatment plants. DWASA i s presently involved indiscussions with a number o f Development Partners, including the World Bank, to address these issues. Inparticular, GOBhas requestedassistance from the Bank to prepare a project to improve water supply, sewerage, sanitation and storm water drainage services in Dhaka. The sewerage and sanitationprojectplans, among other improvements, to rehabilitate the existing sewer systems, storm water drains and natural retention reservoirs, and buildnew storm water pumpingstations inDhaka. The main objective o f the "Dhaka Sewerage" sub-component would be to rehabilitate existing trunk sewers and extend secondary and tertiary sewers to reach new customers so that the full capacity o f the Pagla sewage treatment plant can be used. 102. DWASAis currently indiscussions with developmentpartnersto finance an expansionto the Saidabad Water Treatment Plant, rehabilitation and improvement o f services o f the water supply distribution network, as well as urgently neededimprovements to the sewerage network andthe Pagla Sewerage Treatment Plant. DWASA and development partners are coordinating closely to ensure that overlaps are minimized and that no gaps occur inthe neededinvestment to Dhaka's water supply, sewerage and drainage system. DWASAhas already begunto implement a performance improvement programfor the utility,which focuses onkeyoperating and financial indicators to monitor improvement in DWASA's service inwater supply, sewerage and drainage operations. TargetedEnforcement and Low-Cost Treatment Options to ControlIndustrial Effluent 103. The remaining priority water quality challenge i s treatment o f industrial waste. Of the challenges noted above, this i s the one that i s most inthe control o f the private sector, and currently the least effectively handledby regulatory agencies. To date there has been little to no enforcement o f environmental regulations, and as a result, industrypollutes the surface waters o f Dhakawith impunity. To reduce the pollution o f surface water bodies, both on-site andcentralizedtreatment o findustrial effluents are required. To reduce the pollution o f groundwater bodies, a reduction o fpollutants leached to the aquifer can be achievedby on- 36 site treatment incombination with improved conveyance o f effluents to a centralized treatment facility. 104. The Government has requestedassistance from the Bank to reduce the pollution o f water bodies by industrialeffluent. The proposedintegrated environment and water managementproject will invest intreatment options for industrialeffluent, andwill also build appropriate capacity for improvedmonitoring o fpollution and the more efficient enforcement o f environmental compliance. As the main agency responsible for water quality andwater treatment inDhaka, DWASAis likely to be the principal implementingagency for this project, while DOEwill be involved inall components, especially those related to environmental monitoring and compliance. 105. The mainindustryclusters and effluent "hotspots" includethe tanneries at Hazaribaghwhich pollute the Buriganga River, the Tejgaon Industrial Area which drains to the BaluRiver, the Tongi IndustrialArea which pollutes Tongi Khal, the Sayampur and Fatullahindustrial clusters inDhaka South andNarayanganj which discharge to the Buriganga River, and the developing heavy industrystrip along the Sitalakhya River. A comprehensive strategy to bringindustrial effluent under control at the industrialsites would include at least the following four elements: 0 Tighter control on new industrial development inthe center o f the city, through more effective application o f the EIA system. Credible use o f the EIA approval process to require investment inadequate on-site or shared effluent treatment facilities would reduce the attraction o f land-scarce city center locations for new developments, and would have the effect o f encouragingthe development o f industrialzones outside the city that can properly service all industrial waste. 0 Inadditionto controllingnew development, the EL4systemcould also beusedmuch more effectively to manage effluent fiom existing facilities. Under the Environmental Conservation Rules (1997), industries inthe Orange and Red Categories are required to renew their Environmental Clearance Certificates annually. Although little used at present, this requirement offers a clear opportunity for the DOE to agree on compliance plans with priority polluting facilities, which ifcombined with anenhanced program o f environmental monitoring and regulatory action, would gradually increase pressure to reduce contamination. 0 The development o f compliance plans linked to annual renewals o f Environmental Clearance Certificates would also stimulate demand for technical assistance for waste minimization. Such assistance, potentially drawing on the I S 0 14001model o f environmental management systems, could be offered by the DOEas a component o f the compliance planningprocess. The added advantage o f the introductiono f environmental management systems is that it provides businesses with a tool to optimize productionprocesses whilst reducing waste and improving the efficiency o f energy use. 0 Development o f shared waste treatment facilities. Inplanningsuch investments, two key principles should be adhered to: (i) maximize the involvement, both financial and technical, o f the industries whose effluent the facilities are intendedto handle; and (ii) minimize the capital and recurrent costs involved. Inparticular, it should be clear 37 that the operating andmaintenance costs o f waste treatment will be borne by those generating effluent, basedon a per unit volume charge. 106. A reductioninthe discharge of effluents to vulnerable surface water bodies canbe achievedthrough appropriate treatment trains o f primary, secondary andtertiary treatment technologies, including wastewater stabilization and retention ponds, as well as constructed wetlands. Due to the highpollutant load o f the effluents, a single treatment option will not achieve the desired effluent quality; consequently, a successfultreatment strategy i s likely to consist o f a combination o f appropriate treatment technologies. 107. Constructed wetlands incombination with primary and secondary treatment, such as waste stabilizationponds, offer one possible approach to minimize the capital and recurrent costs o f treating industrial effluent. International experience has demonstratedthe effectiveness o fusingreedbeds to strip contaminants from a variety o f waste streams, and recent positive data &om reedbed experiments inNarsingdi7*have stimulated interest inpilot implementation o f constructed wetlands inthe Dhaka area. Results from the Narsingdi pilot indicate that constructing and operating a settling tank and reed bedwastewater treatment system, excluding the cost o f land, increases the annual operating costs o f small andmedium- sized textile factories by only 0.5%. Amortized over ten years, the purchase o f land required for a reed bed could increase annual operating costs o f textile factories by a further 2%. In comparison, the costs o f mechanical and chemical waste effluent treatment systems are up to 5% o f the annual operating costs o f larger textile factories. 108. Assessment o f the feasibility o f a constructed wetland initiative inDhaka will require consideration o f the landcost, the practicality o f acquiring sufficient land andprotecting it fiom future encroachment, the construction and operational costs, and determination o f the potential decrease inpollution load and the associated benefits. These results could thenbe comparedto more conventional wastewater management methods involving mechanical and chemical treatment, which require less land, but have higher construction and operational costs. A potentially important consideration will be whether the wetland area required can serve a dual purpose, for example as a pumppond or stormwater buffer. One possible approach i s the construction o f "hybrid" systems that combine the positive elements o f the wetland and mechanical options. These might handle the wide variability o f contaminants in the surface drainage inspecific Dhaka sub-drainage basins, such as Tejgaon, by combining a common effluent treatment plant for settling o f solids and associated contaminants, and a constructed wetland for strippingdissolved contaminants fiom surface drainage. 109. An initial assessmento fopportunities for application o fthe constructedwetlands approach to managing industrial effluent suggests that it would be worth conducting feasibility studies for the following four locations: isolationo f wastewater from Tejgaon, anduse o f a series o f linked settling ponds andconstructed wetlands (total area ofabout 20-30 hectares) runningbetween Rampura and the BaluRiver to strip contaminants (especially ammonia) fiom water (land availability still to be determined); 71BEMP,2005b 38 application o f a small (2-4 hectare) constructed wetland for treatment o f waste from a textile industrycluster (5-8 factories) inthe Fatullaharea (suitable land appears to be available); experimentation with settling ponds and constructed wetlands to cleanpolluted surface drainage inthe GoranChatbari pumpponds on the Turag River (276 hectares o f landpondowned by BWDB are available); and development o f in-plant waste minimization and common reed beds for small clusters o f industries along the Dhaka-Tangail Road (Dhaka District); this area has been surveyedby Waste Concern, providing a good baseline for design and implementation o f innovative wastewater management schemes; apparently land acquisition would not be a significant problem. V. Water QualityinDhaka:RecommendationsandAreas for WorldBankSupport Strategic Frameworkfor Management of Dhaka's WaterResources 110. Interventions to improve the quality of surface and groundwater inDhakaneed to fit within a integratedlong-term strategy addressingwater quality, water supply, sanitation, and flood management. To achieve this goal, a single statutory body should be formed to promote cross-sectoral coordination and minimizejurisdictional conflicts. An important element o fthe strategic framework will be adequate monitoring o f environmental pollution, incombinationwithpublic information, aimed at raising awareness ofthe causesandimpacts o f environmental degradation, and at disseminating informationabout related interventions. Such initiatives are essential to buildcivil society andprivate sector support, both for the necessary investments, and for strengthenedenforcement o f environmental regulations. Compliance Promotion 111. Industrialdischarges into rivers, canals and groundwater mustbereduced ifwater quality i s to be improved. This will require stricter enforcement o f environmental clearance conditions and effluent standards, focusing on priority sources o f contamination. Compliance plans for existing priority facilities should be agreed through application o f the requirement that they renew their Environmental Clearance Certificates annually. Tighter control on new industrial development inthe center o fthe city mustbe applied through more effective use o f the EIA system. To achieve tighter regulatory control it will be necessary to re-examine the institutional incentives for DOEstaff, based on a consideration o f performance indicators, transparency and accountability, and to better define the linkages betweenthe regulatory roles o f DOE and DWASA,as the principle agency responsible for water quality inthe Dhakawatershed. 112. Inadditionto direct regulatory control, international experienceunderlines the value o f providingthe public with specific informationon sources o fpollution, includingthe identities and performance o f the principal actors involved. There i s significant scope for DOEto adopt suchanapproach, focusing onpriority sources ofcontamination, andmaking the results o f environmental monitoring and decision-making as transparent as possible. Heightenedpublic pressure, combined with stricter enforcement o f effluent standards, will help stimulate demand for alternative approaches to waste treatment andreduction. In response, technical assistance for waste minimizationinitiatives, including the development 39 o f environmental management systems based on the I S 0 14000 model, could be provided through DOEas part o f a broader program o f compliance promotion. 113. A number o f mechanisms exist or are proposedthrough which the World Bank could support compliance promotion initiatives inDhaka. Inadditionto budget support for the DOEthrough the ongoing programofdevelopmentpolicy lending, proposedprojects for private sector development and water resourcemanagement inDhaka could include components to provide the DOEand DWASA with technical assistance for the initiatives described above. Investing in Waste Treatment 114. The World Bank's Country Water Resources Assistance Strategy for Bangladesh7' establishes that improving the quality o f surface and groundwater inand around Dhaka will require significant investment ineffluent collection and treatment. Inresponse to the Government's request, the Bank i s helpingprepare a project to improve water supply, sewerage, sanitation and storm water drainage services inDhaka. Bank assistance for a separateproject was requestedby the Government, to strengthen the management o f environmental quality and water resources through investments inappropriate treatment technologies, including non-conventional solutions, such as septic tank effluent systems and constructed wetlands. 115. Inadditionto Government investment andthe support o f development partners, mobilizing sufficient resources to effectively address Dhaka's environmental challenges will require private sector participation. Improved compliance with environmental legislation, combined with application o f the Polluter Pays Principle, will stimulate demand for private investment, for example inshared waste treatment facilities. Establishing andmaintaining the conditions necessary to attract private resources will require the continued transparent enforcement o f regulations, combined with institutional reforms that provide strategic direction and clarity o f roles, and that support the recovery o f costs for urban services. '*WorldBank. 2005b 40 Chapter 4: Management of Capture Fisheries 116. In2000, Bangladesh's fisheries sector contributed some US$1.5 billionto the country's GDP, amounting to about 4% o f the andthe seafoodexport sector is now the country's second largest source o f foreign exchange. Bangladesh's inlandand coastallmarine capture fisheries represent a safety net for the economic and nutritional needs o fmany o f the ruralpoor. Four out o f five rural Bangladeshis, amounting to as many as 85 millionpeople, are dependent to some extent on aquatic resources. It i s estimated that over one millionpeople fish full time and another 11million fishprofessionally on a part-time basis, with the fisheries sector providing employment for 9% o f the country's labor force. In terms o f nutrition, Bangladesh's aquatic resources, from both capture fisheries and aquaculture, are reported to meet more than 65% o f the country's animal proteinneeds (twice the regional average and the seventhhighest inthe world), and are a critical source o f essential minerals, vitamins and fatty acids. 117. The fate o f Bangladesh's capture fisheries i s inextricablytied to the condition o fthe nation's wetlands. Recent economic studies74indicate that wetlands have almost twice the economic output o f rice crops, exceeding Tk. 35,OOO/ha/year, with the largest share o f their direct benefits going to poor people inrural communities. Inaddition, wetlands provide a variety o f indirect environmental services inthe form o f flood control, ground water recharge and pollution abatement. Any strategy that addresses poverty alleviation inrural Bangladesh musttake these fisheries and aquatic resources into account. I. TheStateofCaptureFisheries 118. Inthe pastdecade awide rangeofchanges affecting fisheries havetakenplace, includingvery large increases infishproductionfrom all forms o fpond aquaculture, declines inmostcapture fisheries, encroachmentanddegradationofnatural assets, rapidurbanization, infrastructure investments that have negatively impacted fisheries, and increasedpollution. A major constraint to fishproductionis reduceddry season surface water flows inthe Ganges and other rivers, related to the operation o f the Farakka Barrage, unregulated water extraction for irrigation, andthe impacts o f a large number o f FloodControl, Drainage and Irrigation (FCDI) projects. 119. Figure 4.1 represents a consensus o f opinion on productionprojections by fisheries sub-sector, based on the 2003 Fisheries Sector Review and Future Development (FSRFD) study. These data are projections from the Household Expenditure Survey (BBS) and also use aspects o f FisheriesResources Survey Service (FRSS) and other Department o f Fisheries (DoF) data. It i s generally agreed that both freshwater and brackish-water aquaculture will continue to grow at about 5.6% and 3.2% per year respectively, which i s slower thanthe 20% per annumreported inthe past decade. There is also a general consensus among most authorities that the capture fisheries, bothinland and coastallmarine, are indecline, at rates o f about 2.1% and 1.6% per year, respectively. There i s not unanimous agreement with this statement, however, particularly regarding declines inthe marine sector, and there i s some evidence that deep water offshore stocks do offer some opportunities for the industrial 73FSRFD.2003 74MACH Project, Hail Huor Resource Valuation; DANIDA, h4AEP and GNAEP Wetlands Study; BCAS- ICLARh4LivelihoodsStudy; Munir,A, 2004 41 Figure4s1:FisheriesProd Sub-sector `IF ~~t~~~in A ~ ~and Ca # ~ Eis~ heriesI ~ ~ ~ ~ in2002 and 2012 IIIniandcapture 2002 fisktenes 5 o Coastal capture L fisfienes aInlanda q ~ a ~ ~ ~ ~ u r e 2012 the poor. 42 Box 4.1: Saving the Hilsa - Showingit Canbe Done Hilsa remains the most important fish inthe capture fisheries, and is the national fish o f Bangladesh. In the years 1999-2002 the hilsa fishery showed precipitous declines o f as much as 60%. These were llkely, inthe longterm, to haveresultedinthe collapse ofthis fishery. In2004, however, a seriesof management stepsbased on recommendations o f the DoFiFFP-GEF have contributed to a very notable recovery. This may be one o f the f i s t times inBangladesh that a nationwide effort has led, at least temporarily, to a reversal inthe decline o f a natural resource. Fromthe point o fview o f the hilsa fishery this was a remarkable effort by Government, and a clear success o fthe DoF, the project and the individuals involved. This effort should be seen as an important first step inwhat should become a long-term national effort. Ths combined national effort was an ad hoc endeavor responding to an important national issue, combining a number o f key elements: Awareness - national concern and wide agreement that an important resource was declining; Sound science a concerned Department and Ministrywith anunderstanding of the problem and - anactionplanbased on sound science; Political will -political representatives willing and able to provide the political support necessary; Inter-ministerial cooperation - brought about by that politicalwill; and, Implementation of the managementplan developed by the relevant government Department. - Source: Basedon information collected bythe DoFNorldBank fundedGEF component ofthe Fourth FisheriesProject 122. Production from the eight millionhectares o f seasonalflood-lands i s by far the most important component o fthe inland fishery, which includes floodplains, beels and rivers. As monsoonwater annually spreads across the floodplain, nutrientsare released andprimary production explodes over a very wide area. So long as adequaterecruitment i s present, there follows tremendous fisheries production. Studies inBangladesh and throughout Asia suggest that this productioncouldbe as highas 300-400kgha inhighquality floodplains. Production i s dependent on a number o f factors including the extent, duration and seasonality o f flooding, as well as the hydrology o f individual water bodies. 123. The dry seasonrepresents the most critical season for all specieso ffish andthe greatest impacts occur at this time, when populations are at their lowest levels, fishery habitats are limited, predation i s at a peak, and growth i s slowed. Competition for food i s keen andpressureby fishermen remains high. Reductions, for whatever reason, indry season aquatic habitat have the potential to reduce parentstocks to below replaceable levels. Basic minimumstream flow requirements are necessaryto maintainhealthy fish populations and to ensure that sufficient parent stock are available for re-population o fthe floodplain fishery duringthe next wet season. Perennial wetlands and minimal riverine flows along with sufficient parent stock arethe keyto fishproductioninBangladesh. TheShifting Species Composition of theInland Capture Fishery 124. The major species group (66%) caught inthe beels andfloodplains are now awide variety o fmostly small fish, mainly comprising grazers and detritus feeders, small predators, and small "pelagic" planktonfeeders. Carp, includingmajor carps, large catfish and large fish ingeneral, have greatly declined inabundance, buttogether may still comprise around 11% o fthe catch. Smaller K o i (climbing perch), snakeheads, other catfish and other bee1 resident species with the ability to tolerate low oxygen levels, comprise a significant proportiono fthe catch, together around 18%. 43 125. Overall 40-70 species are typically caught inmost beellfloodplainsystems. However, 5-7 species will typically contribute 60-80% o f the catch. Dominant species (commonly more than 10%o fthe catch) inthe floodplain catch are small prawns (mainly Macrobrachium spp), Puntius sophore and other Puntius species, small Channa, Colisa fasciatus, Aorichthyes seenghala andHeteroprzeustesfossilis, and a few other fast breeding small species. Prices for all non-aquaculture species includingthe smallest fish have risen substantially inrecent years. 126. There appears to have been a significant shift from larger fish and fish species to smaller fish and prawns. This i s probablyrelated to: Restriction o fbreeding migrations for all migratory species; Loss o f dry seasonhabitats most suitable to the species and the loss o f connections for estuarine and riverine species that utilize the seasonal floodplains as breeding and nursery areas; Greater susceptibility o f larger species to over-fishing (of spawn and adult); and, Greater resilience o f smaller rapidly reproducing species to over-fishing and to losses o f dry seasonhabitat. Insome ofthe smaller beels andenclosedfloodplainareas stockingtakes place, andinthese systems the proportion o f major carps, silver carp, common carp and grass carp i s significant. Most o fthe baors (oxbow lakes) inthe Jessore area are stocked, and the catch composition reflects this, with 40-60% exotic carps, 8-13% major carps, and 29-42% other. 127. The river catch was inthe past dominated interms o f bothvalue andproduction by the migratoryhilsa (Tenualosa ilisha). The Farraka Barrage inIndia coupled with heavy fishingo fjuvenile stocks has resultedinthe disappearance o friverinehilsa. Untilthe 1970's almost all the hilsa consumed came from the rivers, butnow most o fthe catch comes from the Bay o fBengal. However, thejatka or juvenile hilsa catch still occurs inthe lower reaches o f the Meghna and other rivers which serve as nursery areas for 5-7 months. Prawns, mostly small, are probably the second most important group, contributing 10-15% o fthe catch. Other important species are Macrobrachium spp., Clupisoma garua, Pangasisus pangasius, Puntiussophore, Glossogobius giurus, Aorichthys seenghala, Labeo rohita, Catla catla, Wallagu attu andMystus cavasius. Inpractice a wide variety o f other species are caught, with around 35 species each contributing more than 1% to the catch. Open Water Stocking: Ambiguous Impacts 128. Open water stocking inBangladeshi s the result of the success o f the World Bank supported Second Fisheries Project, also known as the Baor Program inthe mid-1980's. This program showed that yields as highas 1,000 k g h a could be obtained with intensive stocking o fnative and exotic carps inthe semi-closed baor areas. Inthe early 1990's the Third Fisheries Project (also supportedbythe World Bank) and the SecondAquaculture Project (supported by the AsianDevelopment Bank) incorporated open water stocking into their strategies. More recently the DoF i s supporting private sector initiatives that block off large seasonally flooded areas. Openwater stocking continues to be supportedby the DoF, a number o f development partners, and many national and internationalNGOs. All have 44 shownthe overall technical feasibility andincreased yields o fhigh value carps that result from open water stocking. 129. Controversies have arisen, however, regarding the sustainability and cost recovery o f stocking programs, as well as social andbiodiversity concerns. Surveys undertaken bythe FourthFisheries Project78alarmingly show that the FourthFisheries Stocking Programs have negative or at best no impact onthe livelihoods o fthe poor. Studies byWorldFish o f fishers and other community groups who haveundertaken stocking have shown that those directly involvedinstocking do benefit, butthe impacts on the wider community, including other subsistenceusers o fthe resource, are ambiguous.79 130. Intuitively,cuttingoffa water body from the floodplain, other wetlands andrivers, is likelyto limitbiodiversityinthat water body, as well as insurrounding openwater areas. Short-term studies undertakenbythe DANIDAfundedBaor Program as well as the GEF component o fthe FourthFisheries Project examined impacts o f stocking on fisheries biodiversity. These showed that highstocking rates didnegatively impact natural fish stocks and overall biodiversity, while stocking at lower levels did not appear to have an impact. Another system, pioneered inDaudkundi and beingpromoted bythe DoF, calls for shares to be soldto landowners whose lands seasonallyflood. Once again, while profitable, issuesof access rights o fthe poor, and impacts onbiodiversity, are unknown. What i s known i s that this system is spreading quickly ina number o f areas. TheNeedfor Management Controls in the Coastal CaptureFishery 131. The marine andcoastal capture fishery is aprimary source o fincome andnutrition for over 484,000 households inthe coastal region.*' Yearly productioni s inthe order o f 0.45 -0.6millionMT. Full-timeequivalentemploymentisthoughttobealmost0.2million. In addition about 0.4 millionpoor men, women and childrenare involvedinseasonal shrimp larvae collection. As inthe case o fthe inlandfishery, mucho fthis work i s seasonalwith most o fthe labor providedbythe poorest segments ofthe communities. 132. Unlike the inlandfishery there i s more o f a commercial focus to the coastal and marine fishery. Access to most coastal andmarinewaters entails the use o f a boat and, except for river mouths and estuaries, motorizedboats are a requirement. The industrial trawl fishery can exploit deeper water fishery resourcesup to a deptho f 50-200 myandthe prospects for exploitingthe deepest waters have not beenhlly explored. 133. Worldwide, marinefishery resources are indecline, and those inBangladesh are no different. The majority ofopinionfrom fishers, DoF fisheries professionals and fisheries scientists, i s that most inshore stocks are indecline or at best have reachedtheir maximum sustainableyields, andthat the peak of coastal andmarine productionwas reached inthe late 1990's. This i s almost entirely the result o funregulated access and a lack o fmanagement controls. While pollution and illegal fishingby foreign trawlers operating inBangladeshi waters are certainly concerns, over-fishing remains the mainissue. O fparticular concern has beenthe hilsa fishery, which accounts for much o fthe marinecatch. 78WorldBank, 2003 79P. Thompson, World Fish, PersonalCommunication ICZMP, 2003, PersonalCommunications 45 Protecting Coastal Breeding and Nursery Areas 134. Bangladesh's coastal waters hold a wide diversity o f fishery resources. The marine environment contains 475 species o f finfish and a number o f crustacean (shellfish) resources including 36 species o f shrimps, and several other traditional and non-traditional fishery items such as cuttlefish, octopus, oysters and mussels. Naturalmangrove forests cover almost 600,000 ha primarilyassociated with the Sundarbans Reserve Forest with another 100,000 ha o f planted mangroves, the result o f various Government and development partner supported programs.*l Ithas beenestimatedthat every hectare o f mangrove generates upwardso f 450 kgo fmarine catch. There is a needto identify andprotect breeding and nursery areas o f commercially important fish andprawns, as has taken place on an ad-hoc basis for the hilsa. Outside o f the Sunderbans (see Box 4.2) few effective protected areas exist. Box 4.2: FisheriesManagementinthe Sundarbans The Sunderbans comprise the most important nursery area for the Bay o f Bengal fisheries. Ithas been estimated that every hectare o f mangrove generates upwards o f 450 kg/ha of marine catch. The continued existence and functionality o f the Sunderbans mangrove forest is o f critical importance to the entire marine fishery of the Bay o f Bengal. Through the Sundarbans Biodiversity Project (SBCP - an MoEF project supported by the ADB) a management regime has been developed and is reported to have been adopted. This represents the first attempt at managing a coastal fishery inBangladesh. Management of the Sundarbans reserve forest lies with the Forestry Department, under the auspices o f the MoEF. Management practices within the Sundarbans are subject to specific protectionorders, which prohibit access to specific areas at specific times o f year. Access to the Sundarbans is restrictedby a permit system, allocated to specific vessels with a history o f having fished inthe zone. There are no quota or effort limits set inthe policies o f the Forest Department. Of recent concern is the precipitous closing ofthe SBCP, but it is not knownhow this will impact the management schemes put inplace. 11. Impacts of Capture Fisheries Decline 135. Traditionallythe inland capture fishery has been Bangladesh's main source o f fish for food. This is no longer the case, with change occurring rapidly over the past 25 years. In spite o f declines, the inlandfisheries continue to play a significant role as a source o f nutritionand income for a large proportiono f the rural and urbanpopulation. Consumption informationfrom the 2000 Household Expenditure Survey o f the BBS shows that average fishconsumption inthe country declinedby 12%since 1995,while fish consumptionofthe poorest 22% o f the populationhas declined by 38%, evidence that lower per capita fish supplies are pushingfishprices beyond the reach o fthe poorest consumer. Loss of Wetlands: a Key Resourcefor thePoor 136. The beels, boars, haors and rivers that make up the wetlands inBangladeshhave beenundervaluedby decision makers and developers, too few o f whom are aware o ftheir 81For example, the ADB Greenbelt Program 46 true economic value and the environmental services they provide. It is reported that Bangladesh has lost 50% o f its permanent wetland area. 82 137. Recent studies from a variety of GOB programss3show that wetlands and fisheries are o f critical importance to Bangladesh's rural poor. The first economic valuation of a Bangladeshwetland took place inHail Haor, M o l v i Bazaar, and indicated that this wetland has an annual output of approximately Tk 30,O0Og4per ha. The study mainly considered physical outputs. It didnot include water recharge, pollution abatement, existence or a number o f other values as data were not immediately available. This conservative estimate foundthat almost 50% o fthe value directly benefitedthe poor. 138. Apart from fish, the seasonal andpermanent wetlands inBangladeshprovide a range o f products. These include various food items (plants and animals), medicinal plants, fodder, fuel andbuildingmaterials, mainly used bythe poor. A s detailed inFSRFD and DANIDA studies, four out of five rural Bangladeshis, particularly the poor, depend to some extent on aquatic resources. They are increasingly vulnerable to threats to the resource and conflicts over access to resources. With land holdings declining, incomes from rice stagnating, and limited opportunities for other rural income generating activities, increasing pressure is being placed on the remaining wetlands and open fisheries. 139. Surveys conducted by several DoFprojectss5conclusively show that the poor depend on, and are major beneficiaries o fpublic wetlands for food, income and other purposes.86 Data from the MACHwetlands valuation show that as much as 60% o f the benefits from a large haor inSyhlet flow to the poor. An environmental impact assessment of wetlands in Greater Noakhalig7conducted for DANIDA showed that 80-93% o f the community utilized those wetlands and that the poorest members o f that community derived 15% o f their income from harvesting its products. Surveys ofhighly degraded wetlands inSherpur District conducted by the SUFER Project" show similar trends with over 80% of wetlands users being among the poorest members o f their respective communities. Quantzjjing Lossesfrom CaptureFisheries 140. The lack of quality time-series data makes the economic losses inBangladesh's fisheries difficult to quantify. Overall it is known that during the period 1999-2002the Hilsa catch declined by as much as 50% from previous levels. It is further known that major declines have occurred inthe major and minor carp fisheries since the 1970's. Estimates by a variety of authors suggest that historical declines inthe inland fisheries amount to 30%, while the peak of marine capture fishery is know to have occurred inthe 1990's. A s Table 4.1 indicates, the annual losses for the species shown could be inthe order o f U S $ 4 2 millionper year. Applying an average economic value for the decline inall capture fishery species of '*Whilealarming, this compares with the continental US, which has seenthe destruction of morethan 50% of its wetlands, while California has lost 90% or more, as studiedby the University of Californiaat Berkeley, and uoted by Williams, T. 1996 'The MACHProject, the DANIDA fundedAEPs, the World Fish Center CBFM program, the Fourth Fisheries Project andits GEF component 84Colavito, L.et al. 2000 85MACH, DANIDA, SUFER 86Colavito, L, Collis W. J. et al, 2001; IUCN: Wetlands Workshop; DANIDA,2003. 87Winrock. 2003 88Ahmed, M.2003 (draft) 47 US$2,232 per tonnesgto the annual losses shown inFigure4.1 suggests that the lost productionamounts to some $56 millionper year, which probably understatesthe broader economic lossesto fishers and the nation as a whole. Table 4.1: EstimatedPhysicalandFinancialLoss dueto DecliningProduction Annual Maximum Annual Average Production Species Production Annual 2002 Basedon Basedon Basedon 1999-2002 Production19 (mt) Maximum Average Average (mt) 99-2002 (mt) Production Production Production (mt) (mt) (US$) Major Carps 9,639 2,780 1,443 8,196 1,337 1,586,271 382 I 3,212 I 968 I 984,203 I 62,944 1 49,464 I 16,672 I 39,560,441 1 Indian I I 1 I I Salmon 2,428 1,129 930 1,498 199 675,330 IAU Species L I I I $42,806,245 I Source: F1 3s data 111. PoliciesandInstitutionsfor CaptureFisheriesManagement 141. The role ofMoFLandDoF as promoters ofaquaculture, commercial fishingand other forms o fproductioni s clear. They are also the responsible agencies for the regulation o f fishing effort and fish quality issues. It i s not clear, however, which government agency or group holds primary responsibility for the protectiono f aquatic habitats (wetlands andcoastal habitats), that are the basis for fishproduction. A number o f Ministries including Environment, Water, and Land, and Local Government, hold a variety o fmandatesinthis regard. MoEFResponsibilitiesfor Aquatic Habitat and Biodiversity Conservation 142. The Ministryo fEnvironment and Forests (MoEF) i s responsible for coordination o f the Government's Environment Policy o f 1992, giving it overallresponsibility for national environmental issues. These include environmental pollution control, conservation o f wildlife including waterfowl, responsibility for managemento fthe country's various national parks andprotected areas, and implementation o fthe various international environmental treaties to which Bangladeshi s aparty. Part o fthe Environment Policy o f 1992 calls for protection o f freshwater and coastal/marine resources. As a result o fthese responsibilities, the MoEF, through boththe Departments o fForestry and the Environment, i s becoming more involvedinwetlands and, therefore, fisheries conservation. 89The price of US$2,232 per tonne i s calculated as the weighted average price o f the losses shown inTable 4-1. Consistent with the economic analysis conducted for the World Bank-supported Fourth Fisheries Project, the economic value o f fish consumed domestically is assumed to be equal to the fmancial value, as no significant distortions due to taxes or subsidies are involved. 48 143. TheForest Department (FD) controls the two most important wetlands ofthe country, the Sunderbans and Tanguar Haor. The MoEF has implemented the only fisheries management scheme inthe coastal sector, as aresult o fthe Sunderbans Biodiversity Project's Fisheries Management Program. InTanguar Haor, the most important freshwater wetland in the country and Bangladesh's second Ramsar site, the MoEF has responsibility for overall management. Inaddition, through the UNDP-hnded Sustainable Environment Management Project (SEW) the MoEF i s overseeing anumbero f further wetland management schemes. 144. TheDepartment ofEnvironment (DOE)under the MoEF is responsible for protecting overallbiodiversity andunder the Environmental Conservation Act i s able to designate Environmentally Critical Areas (ECA) as areas for environmental protection. The DOEhas designatedcoastal areas, urbanlakes and large wetlands as ECAs. This includes Hakaluki Haor, the secondmost important wetland area inthe country and a potential Ramsar site. While having a general responsibility for conservation and the environment, the MoEF does not have a specific mandate inthe areao f aquatic resource protection. Ingeneral, these organizations lack the capacity andthe in-house expertise to manage fisheries. However, the DoF, while having expertise inthe areas o f fisheries management and to a certain extent community management,lacks abackground inprotected area management. Leasing of Water Bodies by theMinistry of Land 145. Apart from those areas controlled by the MoEF, the Ministryo f Land(MOL)controls 3,773 open water areas (about 1,126,000 ha) and 8,549 closed or semi-closed water bodies (about 14,000 ha). Total revenue from leasingthese assets in 1998 was Tk. 127million.g0 The major purpose o fthe leasesystemremains revenue generation. MOLleasepolicieshave been and remainan area o f contention within Government andthe NGO community. Leasing rates and methods o f awarding leasescontinue to stir controversy and it has long beenrecognized that the current lease system i s part o fthe reason for the continued decline o f Bangladesh fisheries and wetlands. 146. Determining which Ministryor Department controls the leaseprocessis a highly political issue, and remains subject to discussion, but there is no doubt o fthe need to add conservation elements to leasing agreements, andto eliminate illegal fishing methods (for example drymg, poisoning, anduse ofillegal gear) for individual leases. Inaddition, lease agreementscould includerequirements for small sanctuaries and specific management practices establishedinconjunction with local government andtheir communities. Areas of Institutional Reform: Cross-Sectoral Coordination and Community Participation 147. Complex institutional andgovernance issues, engaging a mix o f formal and informal institutions, public andprivate, and involving arange o fcross-sectoral linkages and areas o f responsibility, characterize the fishery sector. Boththe recent FSRFDstudy (2003) and the Bangladesh Biodiversity Strategy andAction Plan(BBSAP, 2004) emphasizethe needfor improvedmechanisms to coordinate managementandplanningo fthe broader natural resources andrural development sectors. Both follow the reasoning o fthe National Strategy for Accelerated Poverty Reductionandthe MDGs, which support more cross-sectoral coordination and community participation. Boththe FSRFDand the BBSAPrecommend 90Islam, M.N., 1999 49 that highlevel committees be formed to coordinate inter-institutional relationships and management of natural resources. They suggest that fbture investment inthe sectors be channeled throughthese committees. IV. CaptureFisheries:RecommendationsandAreas for WorldBankSupport 148. The recent success o f the DoF hilsamanagement program, and the achievements o f a number o f other DoF programs such as MACH, CBFM-I1and others, point the way forward for management o fthe inlandand coastallmarine capture fisheries. At the national level, development partners should align their priorities with the Government's strategic planning for fisheries, including the draft InlandCapture Fisheries Strategy. Withinthis strategy, the actions that are neededto reversethe decline o f Bangladesh's capture fisheries are reasonably clear, as summarized below. Protect Dry Season WaterFlows 149. The World Bank's Country Water Resources Assistance Strategy for Bangladesh concludes that the availability o f dry season water i s the most critical issue facing the nation's inlandcapture fi~heries.~' Itis estimatedthat 50% or more o fthe perennial wetlands o f Bangladeshhave beendrained, encroached, filled or otherwise lost inthe past 30-40 years. This has negatively impactedthe poor, fish production, plant and animalbiodiversity, as well as a variety o f environmental services that wetlandsprovide. Given the direct connection betweenthe poor and the wetlands o f Bangladesh, and inline with the recommendations o f the PRSP, there i s a needto preserve dry seasonwater. This will entail the conservation o f dry season flows inthe major rivers, conservationand rehabilitation o f perennial wetlands, potentiallyincluding some re-excavation, and management o f these areas. As part o f this effort, capture fishery requirements for dry season flows should be estimated, and the informationprovidedto the Ministryo f Water Resources for use inplanning and international negotiations. Water quality, as well as quantity, i s also important, and pollution fiom industrial, urbanand agricultural sources mustbe controlled to protect aquatic habitats. Establish National Sanctuary Systems 150. Designation o fprotected areas large and small, fresh and salt water, is the first step in ensuring the continued sustainable use o f Bangladesh's aquatic resources. Inadditionto protecting the major breeding and nursery areas through nationallydesignated sanctuaries, significant benefits would be derived &om establishing small sanctuaries as an element o f the lease for all water bodies. This would require revision o f MOLlease procedures to require conservation elements that include (at a minimum) establishment o f small local sanctuaries. Where communities agree, such small sanctuaries should be made permanent though Government recognition. Develop and Implement Fisheries Management Regulations 151. An important step towards sustainable fisheries management wouldbe the development and implementation o f regulations covering gear use, meshsizes, and closed seasons appropriate for the individual inlandand marine areas, basedon sound science and 91World Bank. 2005 50 community participation. Such initiatives should aim to limit entry to the fisheries, but protect the access rights o f true subsistence fishers. Where appropriate, communities should be encouraged to self-regulate entry. Leasing can be a means to limit access andmanage the capture fisheries resource ina biologically sustainable way, but this will require reform o f the existing system's emphasis o n short-term revenue generation, and a renewed focus o n community-based fisheries management. Inthe marine setting, this process will require boat registration and limits on the entry of new boats into the fishery. To buildcommunity support andoffset any possible negative social or economic consequences, suitable mitigation must be providedto impacted fisher communities. A separate regulatory concern is the need to ensure that impacts on fisheries are more consistently addressed inthe environmental assessment o f infrastructure that may restrict fish migration, particularly investments inroads, embankments and drainage structures. Integrated Coastal ResourceManagement 152. Based on the assessment of continuing decline inmarine inshore resources, high poverty incidence incoastal regions, particularly among landless people dependent on the capture fisheries, and the critical need to manage and regulate the artisanal marine capture fisheries, the adoption o f an Integrated Coastal Resource Management framework addressing poverty and the long-term viability of the coastal/marine ecosystem is recommended. Strategically, the support should be multi-sectoral and lead to livelihood diversification, reducedpressure o n marine inshore resources, devolved and strengthened monitoring and law enforcement capacities, and effective participation o f local communities incoastal resource management. This strategy could take place within the framework being developed by the IntegratedCoastal Zone Management (ICZM) project.92 Enhance Monitoring of Fisheries 153. Fisheries statistics are at present unreliable. There is significant disagreement over the actual state of the country's fish production and fish biodiversity. Investments and specific management decisions are almost impossible to make without current reliable information. Improvingthe fisheries database involves spreading the ownership of the data and involvinguniversities, FRI, NGOs, the private sector and others incivil society inthe collection and assessment of fisheries information. Catch monitoring must also be improved througha revisiono fthe FRSS, which would entail establishing a separate group within FRSS to monitor the open water catch. Reducing Barriers to theImport of Fish 154. Maintaining stable prices for the country's most important source o f animal protein will also help relieve pressure on capture fisheries. The key to stable prices is increased supplies. There i s little or no scope for the further expansion of capture fisheries given the current levels o f exploitation. The only internal source where sustainable fish supply increases are possible is aquaculture, mainly from inland ponds, and it is extremely unlikely 92The GOB, Dutch and DFID-funded project works within the Water Resource Planning Organization (WARPO) o f the Ministry o f Water Resources. At present it does not cover fisheries but aims at layingthe foundation for an integrated coastal development process. Inconsultation with the Government its objectives include the development o f the following: (i) Zone Policy, (ii) Zone Development Strategy, (iii) Coastal Coastal Priority Investment Program (PIP) within 2005 51 that internal productionwill meet demand. The reduction o f import duties andother barriers, particularly on cheaper fish, should be a part o f the effort to increase supplies and reduce the intensity o f the exploitation o f capture fisheries. MaintainingAssistancefor CaptureFisheries 155. Government anddevelopment partner assistance have been instrumental inshaping the sector, particularly inthe areas o f inland aquaculture and to a lesser extent the inland capture fishery. There has been continuous assistance provided over the past three decades bydevelopment partners to the Government supporting the expansiono f aquaculture and small scale management o f inlandopen water capture fisheries. Inthis periodmore than US$ 350 millionhas been investedby international organizations. 156. International financial assistance has been allocated indecreasing order o f importance to (i)aquaculture (50%), (ii) open water fisheries (40%), and (iii) inland coastaVmarine capture fisheries (5%). At present, inland aquaculture continues to be strongly supported by DoF and a variety o f development partners. Brackishwater (shrimp)aquaculture i s rightfully ledbythe private sector with some support from Government agencies and donors. Earlier support to the inlandcapture fishery mainly focused on open water stocking but the sub- sector i s now receiving more broad-basedsupport fi-om Government and development partners. The coastal and marine capture fisheries have not enjoyed the long-termsupport that has beenprovidedto aquaculture andthe inlandcapture fisheries. Followingthe focus o f the MDGs andNational Strategy for Accelerated Poverty Reductionon pro-poor policies and growth, the keypriorities for continued World Bank support to the fisheries sector inthe mid- to long-term should be inthe areas indicated above. 52 Chapter 5: SustainingSoil Quality 157. Soil performs a number o f important services or functions, among which the following are o fparticular importance: Supporting the growth and diversityo fplants and animals byproviding aphysical, chemical andbiological environment for the exchange o fwater, nutrients, energy and air; Regulating the distributiono frain or irrigationwater betweeninfiltrationandrunoff, and regulating the flow and storage o fwater and solutes, including nitrogen, phosphorus, pesticides, and other nutrientsand compounds dissolved inthe water; Storing, moderatingthe releaseof, and cycling plant nutrients and other elements; 0 Acting as a filter to protect water quality, air and other resources; and Supporting structures andprotecting archeological treasures. 158. The term "soil quality" is usedto describethe ability of soil to performthese functions. The USDANatural ResourcesConservation Serviceg3defines soil quality as: "The capacity of a specific kind of soil tofunction, within natural or managed ecosystem boundaries, to sustainplant and animalproductivity, maintain or enhance water and air quality, and support human health and habitation. Changes in the capacity of soil to function are reflected in soilproperties that change in response to management or climate." 159. Maintainingthe functions o f soil is thus central to the achievement o f sustainable development. Inexploring evidence for a degradation o fthe soil resource, it i s important to identify first the soil function o f interest and thento relate this to a measurable soil property or properties. An example of soil function i s `the ability of soil toprovide raw materialsfor construction of dykes, roads and dwellings '. The related soil property i s the extent, interms o fboth area and depth, o f soils o fparticular clay content or type. Fromthis example it i s clear that boththe function o f soil and the related soil properties maybe measured. I. ChallengesFacingAgricultureinBangladesh 160. Agriculture accounts for some 23% o f GDP and more thanhalf o ftotal employment, so the ability o f soil to sustainagricultural productioni s an issue o fnational concern. Given the overridingimportance o f agriculture to Bangladesh, the soil functionthat has received the most attention to date i s the capacity o fthe soil to `sustain cropproductivity'. The terms soil productivity or soil fertility are usedinterchangeably to capture the relevant related soil properties. Inaddition to concerns that soil productivity i s declining, there are reports o f a degradation of soil that may affect other aspects o f soil quality. This chapter outlines briefly the future challenges facing agriculture inBangladesh, including the implications o f climate change, andreviewsagricultural productivity at the national and district levels, as well as evidence that a decline insoil productivity i s occurring, before recommending ways to strengthen the strategy for monitoring o f soil quality. 932001-httr,://soils.usda.gov/sai/files/sa one 1.udf 53 161. InBangladeshacombinationoffactorscreateachallenging situationfor agriculture, particularly for rice production. Domestic demand for rice i s increasing, there i s a limited flow o f foreign exchange to pay for rice imports and the government strategy i s to meet this demand through national production. Historically, increases inproductionwere achieved through introducing higher yielding modernrice varieties to raise levels o f yield inboth the Aman andBoro crop, andby increasing the area o f land cultivated, mainly by expanding the area under irrigated Boro. Opportunities for future expansion o f the cropped area are severely constrained by a number o f factors: 0 Urbanization and industrialization are encroaching on the available land, competing for and contaminating water resources; More profitable agricultural options than rice productionare available. Agricultural diversification i s likely to compete for land (particularly irrigated higher landsused for Boro production); and, Sea level changes expected as a result o f climate change will inevitably impact upon landuse inlower lying areas, while inhigher lands adaptation to water scarcity also associated with climate change will require adoption o f crops with lower water requirements. Given this context, any future increases inrice productionwill have to be achieved through increasedyields o f bothAman and Boro crops. 11. Trends inAgriculturalProductivity Intheearlytomid-1990sconcernswereraisedthatproductionincreases achievedoverthe previous three decades inrice-based cropping systems may have involved a trade-off against long-term s~stainability'~.Increases incrop productionslowed and rice crop yields declined. A decline insoil quality (expressed as soil fertility or soil productivity) was inferredas the cause. These concerns are widely articulated inthe literature and reflected inthe National Strategy for Accelerated Poverty Reduction. This section revisits these trends. 162. Cereals productioninBangladeshhas maintained a long runtrend rate o f growth over the last four decades o f around 2.5% per year. Figure 5.1 shows the four-crop running average o f grains production. Intensification o f agricultural productionassociated with the introduction o f improved, shorter duration rice and wheat varieties that were less photoperiod sensitive, together with the expansion o f surface irrigation, ledto a structural change inthe cereals production system. Initially this occurred with an increase inwheat productionand then, more significantly, o fBoro rice production(Figure 5.2). A minor trend has beenthe decline, relatively small inabsolute terms, o fAus production, and other rabi crops partly to make way inthe cropping system for the rise o fBoro. To get a clearer understanding o f the trend inproduction, it i s necessary to consider when particular factors such as the introduction o fnew technologies, or shocks such as natural and man-made disasters (such as floods and adverse price movements), influenced production. 94Asaduzzaman, 1995; Brandon, 1995; Pagiola, 1995, Scherr, 1999 54 163. Usingakinkedexponential growth it ispossible to identifytrends and shocks incrop production, as shown inFigure5.3. Between 1971 and 1972 gross crop productionfell dramatically and i s modeled as a discontinuity. This reflects the disasters o f 1970-1972, includingthe cyclone o f 1970 andthe liberationwar in 1971. Inthe periodbefore this, a rate o f growth was maintained and i s modeled as a constant rate. From 1972 to 1977 a new faster rate o f growth was maintained as cerealsproductionrecovered to its previous trend line. From 1978 untilthe present total cereals productioni s modeled as maintaininga constant rate o f growth slightly faster than that maintained up to 1971,although there have been quite significant deviations from this trend, particularlyinthe mid-1980s and mid- 1 9 9 0 ' ~at~the points marked as slow-downs inFigure 5.3. Figure5.1: Growth of Total Cereals Output (ln`000 tons) 10.5 10 output In `000tons 9.5 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 Year -output ---Predicted Note: Output isthe crop wise movingaverage of the 4 crops (wheat, boro, aus and aman) Predicted is the expectedoutputfrom In(output) = 9.07 + 0.0062'~(rsq = 0.95) Which is a long run growth of 2.48% per annum since there are 4 crops per year 164. The underlyingdeterminants ofproductionlevels however are not clear. Somehave arguedthat productionis determinedbyprice96,butwhile the relationship betweenprice and productionholds reasonably well up untilthe late 1990s, there has been a significant rise in productioninthe last 5 years, notwithstanding continuous low real rice prices. This may have beeninpart due to the Government's focus onrice productionduringthis period, and may also reflect recovery from the 1998 floods. The effect o f liberalizing marketsinBangladesh hasbeento establish a relative low parityprice for rice, basedon imports from India97,and it i s not unreasonable, therefore, to anticipate that rice productionmay now beginto slow. ~~~ 95 (Boyce, 1986,1987) 96 Ahmed (2001) does this with data up to 1996-7 97 PreviouslyBangladesh imported from Thailand and other sources. Inthe1990s the private sector has developed trade with India as the most profitable source of staples imports. Obviously trends in Indianagriculture, prices etc., has an effect on these parity prices. It i s not clear that Indiawill remain a reliable source o f imports for Bangladesh ifthe food situation were to deterioratethere, given the history o f interventions inthe grain trade by Indiangovernments. 55 f bc els of of Mrsjor CcseaXs in Baaglad I E z 20@00- C 0 L 0 Q '8 - C 0 0 10000- 0 0boro 0aman 0wheat 0 - 0aus I 1360 1970 1980 2 990 2000 t t I i I 1 I370 1980 1990 2000 0 total annual grains output (In> c - mp ~ ~ dindex ~ ~ d i ~ 111. Evidence of Declining Soil Productivity and Soil Quality 165. The growthtrend inagricultural production and the influence o f agricultural and food market developments onproduction were discussed above. As described earlier it i s importantto distinguish soil functions associated with soil quality. The following sections explore the evidence for a decline insoil productivity (i.e. the function of soil to sustain plant productivity), and then consider evidence for a wider decline insoil quality. Evidence of a Decline in Soil Productivity: Yield and TotalFactor Productivity 166. Longterm rice-wheat experiments provide a useful starting point inthis analysis. These experiments are generally established with the technical optimuminmind. Typically, such experiments provide a measure o f yield (plant productivity) at specified levels of inputs and, insome cases, yieldresponse to inputs over time. So, where inputs are constant, and evidence o fpests and disease absent, a decline incrop production, measured as yield, may signal a decline insoil productivity. Long-term experiments constituted a major component o f the evidence that yields were declining inthe early 1990s. This evidence was typically drawn across a number o f countries and agricultural situations, some of which differ from Bangladesh inbothenvironmental characteristics and cropping pattern, and show no consistent yield impact. Dawe et al., (2000) analyzed long-term yield trends in47 experiments inrice-rice and rice-wheat systems, and argue that yield decline is not very common, particularly at yield levels actually achieved by fanners. Duxburyet al., (2000) reviewed rice-wheat experiments on the Indo-Gangetic plains and showed that rice yields were declining ineight and wheat yields inthree out of 11experiments. However, Saleque et al. (2004b) foundno evidence o f a yield decline for the years 1990-1999 for a field experiment at the BRRIexperimental farm at Gazipur. 167. Given that the Boro crop is dominated by HYV crops, and that management practices have remained constant with timeg8,it is reasonable to expect that yield trends inthe Boro crop yield infarmers' fields may reflect underlying soil productivity (and improvements in varieties). Pagiola (1995) analyzed yield trends at the district level and found that yields between 1979/80 and 1993/4 had shownthe greatest decline inthose districts which hadbeen early adopters of HYVs. These observations were particularly worrying because they raised the prospect that a more widespread decline might occur with time. 168. Itcannowbe seenthat the analysis byPagiolawas influencedbythe periodinthe early 1990s where yields and productionwere below trend. District level yield data for the period 1979/80 to 2002/03 suggests that the yield trends are stable or increasing. The only district where the yield trend is negative is the Chittagong HillTract, which is not a major rice producing area. In12out o f 21 districts the increase is significant. For a number o f districts, however, the yield trend is flat, which may indicate continued cause for concern, given the need to increase yields. While more detailed trend analysis of the sort presented earlier could be used to describe these data, inthe absence ofreliable explanatory information, the value o f such interpretation is limited. 169. As described earlier, assessment ofyield trends as a proxyfor soil productivity assumes inputs over time are constant. Whilst this is reasonable as a first approximation, Ahmed, 2001 57 Total Factor Productivity (TFP) which provides a measure o f output relative to inputs, provides a way to account for changes inmanagement when interpreting productiondata. Data on total factor productivity for rice productioninBangladesh are limited, however. A key constraint i s the lack o f available data on fertilizer use at the district level, particularly since the liberalization o fthe fertilizer market. Giventhe lack o f reliable data on input use, it i s not currently possible to calculate TFP at the district level for Bangladesh. Ahmed (2001) who compiled informationon TFP usingdata available at a national level inBangladeshfor the periods 1975/76-1986/87 and 1987/88-1997/98 found that TFP grew throughout this periodby around 1%per year ifconstant rice prices are used. Usingcurrent pricesg9,there i s evidence that, whilst TFP continued to grow, the rate o f annual growth inproductivity slowed inthe second decade (1987/8 - 1997/98). Ahmed attributedthis slowingto alower growthin rice prices compared to input costs. Nutrient Balances 170. Nutrient balances are proposed as an indicator o f likely hture soil fertility issues. They are not a direct measure o f either soil function or soil property. However, they can be relatively easily derived from data that would be usedto calculate TFP. Negativebalances over time indicate a trend to deplete soil resources. Visual symptoms ina crop o fnutrient deficiency or positive crop responses to a particular nutrient input"' confirm that soil resources are depleted, or ina form that i s not available to the plant. 171. A national nutrient budget for Nitrogen(N),Phosphorus (P) andPotassium(K)was calculatedusinga partialbudgeting approachthat considered national data on crop yields (BBS data) andfertilizer inputdata from the MMIS."' This analysis suggested that the P budget was somewhat negative andhas not changed over the last 20 years, while the K balance i s muchmore negative. Ninputssuggest a surplus application, but this reflects the fact that typically more than 50% o f nitrogen fertilizer added to rice soils i s lost. Once losses are accounted for, then the balance becomes negative. These data are somewhat inconflict with other evidence, however. Ahmed 2001 reports that the balance ofN:P:K appliedto rice was 50:30:20 and that the ratio had shifted to 72:15:12 by 1996/7. 172. Partial nutrient balances were assembled at the AEZ level usingdata from the SFFP demonstration database.lo2 These data allowed comparison o f farmers' practice and yields for aBoro - fallow -T Aman rotation. The findings were that the balance for nitrogen rangedbetween -50 and 0 kgha-' yr-',phosphorus was between -10 and+5 kgha-' yr-' and the potassium balance was always very negative at -225 to -100 kgha-' yr-'. Ripjma further reported that the balances were less negative inthe Barind areas (AEZ 25,26 & 27) in comparison with the Ganges Floodplains (AEZs 11,12 & 13). However, Ripjma cautioned that whilst the findings indicate trends and confirmthe potential to identify areas o f concern, the data didnot reflect actual cropping patterns andintensities inall locations. 99 Given that there i s an expectedrelationship between output price (Le. rice price) and input prices this is a propriate. l' This holds for macro-nutrients excepting Nand all micro-nutrients lo' (Ripjma, 2004). lo* (Rijpma et al., 2004). 58 Crop Biophysical Indicators 173. The relationship betweennutrientuptake and grainyield canbeusedto diagnosecrop biophysicalconstraints. Again this i s not a direct measure o f either the function or related soil property, butmay provide important diagnostic information. A limited data set shows the relationship between grainyield andNuptake obtained for the Boro rice crop at four locations (Dhamrai, Daulutpur, Gabtali and Shibgaj) during 1998 and 1999.'03 These results fall around the lower limit for accumulation establishedby Witt et al. (1999), suggesting that sink formation was limitedby factors other thannitrogen. Simplyput, the plant i s not deliveringthe levelo fyield that would be expectedgiventhe measuredlevel o fNuptake by the crop. 174. Theresults suggest some factor other thanNuptakelimitedyield. Inthis study, application o fthe macro-nutrients (P and K) and compost didnot have any significant impact on yield. Other factors such as micro-nutrient deficiency, pests, disease, lack o fwater, low radiationmay have limitedyield. The data set i s not sufficiently comprehensive to draw widespread conclusions, however the analysis does provide a usehl example o fhow the aspects o f crop performance can be usedas an indicator o funderlying soil productivity issues. Evidencefor a decline in Soil Quality: Quantitative measurements 175. The soils and environmental characteristics ofBangladeshhave beenextensively mapped andusedto inform planning, landuse andmanagement decisions (see Box 5.1). The soil survey and analysis to date has focused on describing environmental characteristics and measuring soil chemical properties that may determine soil suitability for, and fertilizer requirementsof, agricultural crops. Box 5.1: Soil Mapping inBangladesh The first soil map o fBangladesh (then East Pakistan) recognized seven soil tracts combining physiographc, parent material and soil units. Reconnaissance soil surveys by the FAO-UNDP Soil Survey were undertaken from the early 1960s. This mapping was completedby the Soil Survey Directorate of the Government o f Bangladesh(now the Soil Resources Development Institute, SRDI) in 1975 and led to the publication o f the first soil map o fBangladesh at a 1:1million scale. Further detailed analysis was carried out through the FAO/UNDP supported Agroecological Zones (AEZ) project study inthe 1980s. The AEZ maps are at a scale o f 1:250,000. AEZs, while providing a usefulcharacterization ofthe environment, remainbroadunits o f characterization. Recognizing this, S R D I pursued the `Upazila Nirdeshka' program to collect basic informationon land, soil and water resources that would serve to identify resource management domains (RMD) as a spatial management unitthat offers opportunitiesfor the identification andapplication ofresource management options to address specific landmanagement issues. The Upazila Nirdeshka maps are completed at a scale o f 1:50,000. SRDI have published403 Upazila Nirdeshaka (previously called Thana Nirdeshka) and a BARC GIS Project has so far digitized andupdated 300 ofthese maps (BARC 2004). Researchon soil fertility and fertilizer use at the farm level was also started inthe 1960s with the establishment o fthe Soil Fertility and Soil Testing Institute o f East Pakistan. The first fertilizer recommendation guide was publishedby BARC in 1979. These recommendations were revised and developed over time. By 1989 the guide was revisedto establish cropping pattern-based generalized fertilizer recommendations for moderate yield goals for the mainAEZs. Generalized fertilizer recommendations were developed for the major crops. lo3(Hossain 2001). 59 176. Rahman et al. (undated report) compares soil properties that may affect soil productivity under different physiographic units sampled in 1967 and 1998. The results suggested a decrease inpH, indicating acidification, and a decrease incalcium, magnesium and potassium, with no consistent change inorganic matter, Nor P status. It should be noted that this survey appears to be basedon a limited sample (24 observations) and no details o f how methods were standardizedor controlled between 1967 and 1998 were provided. Nor i s evidence o f a loss o f soil function recorded. 177. A framework that identifies key soil functions, for the specific complex situationin Bangladesh, does not yet exist, and i s beyondthe scope o f this chapter. Thus it i s difficult to comprehensively review the wider evidence for a decline insoil quality. Well-recognized, localized, soil degradationproblems exist inBangladesh. Deforestation for example i s leading to erosion inthe Chittagong HillTracts and salinization i s reportedto have increased by 22% since 1973.lo4 important, and likely to affect a number o f soil functions, these While problems have limited geographic extent. A studyby the FAO"' suggested that inthe late 1980s, the total degraded land inBangladeshrepresented 7.4% o fthe total land area. When comparedto other countries inthe Asian Pacific region, this level o f degradationwas low, with only Myanmar and Tonga estimated as having lower levels o f degradation. Emerging problems include the depletion o f groundwater, and a build-upo f arsenic insoil as a result o f irrigation with water contaminated with naturally-occurring arsenic, although there it i s not yet clear what concentration o f arsenic inirrigationwater would have a quantifiable impact on agricultural yields or humanhealth.lo6 QualitativeAssessments 178. Farmers are aware o f subtle changes insoil properties and associated functions. Saleque (2004a) found that farmer's assessmento f soil fertility were consistent with measured soil properties. Hossain (2001) found that farmers inBangladeshreported a beneficial change insoil properties associated with a change inmanagement o f organic matter inputs. With application o f compost the soils were reported to be less hard. The change could not be substantiated through soil chemical measurements, including soil organic matter status, but was reflected inmeasures o f soil physicalbehavior. 179. Assessments o f soil quality, or o f changes inquality, can draw upon qualitative data o f different types, obtained indifferent ways. Gaunt et al. (2001) found a keen awareness amongst the farmers o f the non-sustainability o fparts o ftheir farming systems, and o f the need for better management o f soil fertility andpests. The resource intensive approach taken by Gaunt, usingparticipatory methods working through focus groups and drawing on a relatively small sample at distinct locations. Rahman(2004) used such an approach to design a questionnaire which was then used ina survey to interview a total o f 406 households. In this study farmers were asked to respondto a set o f twelve specific environmental indicators which hadbeen identifiedinprevious focus group discussions. As shown inFigure 5.4, soil fertility was ranked as the major problem (86% o f those interviewed agreed), followed by ~~ IO4(Muzib, 2004) 105Reviewedby Scherr (1999) World Bank, 2005 60 Increasedcrop d~ S UB~ S Fbducedfish catch Effects of human heaith Soilferttiity 0% 20% 40% 60% 80% 1DQ% 180. Bothrh 8 0 Existingsoil test protocols establishedto measure soil fertility and informagricultural management decisions are too narrowly defined to monitor the functions o f soil that are defined by soil quality; 0 Sufficient data are not available to ascertain whether soil productivity has declined, butlimitedevidence from repeatedsoil samplingat the AEZ levelmay suggest decline insoil properties associated with soil productivity; 0 Fertilizer inputsare imbalanced and nutrient mining i s occurring, particularly for potassium; 0 Limitedcrop physiological observations suggest poor rice crop performance; 0 Qualitative evidence suggests deterioration o f soil quality and impacts o f intensification o frice productiononhumanhealth and fish production; 0 Scientistshave expressed concerns that salinization, acidification and arsenic contamination are emerging soil quality problems. IV. Implicationsof Climate Change 183. Agricultural productionand soil quality are both influenced bythe environmental impacts (externalities) associated with actions elsewhere, and likewise environmental externalities o f agricultural productionmust be considered. These externalities create impacts and costs for society that are not captured by a field-based assessmentand financial analysis o f crop production, and may also have an impact upon hture agricultural practice. The externalities associated with rice productioninclude: Depletiono f groundwater due to use for irrigation; Point source pollution, such as arsenic insome situations; Non-point sources pollution, derived from agricultural and other sources; and, The productiono f avoidable methane (Cb) and nitrous oxide (N20)emissions. While detailed review o f these externalities i s beyondthe scope o f this chapter, it i s important to note that these externalities have negative impacts inthe context o f the definition o f soil quality introduced above. The implications of climate change for agriculture inBangladesh are consideredbriefly. Adaptation to Climate Change 184. Climate change i s likely to influence agriculture inBangladesh. Sea level changes expected as a result o f climate change will inevitably impactupon landuse inlower lying areas as flooding and salinity increase, while inhigher lands adaptation to water scarcity also associated with climate change will require adoption o f crops with lower water requirements. As indicatedearlier this mayimplya slowing, or reversalofthe expansion ofthe irrigated Boro rice area. 62 Mitigation of Climate Change 185. Agricultural systems produce greenhousegasses. Carbon dioxide (C02), methane (CH4) and nitrous oxide ( N 2 0 ) areimportant greenhouse gases emitted from agricultural systems. These gasses have different reactivity inthe atmosphere, with CH4andN20 approximately 30 and 320 times more reactive than C02 perunit inthe atmosphere. Methane i s produced under anaerobic conditions and N20 i s produced by biological action upon nitrate as oxygenbecomes depletedinsoil duringwetting. Thus the level o f CH4 andN20 emissions from arice field depend onwater and other management factors. Ifcontinuously flooded, rice fields become anaerobic andthe levels o f CH4 emission are high'07, while aeration or drylngreduces CH4 emissions. 186. Emissions o fN20loss are much less clearly understood. Studies have shown that N20emissions arelow underirrigatedconditions."* AlthoughN20emissions are low duringthe period fields are flooded, N20emissions increasewhen the soil surface o frice fields dry or nitrogenfertilizer i s applied inthe floodwater. Researchto date has, typically, lookedat crop losses associatedwith crop managementfactors suchwithin seasonaldrymg, fertilizer form and application, and other managementactivities affecting C h andN20 emissions. Such studies o frice field emissions consider only emissions during the period of crop growth and do not addressN 2 0 emissions duringtimes o fnon-rice cropping, particularlyduring landpreparation for transplanting rice.log 187. MineralNitrogen (N)that accumulatesas Nitrate (NO3) under aerobic conditions betweencrops i s lost uponirrigation. These losses o fNare predominantly ingaseous forms, butthe amount lost as N 2 0 i s uncertain. The findings o fBronsonet al. (1997) indicated that these transitional losses amounted to some 30% o fmineral Nthat accumulates insoil prior to flooding at the time o f landpreparation. Givenaveragelevels o fmineralNo f 50 kgNha-' measuredinsoils prior to irrigation'" this would equateto 23.6 kgN(equivalent to 7.3 t C02 ha-'). Zhenget al. (2000) measuredlower fluxes duringthe transition upon flooding the rice crop. Emissions were approximately 5 kgN(equivalent 2.4 t C02 ha-'). 188. These transitional losses o fN20 canbe avoided either through improved management ofthe fallow period and rice crop establishment phaseor, where control over irrigation exists, by growing an alternateuplandcrop. Thus emissions from rice agriculture inBangladesh couldbereducedby: 0 Diversifyingo f agricultural production; 0 Management o fthe transition phases, together with improvements inthe efficiency o f rice production. 189. The potential for emissions avoidance o f CH4 andN20range from 4 - 11t C02per hectarewhere Boro rice i s replacedby anuplandcrop. Emissions under the improved technologies scenariowill depend on strategies adopted and whether transitional lossescan IO7 Absolute levels dependon factors such as soil type, levels o f organic matter incorporation, however IPCC (1996) use irrigation as the factor to estimate CH4emissions, reflecting its dominant control. lo* (Freney et al. 1981) 109 (Chen et al. 1996; Xing and Zhu, 1996) 110 (Hossain, 2001) 63 be avoided, but importantlyincreases inthe efficiency o f rice production will reduce the emission intensity, that i s the emissions o f CH4 andNzOper ton o f rice produced. V. SustainingSoil Quality:Recommendationsand Areas for World BankSupport Indicators of Soil Quality: Developing a Frameworkfor Monitoring Soil Quality 190. Given the importance o f the soil resource to sustainable development inBangladesh, and the critical importance o f increases inagricultural productivity, immediate actions should be taken to strengthenthe monitoring o f soil quality andproductivity. A review o f the current state o f the art inmonitoring o f soil quality should be undertakento enable Bangladeshto identify headline indicators o f soil function and associated soil properties that itwould be desirable to measure, bothqualitatively andquantitatively. These indicators should be inline with international best practice, but sensitive to the complex situation in Bangladesh, and selected to informongoing efforts to improve agricultural production. Identificationo f these indicators should form part o f the process o f developing a framework for soil quality monitoring, incorporating a methodology for monitoring. Existingsurveys should be reviewedagainst this framework to identify gaps and redundancies. TotalFactor Productivity as a Measure of Soil Productivity 191. Effective monitoring o f soil productivity requires consideration o f total factor productivity, which inturnmeans the collectiono f informationto supplement soil quality data. Such informationmust include data at an appropriate level o f aggregation on agricultural productionand trends, prices and quantities o f labor, fertilizer, pesticides, and other inputs, as well as socio-economic andenvironmental conditions. Define Institutional Roles and Responsibilitiesfor Monitoring Soil Quality 192. A variety o finstitutions have a role to play inmonitoringsoil quality. While SRDI is primarilyresponsible for soil monitoring andBARC provides coordination, anumber o f institutions includingNARS, BRRI, BARI, and various universities support relevant research, and DAE, BBS and M M I S are important sources o f data. To more effectively monitor soil quality, it i s important to more formally establish institutional responsibilities, and to agree on mechanisms for the collation o f data from these diverse sources. 193. Details o f existing surveys inrelevant GOBinstitutes and Ministries should be collated and reviewedfor complementarities and overlap. Key surveys are the annual survey undertakenby BBS on crop production, irrigation, croppingpattern and landuses, SRDI Longterm Soil Fertility Monitoring and Salinity Monitoring Surveys, and M M I S data on agricultural inputs." Effective monitoring will require either revisiono f component surveys and co-ordination between institutions undertaking these surveys, or expansion o fmonitoring efforts within relevant organizations. A key to compatibility between surveys will be to agree an appropriate environmentally and politically relevant unit for fbture monitoring and 111The BBS survey provides data on the production of rice, and other important crops, which are obtained from a sample o f 5,000 five-acre plots nationwide. The sample design and selection o f clusters was fmalized in 1963 andthese data are reportedandaggregated at the district level. Hoque and Sider (2004) indicate that 5% o fthe clusters are no longer operational andhighlightthe need to update andrevisit the sample design to reflect changesboth inland-use and the landscape. 64 underlying sample design. The potential to collate data at the Upazila level should be considered. Havingdefined a framework for monitoring soil quality, the design o fthe existing SRDI LongTerm Soil Fertility Monitoring and Salinity Monitoring surveys should bereviewedto assessrelevance, cost effectiveness androbustnessofdesign, andthe results to date should be published. A number o f development partners, includingthe World Bank, are ina positionto help strengthenthe soil monitoring framework through ongoing and proposedtechnical assistanceto the agriculture sector. Leveraging Funds Available Through Carbon Emissions Trading 194. The Kyotoprotocol establishedthat avoided greenhouseemissions indeveloping countries couldbe offset against emissions by industrialized countries (those listed inAnnex 1ofthe protocol). Markets enableemissions reductions to betraded creating a source of income. To date, the strategy for carbon trading inBangladesh has focused onreducing emissions from industry, energy and waste. An initial review suggeststhat an opportunity exists to monetize avoided greenhouse gas emissions associatedwith rice productionthrough carbon emissions trading. Researchsupport i s neededto substantiatethe extent o fthis opportunity, andtechnical assistancei s requiredto help develop a pilot project. Such apilot would aim to demonstratehow an income stream from carbontrading can provide support to promote crop diversification and the adoption o f improved agricultural technologies. The DesignatedNational Authority i s open to the idea, and should be approachedbythe agriculture community, inparticular BARC and MOA,to further develop this concept, with technical assistance from the World Bank as necessary. 65 Chapter 6: Institutionsfor EnvironmentalManagement 195. Environmental issues are key to economic growth andpoverty reduction in Bangladesh. Inits relatively short history as an independent nation, the government has made significant strides inthe development o f policies and institutions for environmental management. A number o fpublic sector environmental institutions have been established particularly at the national level. There i s growing public awareness o f environmental issues which have entered into the vocabulary o fmany public sector institutions. Further, the government has affirmed its commitment to the Millennium Development Goals (MDGs), including the goal o f ensuring environmental sustainability, which requires the integration o f the principles o f sustainable development into country policies andprograms, and reversal o f the loss o f environmental resources. The Government i s also committedto the Plan o f Implementation adopted at the World Summit on Sustainable Development (WSSD) in Johannesburg in2002, and i s partyto a range o f international environmental agreements, including the Kyoto Protocol. Despite these achievements and commitments, however, the present approachto environmental management, as illustrated inthis chapter, remains centralized and ad-hoc, with implementation falling far short o f legislated intention. This chapter provides a brief analysis o f environmental institutions inBangladesh, highlighting key areas where institutional strengthening i s needed. I. TheInstitutionalContextforEnvironmentalManagement 196. After independencein 1971, some o f the key environmental initiatives undertaken by the Government were the enactment o fthe Water PollutionControl Act, 1973,the BangladeshWildlife PreservationAct, 1973, and the EnvironmentalPollutionControl Ordinance, 1977. It was inthe 1980sthat environmental issues became seen as muchmore linkedto broader development issues and became institutionalized in 1989 with the establishment o f the present Ministry o f Environment and Forests (MoEF). 197. Formal responsibilities for environment management are vested inMoEF, butmany other institutions, directly and indirectly, are involved inmanaging or shaping the environment. These include public sector, private sector and civil society organizations. At the highest level, the NationalEnvironment Council (NEC), established in 1993 and headed bythe Prime Minister, and the Executive Committee o fthe NationalEnvironment Council (ECNEC),headedbythe Minister o fEnvironment andForest, are designedto provide guidance to line Ministries on national environmental issues. Moreover, the Planning Commission o f the Ministry o f Planning has the authority to supervise and coordinate cross- sectoral and inter-ministerial activities influencingthe use o f environment and natural resources. The potential role o f this Ministryi s important since it controls fimding for the implementation o f the Government's FiveYear Plan. Development partners and civil society have also exerted an important influence on environmental decision-making, with a range o f NGOsnow active onboth `green' and `brown' environmental issues. 198. While the institutionalization o f environmental issues into broader development practices has been gradual and inmany respects (such as EA laws) donor driven' 12,since the beginning o f the 1990's, the Government has taken a number o f important steps to strengthen environmental management inBangladesh. An enabling legal environment has beencreated, `I2 (Ahammed& Harvey, 2004) 66 inparticular throughthe Environment CourtAct (2000), andthe Environmental Conservation Act (1995) and Rules (1997), followed by a series o f new pieces o f environmental legislation issued since 2000113.Environmental policy formulation has beenledby the development o f the National Conservation Strategy (NCS) in 1991, adoption o fthe NationalEnvironment Policy (NEP) in 1992 andNational Forest Policy in 1994,andthe NationalEnvironment Management Action Plan(NEMAP)in 1995. Practice lags behindlegislation andpolicy, however, despiteisolated examples o f successful initiatives, such as the elimination o f leaded gasoline, the phasing-out o ftwo-stroke three-wheelers from the streets o fDhaka, andthe ban on thinpolythene bags. 11. The Ministry of EnvironmentandForest:Custodianof the Environment 199. Until1989,therewas no separateMinistrydealing exclusively with environment. In August ofthat year, the MoEF was created, withthe Forest Department beingtransferred to the new Ministryfrom the MinistryofAgriculture, andthe Department ofEnvironmental Pollution Control beingtransferred from the Local Government Division, and inthe process beingre-namedthe Department ofEnvironment. A Broad Environmental Mandate, but ResourcesFocused on Forestry 200. The main functionofthe MoEF is to act as the guide andcustodian for the conservation and development o fthe environment and, inthe pursuito fthat goal, to ensure through appropriate laws andregulations that natural resources, including land, air, water and forests, are exploited andmanagedinan environmentally sustainablemanner. The mandate o fthe MoEF i s broadly definedbythe NationalEnvironmentalPolicy (1992) andthe National Forest Policy (1994), and i s described inthe allocation o fbusiness among the Ministries o f the Government o fBangladesh. As indicated below, the formal functions o f the MoEF emphasizeforest management activities: 0 Define overall Government policy regarding forests and the environment, andto implementandevaluate suchpolicies through its departments; 0 Manage forest resources, and conserve and develop forest land, forest resourcesand wildlife; 0 Maintainnatural and environmental stability; Increase the country's forest resourcesina plannedmanner and arrange to meet the demands for these resources; and, 0 Effect environmental improvement andpollution control. The MoEF is apermanent member o fthe Executive Committee o fthe National Economic Council (NEC), a keydecision-making body for economic policy issues. The NEC also has the authority to approve all public investment projects. 113Including the Environment Conservation(Amendment) Act 2000, Environment Conservation (Amendment) Act 2002, Environment Court Act 2000, Conservationof Play Ground, Open Space, Parks andNatural Wetlands Act (inall municipalareas of the country), 2000, Environment Court (Amendment) Act 2002, Brick Burning Control (Amendment) Act 2001, andThree Amendments (in2002 and 2003) to Environment Conservation Rules 1997. 67 201. The MoEF pursues its activities through five institutions: the Forest Department (FD), Department o fEnvironment (DOE),BangladeshForest Industries Development Corporation (BFIDC), Bangladesh Forest ResearchInstitute (BFRI), and the Bangladesh NationalHerbarium. There are about 8,900 staff under the different agencies o f MoEF, o f which more thanthree-quarters are inthe FD (6,939 employees), and fewer than 3% inthe DOE.MoEF has anannualbudget (both development andrevenue) of about BDT2 billion (about US$34 million), which i s less than0.5% o f the Government's total revenue and development budget. Ofthis total, over 80% i s allocated to the FD and less than 1%to the DOE.Ofthe total MoEFbudget, about 30% isusedfor the payment of salaries, compared with 60% o fthe DOEbudget allocated for this purpose. Largely as a result o fthe focus o f MoEF resources on forestry, institutionalcapacity for environmental planningand monitoring, essential hnctions o f a national environmental custodian, remains weak. MoEF does not have any system inplace to monitor environmental quality, biodiversity, status o f protected areas, levels o f pollution or environmental degradation, and there i s no mechanism to make such information available to the public on a regular basis. TheInsufficiently Funded Mandate of theDepartment of Environment 202. The DOEwas formed in 1989 with a mandate for environmental management later formalized under the Environment Conservation Act, 1995 (ECA'95). The DOEi s headedby a Director General, with Divisional offices inDhaka, Chittagong, Bogra, Khulna, Barisaland Sylhet (see Appendix I1for an organogram o f the DOE).As the technical arm of the Ministry,DOEisresponsible for environmental planning, management, monitoringand enforcement. The mandate o f the Department has expanded over time, evolving fkom an exclusive focus on pollutioncontrol to include natural resources and environmental management, now covering: 0 monitoring environmental quality; 0 promoting environmental awareness through public informationprograms; 0 controlling and monitoring industrialpollution; reviewing environmental impact assessments and managing the environmental clearance process; and, 0 establishing regulations and guidelines for activities affecting the environment. Inaddition to the above duties, DOEalso coordinatesimplementationofanumber of international protocols and conventions to which Bangladesh i s a signatory. Ineconomic terms, most o f the hnctions that DOEi s mandated to serve (e.g. monitoring environmental quality and industrial pollution, environmental awareness and education, establishing regulations and guidelines) are public goods. One exception i s the environmental review and environmental clearance process which i s a service that DOEprovides for a fee to developers, which has bothpublic andprivate good characteristics. 203. While ECA '95 assigns the DOEbroad responsibilities for the control o fpollution, its natural resource conservationmandate i s more constrained. Only limited power i s assigned, extending to the designation o f Ecologically Critical Areas (ECAs - eight o f which have now been declared), and the prescription of uses o f such areas. DOE'S legal authority to declare any ecosystem an ECA i s also a source o f contention between the DOEand the FD. Further, 68 modalities for management o fthese areas have yet to be established, although a GEF- supportedproject has beeninitiated to buildthe capacity o fDOEfor the management o f coastal andwetlandbiodiversity at Cox's Bazar and Hakaluki Haor. 204. DOEcontinues to beunderstaffed, with only 191staffpositions, ofwhich only 85 are managerial or technical, the lowest level o f environment agency staffing per capita inSouth- East Asia. By comparison, HongKonghas a similar agency with more than 1500 staff.' l4 DOEis alsounder-budgeted relative to its broadmandate, with arevenue budget allocation of about BDT25 million (less thanUS$0.5 million). The Department's revenue budget covers only salary, limitedtravel and certainbasic logistics, with most programmatic and logistical requirements beingmet from project budgets supported by a variety o fdevelopment partners. The lacko f coordination betweenthese projects, andthe impossibility oftransferring resources between them, are significant factors incontributingto the further fragmentation o f DoE's already limited capacity. The Environmental Clearance Process: Dominant, but not Transparent 205. DOE,including its six divisionaloffices, is responsible for reviewingandapproving EAreports. Accordingto provisions made inECA 1995, DOEis authorized to issue environmental clearance on all types o f industrialandnon-industrial units andprojects. This environmental clearanceprocess dominates DoE's workload. In2000-2001,DOEprocessed almost 1,300 environmental clearanceapplications, a threefold increase since the enactment o fthe ECA in 1995.115 The requirement for higher impact facilities to annually renew their environmental clearances increasesthe administrative burdenon the Department still further. 206. ECA 1995 requires that no industrialunit or project be established without obtaining an Environmental Clearance Certificate from DOE.All projects are categorized into one o f four groups: Green, Orange A, Orange B and Red. DOEoffices ineach o fthe six divisions receive applications and issue Environmental Clearance Certificates for proposed investments within that division. The divisional offices verify supporting documents and passit on to the divisional head, who assigns an inspector for follow-up. For Greenand Orange A category projects, once the inspector submitsh i s report (typically within 5-7 days) the divisional headmakes a decision within three days o freceivingthe report. Files for Orange B and Redcategory projects are sent to the Senior ChemisVAssistant Director. The files are then forwarded by the divisional office to the Environmental Clearance Committee o fthe DOEinDhaka, andthenpassedto the Director General o fthe DOEfor final clearance"6. Most Environmental Clearancesissuedby DOEare from the Dhakadivisional office. 207. TheEAprocessis not transparentinpart becauseoflegalloopholes and limitations inEAlaws andregulations. There isno legalrequirement for public consultation duringthe Environmental Assessment (EA)process, or even for the provision o f information to affected people inconducting these assessments,"7 although there have beeninstanceswhen DOEhas arranged for the presentationofanEA inthe presenceofDOEstaff and invitedexperts. 114See Lam and Brown, 1997 '15DOE,2002 '16BEI, 2006 117Ahammed & Harvey, 2004 - although the EL4Guidelines for Industries 1997 suggest that an environmental impact assessment should involve the public, this has no legal force. 69 Askingfor public comment andinputinto decision-making depends uponthe interest o fthe entrepreneur. Clear legal provisions for EIA compliance and monitoring are also absent. As such, there i s little emphasis on project monitoring, and implementation o f EIAsi s ad hoc and dependent on the requirements o f donor agencies where these are involved.'" 208. The EAprocess i s a major source o f external influence on the Department. There are several reasons for this. While the ECA 1995 requires environmental clearance for development projects, it also reserves the ability o f the Government not to require any environmental clearance. This keeps open the possibility for project proponents to exert influence to avoid this requirement.'" Wide powers are accordedto the Director General o f the DOEwho has significant discretionary power to suggest any actions necessary to meet the objectives o f the Act, including the power to order closure o f industrial units inthe event that they do not meet adequate environmental standards. Further, inorder to obtain environmental clearances, businesses andproject proponents rely on a number o f intermediaries or service providers to help obtain environmental clearances from DOEand its divisional offices. 209. A survey o f fourteen such service providers showedthat inaddition to the official fees chargedby the DOEfor providing environmental clearances, inat least halfthe cases unofficial fees were paidby service providers inorder to obtain an environmental clearance certificate.'20 Inthe case o f "Red' category clearances, the average value o f the unofficial fee reported by the service providers was approximately US$500. This constituted only 5% o f the total fees paid for clearance, however, with some 90% beingpaid to the service providers (usually about US$900 for "Red" category clearances, risingto more than US$lO,OOO for very large developments). Inprinciple, the services providedinclude preparation o f EIAs and Ems, but the lack o f transparency and consultation inthe process provides little incentive for the effective identificationand mitigationo f potential environmental impacts. The issue o f rent-seeking i s certainly not peculiar to DOEand cuts across public sector institutions inBangladesh(see Box 6.1). InDOEand its divisional offices however, the emphasis on the EA clearance process has come at the cost o f compromising its work inother technical areas. For example, the engagement o f laboratory personnel inenvironmental clearance activities has caused the labs to be left unused, and staff to be unavailable for routine monitoring activities.I2l WeakEnvironmental Monitoring Capacity 210. Withthe bulko fits effort focused onthe environmental clearance process, DOEhas little spare capacity to systematically monitor and analyze environmental information. Although monitoring environmental quality has been conducted on an ad hoc basis for years, there has beenno systematic compilation, interpretation, or subsequent publicationo f these data. Without any quality control or public scrutiny o f the data, the little environmental data available i s generally o f questionable reliability. An important step towards quality-assured environmental monitoring has beentaken, however, with the systematic collection o f air quality data under the Air Quality Management Project, and the DOE'S recent commitment to publishanAir Quality Indexon a dailybasis. 118Momtaz, 2002 119Ahammed & Harvey, 2004 BEI, 2006 121Interviews conducted for preparation o f this report, 2004 70 Box 6.1: Governance inBangladesh The pervasiveness o f corruption i s a broadpublic sector governance issue inBangladesh. As a recent World Bankstudy points out, even after a quarter o f a century o f independence, the State does not ensure "rule o f law" or provide a well hnctioning regulatory andpolicy environment (World Bank, 2002). The cross-country corruption perception index preparedby Transparency International places Bangladesh 145 out o f 146 countries surveyed (TI, 2005). Contributing to weakness inpublic sector governance is a weak judiciary, a corrupt public sector procurement system and police. For instance, surveys undertaken by the BangladeshChapter o f Transparency International, revealed that 89% o frespondents believedthat it was almost impossible to get quick and fair judicialjudgments without money or influence, and 63% o fhouseholds involved in court cases hadbribedcourt officials (World Bank, 1999). Research undertaken as part o f a Bank study titled TamingLeviathan also provides evidence for clientelism andpatronage inpublic administration, as well as estimates o f the economic costs o fpoor governance. For example, surveys show that as a result o fbribespaid, the registered price o f land is reduced by 25% on an average, amounting to a loss o f Tk. 400 million o f government revenue annually (ibid.). Dueto risingpublic pressure, the Governmentpassedthe Anti Corruption Commission Act in 2004, which created legal space to establish an independent body to address corruption, (replacing the earlier Bureau o f Anti-corruption, itselfbelieved to be widely corrupt). The extent to which this new body will be autonomous remains to be seen. Bangladesh's National Strategy for Accelerated Poverty Reduction (2005) recognizes that "a major thrust o fthe PRS [Poverty Reduction Strategy] has to be on ensuring good governance", and governance is the core focus o fthe World Bank's Country Assistance Strategy (CAS) for the period 2006-2009. The CAS emphasizes the broader governance issues facing Bangladesh, including an overly centralizedpublic sector, unhealthy competition betweenmajor politicalparties, weak public financial management, corruption related to procurement, and a weak civil service andjudiciary, all o f which compromises effective service delivery, including law and order, and is detrimental to the investment climate. Organizational Culture of DOE 211. Numerous studiesbasedon empiricalwork indeveloping and developed countries have pointedout the importance o f leadership for organizations to perform Committedleadership i s seen as keyto sustaining worker motivation, a sense of organizational missionand clear performance expectations. DOEand MoEF however, are characterized by frequentchanges o f leadership. InDOE,the leadership of the Director General hasbeen severely compromised bythe fact that this positionhas changedhands more frequently thanonce a year, for the last sevenyears. 212. Another key factor contributing to highperforming organizations i s an implicit trust and contract betweenleaders and employees, as illustrated byresearchina range o f developing and developed countries.123 Worker dedication andmotivationi s further supported by an organization that i s perceived as having a highsense o fmission, i s client responsive and i s anchoredby a management style that encouragesworker participation, decision-making and problem solving. By contrast, the operating environment within DOEi s characterized by frequent changes inmanagement, administrative redtape that delays decision-making, and an organizational culture that is influenced by informal lines o f authority to higher levels. Director Generals are always appointed from backgrounds not 122Wilson, 1989, Grindle, 1997; Khaleghian and DasGupta,2005 lZ3Grindle, 1997 71 linkedto management o f the environment. Moreover, interviews withvarious staff and stakeholders showed that there i s lack o f accountability inthe internal workings o f the organization. Externally DOEi s seen less as an advocate for environmental sustainability and more as a policing agent, contributing to its "image crisis". Moreover, DOEi s a very centralized department with representation at the divisional level only. Effective application o f the Department's limited resources i s hamperedby the lack o f regular coordination betweenthe DOEand its divisional offices, to whose work little importance i s attached. This i s discussed inmore detail below. TheForest Department: DeJining Roles in Conservation and Social Forestry 213. The FD, established in 1862, i s responsible for the conservation and management o f Bangladesh's forest resources through implementation o f the Forest Policy, Forest Master Plan, and enforcement o fthe Forestry Act, as well as implementation o f aspects o fthe National Environment Policy, such as those pertaining to the conservation o fbiodiversityand wildlife, and the sustainable management o f forestry resources. The FDi s headedby the Chief Commissioner o f Forests, and forest management takes place through officers working at the divisional l e ~ e 1 .In~addition, each o f the divisions i s divided into circles staffed by l ~ forest officers, rangers, and guards, with each forest officer covering two or three upazilas. 214. Bangladeshhas limited forest cover, at 10%o f land area, down from 20% inthe 1 9 6 0 ~ . Inpart, the decline can be attributed to governance issues linkedto the forest ' ~ ~ sector. An issue widely reported inthe press i s the complicity o f FD officials inillicit tree felling'26, and fieldwork carried out duringthe course o f this studyreinforcedthe widespread believe inthe lucrative nature o f some FDpostings. 215. Over the last two decades the FD has shifted its emphasis away from policing and conservationtowards community and extension-related roles associated with the rising importance o f Social Forestry. The NationalForest Policy (1994) marked a departure from the commercial emphasis o f earlier policies, emphasizing a commitmentto sustainable development, poverty alleviation, the participation o f local communities, support for private sector afforestation initiatives, and global environmental concerns (including biodiversity conservation and climate change). Implementation o f this policy took an important step forward with the enactment o f the Forest Amendment Act, 2000, which established Social Forestry as a h c t i o n o f the FD. 216. The Forest Sector Review, 200412', recommendedthat the FDbe split into two directorates, (i) the Directorate o f Park Service and Conservation, and (ii) Directorate o f the Social Forestry, bothto be placedunder an Inspector General for Renewable Natural Resources. The role o f the Directorate o f Park Service and Conservation would be to manage protected areas and Ecologically Critical Areas (as declared by DOE),while the Directorate o f Social Forestry would manage community forestry initiatives, includingthose inReserve Forest areas. To date, there has been little progress inimplementingthese reforms. Forestry division do not coincide precisely with administrative divisions. 125 FAO, 2000. The FA0 definition requires both that tree cover be 10% or more, andthat the predominant land use be forestry. MODIS satellite imagery suggests that the true area with 10% or more tree cover may be as much as 35% o f tota1land area. lZ6 TI, 2000 127 Bangladesh Forest Department (2004). The Forestry Sector Review Report. 72 111. EnvironmentalManagement at Sub-NationalLevels 217. Bangladeshhas a longtradition o f sub-national government. Since independence, sub-national government structures have changedperiodicallywith different political regimes, none o fwhich have lasted for a long enough time to become rooted and consolidated as effective institutions o f service delivery.128 Currently, there are six divisions, 64 districts or zilas, 460 sub-districts or upazilas, 4,500 unionparishads and 68,000 gram sarkars. O fthese, the principal elected local government structures are the unionparishads. There is no electedrepresentation at the divisional, district or upazila level. Officers at these levels operate with upwardaccountability, representing a deconcentratedmodel o f infrastructure and service delivery. Representatives are elected, however, to unionparishads andpourashavas(municipalities). At the village level, GramSarkars, establishedthrough the GramSarkar (Village Government) Act promulgated in2003, functionwith 13members representingidentifiedsocio-economic groups. 218. There i s no uniform structure to sub-national representation o f central government agencies, with the FD, for example, beingstructured around forest cover, and a divisional structure that differs from those o f local government. Most o fthe larger government agencies, however, follow the administrative pattern, with a hierarchy o f offices down to the Upazila level. 219. At the sub-national level, it is the upazila administration that isprincipally responsible for basic service delivery. Many central government departments and agencies are representedat this level but the officers remainunderthe authority o f the central government. Planning and coordination o fdevelopment activities inthe upazila are undertaken by the UpazilaNirbahiOfficer (UNO), who is appointed bythe central government andthe Upazila Development Coordination Committee (UDCC). The UDCC consists o fthe chairmen o f eachunion within the upazila, andwho chair the committee on a rotatingbasis. Members o fParliament ( M p s ) act as special advisors to the UDCC, exercising considerable influence, andthe UNO i s a member secretary. The UDCC i s responsible for allocating the Annual Development Plan(block) grants within the upazila. Formal responsibilities o fthe UDCC include reviewing, preparing, andoverseeing development projects, and advising unionparishads on development schemes. Coordination at this level is weak, inpart becauseneither the DeputyCommissioner at the district level, nor the UNO are responsible for preparation and coordination o f comprehensive regional development plans.'29Upazila leveloffices of government organizations normallyreport to two different bodies, first to their own higher level official at the district level, and secondto the upazila administration, which i s effectively the UNO. 220. Unionparishads have beenvested with a range o f development functions, including construction and maintenance o f small scale infrastructure (katcha roads, bridges, canals, and culverts), potable water supply, and flood control infrastructure. They are also responsible for planning andmonitoring o fthe ADP, and local revenue mobilizationand collection. They generatevery little revenue oftheir own, however, depending heavily onblock grants fiom central government allocations, supplemented insome cases byresources from local programs supported by development partners andNGOs. They also have little discretion 12'Westergaard& MustafaAlam, 1995 129ADB et al. 2003 73 over usingthe money that i s collected and face numerous restrictions inthe use o fblock grants by detailed guidelines. Further, decisions relating to implementation o f programs in basic services such as health, education, and water supply, lie with government line departments at the upazila level. Even though union chairman could potentially play an important role through their participation as chairman o fthe UDCC, inpractice their roles are largely constrained to advocacy. Partially De-concentrated Model of Environmental Management 221. The environmental management system inBangladeshconstitutes an extremely centralized and partially deconcentratedmodel o f environmental management. At the divisional level, there i s a Divisional Environmental Advisory Committee headedby the Divisional Commissioner with representation from various government agencies. While the MoEF has forest officers posted below the divisional level, the DOEdoes not have any representationbelow this level. An important gap inexisting formal rules (the Constitution and other laws) i s that the divisions, districts, upazilas, unions do not have a clearly defined role to play inenvironmental management. Lack o f an appropriate mandate and institutional arrangements below the divisional level is a key factor contributing to difficulties in implementing environmental policies and regulations. 222. DOEhas divisionaloffices ineacho fthe 6 administrative divisions o fthe Inadditionto their roleinthe environmental clearance process discussed earlier, theyplay a monitoring and enforcement role, but are not mandatedto provide technical advice to firms and stakeholders (see Box 6.2). Moreover, they get little systematic support from the DOE headquarters at the national level to carry out their activities. The mandate o f the Divisional Environmental Advisory Committees i s to advise on environmental issues, give directives to district level agencies, and coordinate among line agencies at the regional and local levels. These institutional arrangements have not been hlly functional, however, and as a result, Divisional Environmental Advisory Committees rarely meet, and lack authority to ensure implementation o f decisions taken. 223. At the upazilalevel, there is no designatedenvironmental focalpoint or coordination mechanism, and little consideration i s given to environmental concerns. Except inrare cases or complaints, officials at the upazila level are not intouch with the divisional offices o f the DOE.Fieldvisits to severalupazilas duringthe course ofthis studyfoundthat environmental issues are addressed inan ad hoc manner by sectoral officers at the upazila level, particularly when activities inone sector (for example, agricultural runoff) influence activities inanother sector (such as productivity and sustainability o f fisheries inlocalponds). There i s no leadership or mechanism, however, for addressing environmental sustainability issues across sector activities at the upazila level. Line ministryrepresentatives pursue sectoral agendas, with environmental sustainability falling through the cracks.' 3' Considering that officers at this level are not electedbut appointed at the national level, leadership from the line ministries will be crucial ingreater integration of environmental issues at the upazila level. Further, the UNO andthe UDCC could play a muchgreater role inaddressing environmental sustainability issues at this level. I3ONamely Dhaka, Chittagong, Khulna, Rajshahi, Barisal and Sylhet 131Examples might include health officers interested inproviding health services but not in environmental health issues, or agricultural officers focusing on productivity but not ago-chemical environmental risks 74 Box 6.2: Functioning of Divisional Offices of the DOE A fieldvisit to the Rajshahi divisional office o fthe DOE,located inthe town o fBogra, provides a snapshot o f the capacity constraints faced at this level. There are 17 staff inthis office, but only one environmental inspector (compared to three inspectors inthe Dhaka division), and the revenue budget allocation for the divisionaloffice was approximately US$ 30,000 inFY05. The divisional office is mandated to issue environmental license? for investments falling under the ECA 95's Orange-A category (Orange-B andRed categories fall under the purview o fDOE at the national level). Within this category, there are numerous small- and medium-scale industries (e.g. rice husking, brick making, dyeing and handloom industries). One constraint faced by the Bogra staff i s that many f m s do not know they have to obtain environmental clearances. The mainrole o fthe office is monitoringenvironmental quality and inspection, including oversight o f a number o f large public sector f m s , including sugar mills, distilleries, and a chemical factory, all o f which are highly polluting. Monitoring capacity is very limited, however, and the divisional office is not mandated to providetechnical advice to f m s . The divisional DOEcollects fees for issuingand renewing environmental clearances. There is little incentive for the staffto do this systematically, however, as this revenue is returnedto the national exchequer. Regarding linkages with other levels o f government, interviews suggestedthat guidance from the center to the Divisional office is adhoc, andthere are no links betweenthe Divisional office andupazilaor union offices. Source: World Bank ThePotentially Important Environmental Role of Union Parishads 224. Unionparishadspresentlyhave a limitedrole inenvironmental governance. Their mandatesinclude maintenance o fvillage markets, public ponds, graveyards, and recreational places. A potentially important environmental role for unionparishads i s conferred under ECA `95,which requires that while applying for environmental clearance from the DOE,the applicant i s to obtain and submit aN o Objection Certificate issuedby the Chairman o fthe unionparishad (or Municipal Chairman inpourashavas, and the City Corporation Executive inmetropolitanareas). Withno systematicreviewor assessmentprocessinplace, however, these certificates are normallyprocured through privatenegotiation. Nevertheless, ifgreater public consultation couldbe introduced into this process, unionparishads could perform a valuable role inenvironmental management, particularlyconsidering their uniquepositions as locally-based elected representatives. 225. Inadditionto the No ObjectionClearancefunction inthe EL4process, unionparishads perform a variety o f further environmental managementroles, particularly inthe development o f local infrastructure, managemento fwater supply and sanitation investments, andinfluence over the allocation ofnatural resourceleases, includingfisheries. At the upazila level, unionparishad Chairmen are members o fvarious committees and chair the UDCC by rotation. With enhanced awarenesso f environmental concerns, unionparishads could become an important local force for environmental protectionand improvement. IV. Environmental Management in Other Sectors: Incentives and Coordination 226. The MoEF and its Departments, while directly mandatedto undertake environmental management functions, only account for a small percentageo ftotal public expenditure on environmental management. Lineministries whose activities have major implications for the 75 environment include Energy, Transportation, Agriculture, Fisheries and Livestock, Water Resources, and Relief andDisaster Management, among others. Almost 10%o fpublic expenditure i s allocated for environmental purposes, based on a broad definition o f environmental expenditures that includes the following categories: Degradationrelatedpublic expenditures -including public expenditures for activities such as the establishment o f laboratories for soil testing, for arsenic testing inwater, for clean fuel projects, projects for reductiono f water logging, and other cleanup activities; Resourcerelated public expenditures - including public expenditures for programs such as afforestation, establishment o f eco-parks, aquaculture development, integrated coastal management, and agricultural researchprograms; Water related public expenditures- includingpublic expenditures on water supply, sanitation, and canal maintenance; Disaster related public expenditures -includingpublic expenditures on flood protection structures, programs to develop early warning system o f disasters, river bank protection programs, and construction of shelters. A recent review o fpublic environmental expenditures inBangladeshconducted for this report'32found these resources to be allocated betweenthe four categories described above as summarized inFigure 6.1. Figure6.1:PublicEnvironmentalExpenditures Allocation of Environmental Budget E Managementand mitigation of environmentaldegradation 36 Naturalresource managemen 20% Water resource management, water supply and sanitation IBDisasterpreventionand mitigation 28% fi 132E. Haque, 2005. PublicExpendituresonthe EnvironmentinBangladesh- backgroundpaper for CEA 76 227. Trends inpublic expenditure for environmental management are indicated inTable 6.1. Inthis Table, degradationandresourcerelatedpublic expenditures as defined above are grouped together as EE1, on the basis that these primarilyconstitute expenditures on environmental monitoring, protection and remediation. Water and disaster related expenditures as defined above, which are more associated with the provision o f services and protection from natural disasters, are added to EE1to form a more broadly defined category o f environmental expenditures, EE2. 228. As Table 6.1indicates, the levelo fpublic expenditure onthe environment has been relativelyconsistent over the last decade, with EE1at about 0.5% o f GDP, and EE2 approximately equivalent to 1.5% o f GDP. The increase inenvironmental expenditures in 2001-02 was largely a response to the floods o f 1998, which were followed by anincrease in public expenditure for a variety o f purposes, including flood control and afforestation. The higher levels o f EE1expenditure in 1995-96are not directly comparable, as they include expenditure on sanitation, which i s incorporated inthe EE2 estimates for subsequent years. Table 6.1: TrendsinEnvironmentalExpenditure II 1995-96 1998-99 2001-02 2002-03 II II II EE1 share ofPublic Expenditure 5.24%* 3.28% 4.62% 3.28% EE1 share of GDP 0.70%* 0.44% 0.69% 0.48% MoEF share of EE1 2.67% 3.14% 5.03% EE2 share of Public Expenditure 10.81% 13.01% 9.11% EE2 share of GDP 1.46% 1.94% 1.33% MoEF share of EE2 0.81% 1.11% 1.81% Notes: EEl covers degradation- andresource-relatedpublic expendituresas defined above. EE2 includes water- and disaster-relatedpublic expendituresas defined above, as well as all EE1 expenditures. *EEl estimatesfor 1995-96include expenditureson sanitation, which insubsequentyears are includedinEE2. 229. Table 6.1 also indicates MoEF's share inpublic environmental expenditures. While this share has been rising, it i s striking to note that the Ministry only accounts for 5% o f the Government's budget for environmental monitoring, protection and remediation (EE1), and less than 2% o f environmental expenditures more broadly defined (EE2). These figures serve to underline first, the importance o f environmental management policies and actions inother ministries, andsecond, the need for MoEFto play a proactive role incoordinating cross- sectoral environmental initiatives. The status o fthese twinimperatives i s considered briefly below. Sectoral Capacityfor Environmental Management: Building Systems and Incentives 230. A range o f sectoralpolicieshave significant consequences from an environmental perspective, inparticular the Water Policy, Forest Policy, Fisheries Policy, Tourism Policy, Energy Policy, PetroleumPolicy, Agriculture Policy, and IndustryPolicy. While the integration of environmental concerns into sector policies i s still poor, there have beenrecent 77 improvements, for example the inclusiono f referencesto environmental management inthe Industrial Policy (see Box 6.3). While such developments mark a growing recognitiono f the need to ensure environmental sustainability insectoral initiatives, there i s not yet any systematic process through which the environmental soundness o f suchpolicies maybe assessed and rn~nitored.'~~ Box 6.3: IndustrialPolicy (1999) - a Glass HalfFull One o f the 17 objectives o f the Industrial Policy is "to ensure a process o f industrialization which is environmentally sound and consistent withthe resource endowment o f the country" (Chapter 2, Section 2.12). The section on Institutional Support, under `Environmental Protection', states "To control pollution o f the environment, relevant provisions o f the Environmental ConservationAct 1995 and rules framed there-under will be enforced. All sponsoring authorities must ensure that new projects incorporate requisite environmental studies, environment pollution control and other environment related precautionarymeasures. Existing industries, which are likely to cause environmental pollution and endanger public health, musttake appropriate measures for controlling environmental pollution. Industrieswill be encouraged to obtainI S 0 14000certification." (Chapter-XV, Section 15.6). Despite these good environmental intentions, however, none o f the 24 strategies o f the policy relate to environmental management, and the chapter on fiscal and financial incentivesprovides no resources for pollution management. The National Council for Industrial Development (NCID) was instituted in 1999 to provide effective guidance for implementation o fthe Industrial Policy, and i s headed by the Prime Minister, withthe Minister for Environment andForest includedas aMember. The Executive Committee ofthe NCID, however, does not include any representation from MoEF. 231. A growing number o f line agencies are undertaking initiatives to buildenvironmental management capacity, such as measures adopted by the Local Government Engineering Division (see Box 6.4). The M h e r development o f environmental management capacity within key sectoral agencies is essential to meet the MillenniumDevelopment Goal o f ensuring environmental sustainability, and by distributingthe burden o f day-to-day environmental management, will enable MoEF to focus on more effective regulatory oversight. Inorder to strengthenthe incentives for development o f sectoral environmental management capacity, a key element o f MoEF's oversight role i s to builddemand for improved environmental performance, inparticular through the provision o fpublic informationbased on monitoring o f environmental quality and the analysis o fpotential -responses. Cross-Sectoral Coordination: a Proactive Strategyfor MoEF 232. MoEF i s responsible for working with other ministries to review andmonitor the impact o f development projects on the environment across all sectors. Public sector projects under consideration by the Planning Commission are inprincipalpassedto the MoEF for environmental review. With limited technical expertise available to fulfil this role, however, the opportunity offeredby this `environment lens' inthe public planning process is not utilizedto its full advantage, and several recent studies have pointedto the lack o f `33 RahmanandAha, 2005 78 coordination between MoEF and line Mini~tries.'~~specific guidelines for the preparation No andreviewofenvironmental assessments for non-industrial projects havebeenissued, and the processo fproviding environmental clearances for suchpublic sector projects i s ad hoc. While there i s a needto monitor the implementation o f environmental management plans for development projects undertakenby line ministries, DOElacks the resources, and further, has no authority to undertake legalproceedings against line agencies inthe event that they do not addressthe environmental impacts o ftheir activities. 233. The analysispresentedinthe preceding chapters underlines the challenges inherent in developing effective cross-sectoral coordination for environmental management. For example, as considered inChapter 3, the management o fwater quality inDhakarequires coordinated action byDWASA, DOE,Dhaka City Corporation, BangladeshWater Development Board, Ministryo fIndustry,andthe Department o f Shipping, insome cases with overlapping mandates andjurisdictions. Inaddition, the interests o fkey industries, such as tanneries andtextiles, mustberepresented, andmechanisms providedto inform and empower local citizens and community groups affected bypoor water quality and lack o f access to sanitation. Box 6.4: EnvironmentalManagementat LGED The Local Government EngineeringDepartment (LGED) plays a pivotal role inrural infrastructure development. Inorder to be able to deliver sustainable projects, LGEDhas pursued a strategy o f mainstreaming environmental concerns inproject development and implementation, and has supported training inenvironmental management, both for its staff and other stakeholders, including contractors selected to execute works under LGEDprograms. Environmental aspectshave been considered inLGEDprojects since 1992, when the first edition o f "Guidelines on Environmental Issues relatedto Physical Planning" was published. These guidelines have since been supplemented with more specific guidance, for example the "Environmental Codes o f Practice" prepared for the Rural Transport Infrastructure Project supported bythe World Bank. Under the same project, anEnvironmental InformationManagement System is also being pilotedto ensure that top executives inthe Department have access to environmental management informationfor all on-going projects. Recent studies, however, have pointed to the limited application o f LGEDguidelines inrural infrastructure projects (Ahammed & Harvey, 2004). The authors attribute this inpart to the urgent need for infrastructure inBangladesh and o fthe relative marginalization o f environmental concerns with respect to development concerns. 234. A strategy for MoEFto take amore proactive role inthe cross-sectoralcoordination o f environmental managementwould encompassthe following four elements: (i) building demandfor change through systematic monitoring, analysis andpublic disclosure of environmental information; (ii) analysis and recommendation o f options for the mitigation o f impacts; (iii) facilitation o fprocessesaimed at developing consensusbetween sectors and relevant stakeholderson agreed courses o f action; and, (iv) establishment o f indicators and performance-based incentives for implementation, with associatedmonitoring and evaluation. Although still at an early stage, the reduction o f emissions from diesel vehicles i s anexample ofan issueonwhich the DOEis taking concrete steps to buildconsensus and coordinate action by a variety o f agencies (see Box 6.5). `34See Ahammed & Harvey, 2004; Momtaz, 2002 79 Box 6.5: Catalyzing Cross-Sectoral Action -the Case of Diesel Emissions Withtwo-stroke three-wheelers now bannedfrom the streets o fDhaka, the worsening air quality canbe attributed mostly to diesel vehicles, estimated to contribute more than 80% o f emissions from mobile sources. A study conducted by DOEin2005 recommended a variety o f measuresto address emissions from these vehicles. Other than those relating to tightening o f emission standards, however, implementation o f most o f these recommendations lies outside the purviewo f the MoEF, as outlined below: rn Bangladesh Road Transport Authority, the Ministryo f Communications, and the Dhaka Transport Coordination Boardhave the primaryroles to play in(i) promoting the replacement o f the bus fleet with CNG or cleaner diesel vehcles, (ii) establishing bus franchse conditions that include emissions standards, and (iii) fares andprotecting routes to provide adequaterevenue for investment in setting fleet maintenance and renewal. Bangladesh Road Transport Authority also plays the leadrole in incorporating emissions tests invehicle fitness tests; The National BoardofRevenue has akey role to play inestablishing incentives for investment in cleaner vehicles through duties that reflect the environmental costs o f importing old diesel vehicles and engines; The availability o fcleaner fuels dependsprimarilyon the Petroleum Corporation, which must implement the recommendationto import low sulfur diesel, and the Rupantrita Pakritick Gas Company Limited, responsible for ensuring adequate availability of CNG for the renewed bus fleet. While implementation o f these recommendations lies outside its direct control, MoEF has an important mandate to promote these actions through the provisiono f air quality informationand policy analysis. By building public awareness o f the healthrisks posed by diesel emissions, andby establishing inter-agency consensuson appropriate remedial actions, MoEF canbe instrumental increating the public support and institutional momentum necessary for action. The Ministrycan also play a role insustaining such momentum through the provision o f financial support for investments incleaner transportation. The DOE has made important advances inthis direction by distributing the diesel options study and constituting a cross-sectoral committee to recommend specific measuresfor emissions reduction. V. Role of the Judiciary 235. Currently environmental cases may only be heardby the two Environmental Courts established in2002 under the Environment Court Act, 2000, inChittagong and Dhaka. The number ofcasesbrought to date is limited, andthe record o fsuccessful prosecutionsispoor. Untilrecently, onlynine caseshadbeenbrought inChittagong, mostlyagainst hillcutters. In one case a verdict against the defaulter was pronounced inthe form o f a nominal fine. Inthe last year, however, about a dozen further cases have beenlodged, mostly against brick kilns. InDhaka, only about tencaseshavebeenfiledbythe DOE,butintotal some 84 caseshave beenbrought before the Dhaka Environment Court. Most o f the recent cases have been filed against pollutingtextile dyeing industries byprivate parties, whose motivations have become a cause o f concern to the DOE.As the number o f cases heardhas been minimal, the Environment Courts have requestedpermissionto also entertain non-environmental suits. 236. The higher courts (the HighCourt and Supreme Court) have considered public interest litigation cases on environmental matters, with the BangladeshEnvironmental Lawyers Association (BELA)playing an instrumental role inintroducingthis practice, inspiringthejudiciary to take a more active role at the highest level incases o f environmental 80 interest. An important achievement won by BELA inresponseto its appeal was the Supreme Court decision in 1998 to grant citizens andNGOs the right to enforce environmental laws.'35 VI. NGOsandCivil Society 237. A large number ofenvironmental andnaturalresource managementNGOs have playedan importantrole inraising awareness o f environmental issues, piloting innovative environmental managementpractices, and introducingenvironmental considerations into broader decision-making. For example, the Forum o fEnvironmentalJournalists, Bangladesh (FEJB), has beenparticularly effective increating environmental awareness, and a numbero f State o fthe Environment Reports have beenproduced by civil society organizations. Field researchcarried out as part o fthis study also indicated that numerous NGOs are active at the upazilaandunion levels inundertakingactivities such as tree planting, delivery o f sanitation programs, andworking with fisherman to improve the sustainability of fisheries. InDhaka, NGOs are involved inthe management o fmunicipal solid waste, andhave been successful in accessingcarbon financing to support their initiatives. 238. The Coalition o fEnvironmental NGOs (CEN) was formed inthe late 1990's, attachedto the Association o fDevelopment Agencies Bangladesh (ADAB),to coordinate the engagement o f civil society on environmental issues o f concern, but didnot develop into an authoritative entity. As a result o fthe activities o f environmental NGOs, civil society has become more confident and forceful inasserting its views on environmental issues, andthe DOEhasbecome increasingly receptive to working with civil society groups. Inadditionto this activist stance, some of the larger, more broadly-basedNGOs have established their own environmental units, bothto help manage the environmental impacts o ftheir own activities, andto promote environmentally beneficialinvestments. 239. The private sector plays a dual role, acting both as a major source o f environmental degradation'36, andproviding a rangeo f environmental management services. The provision o fprofessional environmental serviceshasnot grown at the rate it mighthave, however, in partdue to the low levelofprivatesector engagementbythe DOE,as well as the limited emphasis placedonthe quality of EIAs and environmental data collection. International clients, bothprivate investors and development partners, are an important source o f demand for such inputs. There have also been isolated examples o f good collaboration between the public and private sectorsto address specific environmental concerns, such as the phasing out ofozone depleting substances and the introductionof appropriate low cost pollution managementtechnology into the textile sector. VII. StrengtheningInstitutionsforEnvironmentalManagement:Recommendations andAreas for WorldBankSupport 240. As the analysis above suggests, weaknessesinimplementation ofenvironmental laws and regulations inBangladesh canbe attributed to a number o f governance factors, including: 13'http://www.elaw.orglnews/impact/text.asp?id=32l 136see Matin, 1995 81 overly centralized environmental management system with practically no institutional mechanism at the lower administrative levels (upazila and below) to address environmental issues; 0 MoEF resources disproportionately allocated to the forestry department; low revenue allocation to DOEand heavy dependence o f the Department on donor funds; weaknesses informal laws, such as the absence o f a legal requirement for public disclosure and participation inEA laws and regulations; the top-down organizational culture o f DOE, combined with the lack o f horizontal accountability betweenDOEand sector Ministries, andlack o fvertical accountability betweenDOEand its divisional offices. 241. Strengthening environmental management inBangladeshwill therefore require action on a number o f fronts, from national planningdown to local decision-making, and across a variety o f sectors. At the national level, more regular functioning o f the National Environment Council and its Executive Committee would greatly enhance inter-sectoral coordination. At the local level, establishing a mechanism for public consultation prior to a No ObjectionCertificate beingissuedbythe unionparishad Chairman would significantly improve accountability inthe process. Continued efforts to buildenvironmental management capacity insectoral agencies, and to strengthen environmental assessmentinpublic sector planning, are essential to achievingthe MDGofmainstreaming sustainable development into country policies and programs. Above all, however, it is clear that a crucial requirement for better environmental management inBangladesh is improved functioning o f the DOE. StrengtheningDOEby Implementingits Strategic Plan 242. Giventhe wide remit of DoE's mandate, and the extremely limited human and financial resources at the Department's disposal, it is essential that the Department target its actions to achieve the greatest impact with the scarce resources available. Recently, DOE undertook an institutional assessmentand developed a strategic plan (and an action planfor its implementation) to clarify its goals, expected results and major initiatives (see Box 6.6) through the CIDA-supported BangladeshEnvironment Management Project (BEMP) p r 0 j e ~ t . This plan was approvedby DOEand should be implemented. One limitation o f l ~ ~ this plan, however, i s that it does not sufficiently address strengthening o f DOEcapacity at sub-national levels. 243. Evenwith a concerted effort to target its activities, by any reasonable standard there are not enoughhuman andphysicalresources to allow DOEto fulfil its mandate and implement its Strategic Plan.'38 Ina country of 130 million, the DOEhas been allocated only about 75 managerial and technical staff, barely more thanone officer for each o f the country's administrative districts. When DOEwas first createdin 1989, there was a government commitment to allocate 650 staff over time. The organizational structure recommended by BEMPto enable DOEto implement its Strategic Plan suggests: 137Intargeting the use ofits scarceresources, anoutstandingissuerequiringclarification isthe role ofthe DOEin naturalresourcemanagement and biodiversity conservation 13'BEMP, 2003. Restructuringthe DOEOrganization 82 Box 6.6: Strategic Plan of the DoE Current Proposed 244. DOEisprimarily a regulatory and enforcement department, andto successfully carry- out its mission, it needs staff inthe field with access to adequately funded logistical and laboratory resources. The emphasis on additional field positions will allow DOEto expand i s field presence to 20 regional offices, bringinggreater community presence andmore effective response to complaints and enforcement issues. While the medium-termgoal i s to develop field offices ineach o f the 20 "old districts", over the longer term the aim i s to expand coverage to each o f the country's 64 administrative districts. 245. As indicated above, DOEprovides no systematic support to its divisionaloffices. Moreover, the divisional offices o f the DOE cannot provide technical advice to the industries they monitor. Even though they are engaged inrevenue collection(through fees for renewal o f environmental clearances), they have little incentive to do this systematically, since these resources are returned to the exchequer. A change inroles and incentives would allow divisional offices to play a stronger role inproviding technical advice to the firms they work with, suchthat they are seen less as a policing andmore as a technical support agency. 246. An additional humanresourceissue that is seenby many DOEstaff as animpediment to higher performance, is the lack o f an environmental cadre within the Civil Service. Although pay and compensationremainthe same, a cadre permits incumbents to transfer betweenministries, andto participate intraining at the BangladeshPublic Administration Training Centre or the Academy o f Planning and Development. Perhaps most importantly, the establishment o f an environmental cadre would allow DOEstaffto rise beyondthe level o f Director, which i s equivalent only to the grade o f Deputy Secretary. The existence o f such a cadre would provide more attractive career paths, and would help strengthenthe Government's environmental management capacity beyondthe DOE. 247. A difficult butequally important factor that needs to be addressed is the organizational culture o f DOE, including the frequent changes inleadership, current top-down style o f management, and lack o f internal and external accountability. Addressing this "image crisis" i s likely to go a long way inimproving its relations with other sector Ministries and the broader citizenry. 248. Securing the financial support necessary to implement DOE'SStrategic Planwill be challenging. To enhance the credibility o f this effort, three principles should guide the allocation o f any new resources: increases infinancial resources and staffing should be accompanied step-by-step with improvements intransparency, accountability and organizational culture inDOE; while project financing mayprovide essential resources for training, equipment, and specific studies, such support mustbe accompanied by the increases inrevenue budget necessary to finance DOE'S evident need for increased staffing; and, given DOE'S heavy dependence on donor funds for programmatic requirements, a mechanism for better coordinating projects and funds needs to be established. With significant additional resources recently committedbyCIDA for technical assistanceto DOE,the most important role for the WorldBank will beto help addressthe revenuebudget issues through its dialogue with the Ministry o f Finance and ongoing programo f 84 development policy lending. The needto implementthe DoE's Strategic Plani s reflected in the policy matrix for the series o fDevelopment Support Credits supported bythe World Bank, andwill continue to beincorporatedinhture development policy lendingdiscussions. Improving Transparency and Accountability in the EA Clearance Process 249. Transparency i s a crucial element ineffective environmental regulation. Informingthe public andallowing itto participate inenvironmental decision-making can help build pressureagainst polluters, reward good performers, and strengthenthe credibility o f environmental institutions. Several specific actions canbe taken to improve transparency and accountability inthe EA clearanceprocess inBangladesh: Placing information about environmental clearances on the web: a first step inthis directionwould be for DOEto place informationrelatedto environmental clearances and complaints onthe internet, and to update this on a regular basis, to help establish public confidence inthe environmental decision-making process; Legal requirementfor public consultation in EA clearanceprocess: ifthe assessment o f environmental impacts i s to become an effective and meaningfulprocess, public consultation mustbecome apart o fthe statutory process, particularly for potentially highriskprojects. A first step inthis directionwouldbefor the government to prepare an appropriate amendment to ECR '97,requiringsuch consultation to take place; Establishing guidelinesfor EA of non-industrial projects: giventhat there are currently no legal guidelines for non-industrial projects, the current practice usedby project sponsors(including line Ministries) i s to sendproject proposals for environmental clearanceto DOEwith or without EM.The clearance o f suchprojects takes place after review by DOE,but the process i s ad hoc. Giventhe importance o f addressing environmental considerations, clear guidelines should bepreparedby DOEfor EAofnon-industrial projects, suchthat the processofgranting clearancesis not discretionary buthas full backing o fthe law; and Delegation of select environment clearancefunctions to sub-national level: the ECA '95 and ECR '97 makeno provisionfor the environmental clearance hnction o fthe DOEto bedevolved to upazila or unionauthorities, evenfor small scale, low impact investments falling under the Green Category. Limitingthe list o f industrialfacilities specified inthe ECR '97 as requiring clearance fiom DOE,and delegating responsibility for clearance o f lesspolluting facilities to local authorities would fi-ee- up scarceDOEresourcesto focus onmore serious environmental risks. Strengthening DoE's Monitoring and Enforcement Functions 250. Bangladesh has a dearth o freliable data on all indicators o f environmental quality, including air quality (both urban andindoor), water quality (both drinkingwater and surface water), soil degradation, biodiversity, and forest cover. The lack o fcapacity for sampling, monitoring, and laboratory testinggreatly hinders the enforcement o fthe government's environmental standards and deprives civil society o fthe ability to participate effectively in environmental decision-making. To help meet the pressingneedfor more reliable and comprehensive environmental information, the data gathering resourceso fprivate sector 85 bodies andresearchinstitutions should be harnessed. The role o f government, particularly DOE,couldthenshift fiombeingthe primarycollector ofenvironmental datato ensuring data quality, analyzing the results, synthesizing information, and disseminating the findings. Such arrangements couldbe establishedby MoEF through executive order. 251. InbuildingDOE'S ability to manage and disseminate environmental information, it will be important to prioritize and focus efforts around agreed strategic goals. At the national level, the provision o f an annual environmental scorecard would provide such a focus, and buildpressure for improvedenvironmental performance. Usinga small set o findicators o f key environmental concerns inBangladesh, the scorecard would be updated annually to track improvements and setbacks inenvironmental management. Locally, focus could be provided through a programto publishthe environmental performance o f industrial facilities, initially targeting selected industrial facilities o fparticular concern. This would both encourage industries to improve their performance, andat the same time would provide direction for improvedmonitoring by DOE. 252. While considerable strides have beenmade inenvironmental legislation, enforcement remains largely absent, with existing legal instruments left untested inthejudicial system. The DOEhas prosecuted very few offences under ECA `95, even at the recently established Environment Courts inChittagong and Dhaka. Ifthe DOEcouldbringmore environmental cases to court and those were tried properly, this would help buildthe credibility o f the government's environmental intentions. To do so, DOE'S capacity inlegal affairs will have to be strengthened, and the Department may need assistance inprioritizing suitable cases for action, collecting evidence, preparing the cases, andtaking prosecutions to court. Giventhe difficulty o f pursuinglegal remedies for environmental purposes, however, DOEshould also place greater emphasis on other forms o f incentive for enhanced environmental performance, especially financial benefits, inthe form o f waste-minimizing win-win solutions. StrengtheningEnvironmental Management Institutions at Sub-national Levels 253. For DOEto exercise its authority more effectively, it needs to have a more regular and coordinated interaction with its divisional offices. Moreover, officers at the divisional level needto be able to provide technical advice to firms since they are muchmore indirect contact with industries, firms and stakeholders. At the upazila level, given that DOEhas no presence, environmental issues mustbe addressed by the UNO, line ministryrepresentatives and UDCC, and integratedinto local development plans. Considering that officials at the upazila levelwork ina system o fupward accountability, these objectives will be more easily facilitated ifthe signals for prioritizing environmental concerns come fiom senior line ministryofficials. 254. At the unionlevelthere is no constitutional mandateto address environmental issues, andconsequently electedunionparishad officials cannotbe heldbroadly accountable for environmental concerns without constitutional changes. Greater specific accountability could be introduced, however, throughthe process o f issuingNo ObjectionCertificates for environmental clearances. At present, these are obtained through private negotiation with the chairman o f the union parishad. Mandating a process o fpublic consultation inthe issuance o f these certificates would enhance transparency and help incorporate environmental concerns indevelopment planning at the local level. Support for the development o f such a 86 processcouldbeprovidedthrough the World Bank's broader program o f assistancefor local governance. Incentivesfor ImprovedEnvironmental Performance by Industry 255. Regulatory approachesto improve environmental management should be complemented with incentives for voluntary improvements inenvironmental performance. Inthe caseofindustry,there isscopefor this to beachievedthroughthepromotionofwaste- minimization and eco-labelling initiatives. While this would primarily attract export- orientated businesses, particularly inthe garmentmanufacturing andaquaculture sectors, consideration could also be givento the promotiono f an eco-label for the domestic market. 87 256. The e n ~ ~ r a n ~~ch~ ai ~l a~~chsscn~ fbr ~analysis inthe CEA were selectedjointly e ~ e by MoEFand $heWorld Bank basalan their refetanee la growthand poverty r ~ d u ~ ~as o n . ~ weli as a ~ ~ ~ n ~ i ~ ofthe tai~ad~j ~ ~ value ~of krther analysis. These criicria led to the e r a o n a selection ofthe f o ~ l a five n ~ ~ ~topics: Basedon the analysis ~ r e ~ e n tindthe precedingchapters ofthis repart, the economic costs e a s s ~ ~ c i awith these sources of e ~ ~ ~ ~ r ~ dn ~m~er and~~atmay t e ~ i~o namauni ta n i ~ ihan4?4of e GDP. The e s ~ i ~ asharedafeach factor is i n d i ~ a ~indFigme 7.1, b~low. t ~ e WaterSuppiy andSanitatinn 34% Dhaka Surface Wales Quality 26 5% i Share of GDP Share by Scurce 257. Among the sources of e n ~ i ~~ ~e ~n a~ ~reviewed,athe lack of access to safe ~a ~ ~$ ~n ~ watcr and s ~ ~ t aimpases the~greatest casts, e t i ~ ~ ~ u ta almost 1.5% of~GDP, asna result ~ ~ ~ ~ ~ afthe p r o ~ u ~ t i lastitt ~~ o the ~ ~r eh ~ adeath and sickness caused by ~ ~ ~ t e r - b o ~ e ~ ? ~ t ~ c disease. ln a d d i t i a ~to these losses, the poor quality of surface water in and around Dhaka impclses~ d ~ ~costs~~ ~~ na a~tol nmore thannO.?% ~ t ~ ~ af GDP, inthe fbrm o f lost 88 agricultural and industrialproductivity, reduced amenity, and additional healthcare costs.13' The deathanddiseasethat couldbe avoided byreducing urbanair pollutionto one-fifth of current levels i s equivalent to almost 1%o f GDP, andthe costs associatedwith indoor air pollution fiom the burningo fbiomass fbels are at least as high. Initial estimateso fthe diseaseburdenassociatedwith exposureto elevated levels o f arsenic inwater indicate economic costs equal to about 0.13% o fGDP, approximately equal to the annual losses from the declining productivity o f capture fisheries. The analysis presented inthis report found no evidence for falling agricultural yields as a result o f declining soil productivity, and while there i s significant scope to strengthen institutionalcapacity for environmental management, no attempt was made to assign an economic cost to poor environmental governance. 258. The costs associatedwith the sources of environmental degradation analyzed inthis report, andthe fact that inall cases the poor are most severely affected, together form significant constraints to the achievement o fBangladesh's goals for growth and poverty reduction. The following sections o fthis chapter consider the extent to which adequate initiatives are underway to address these constraints, and identifypriorities for additional action, including potential World Bank support. While this report estimatesthe economic losses associatedwith the environmental impacts considered, it does not provide a benefit- cost or cost-effectiveness analysis o fthe proposedmitigating actions. Itwill be important to examine the costs o f the proposed actions inmore detail as an element o f the follow-up work ineachofthe priority areas. I. EnvironmentalRiskstoHealth:theNeedtoBetterAddressAirQuality 259. This report estimatesthat initiativesto reduce exposureto environmental health risks could result ineconomic savings equivalent to as much as 3-5% o f GDP. This would be achieved mainlyby improving access to adequate sanitation and safe water supplies, and by reducing exposure to indoor andurbanair pollution, which together account for about 97% o f the environmental factors contributingto the burden o fdisease. 260. The wide range ofinitiativesunderway to improve accessto water supply and sanitation was reviewedinthe World Bank's Country Water ResourcesAssistance Strategy, 2005. Inadditionto the Government's Total Sanitation Campaign, a variety o f schemes are supported by a number o f development partners including the Water and Sanitation Program for SouthAsia, ADB, UNDP, the Government o fthe Netherlands, DANIDA, WHO, JICA, WaterAid, UNICEF, and many national NGOs. The World Bank i s also actively engaged in this sector, both through the DhakaChittagong Water Supply and Sanitation Project currently under preparation, andthe ongoing Bangladesh Water SupplyProgram Project, which represents an important step towards the integration o f arsenic mitigation into an overall vision for safe water supply. 261. While significant resourcesare committed to improvingwater supply and sanitation, air pollution attracts relatively little attention, although respiratory infections anddisease 13'To avoid double-counting, the economic costs associatedwith Dhaka's poor surface water quality are adjusted inFigure7.1to exclude (i) productivity as aresult ofwater-borne disease, and(ii) fisheries lost reduced production. Health care costs are retained, as these are not includedinthe estimate o f productivity lost due to poor access to water and sanitation. As a result o f these adjustments, the estimated annual cost o f poor surface water quality inDhaka indicatedinFigure 7.1 is about US$360 million, compared with the total cost estimate o f US$400 million providedinChapter 3 , 89 caused by poor air quality, bothindoor and urban, may contribute up to 10%o f the total burdeno f disease, equivalent to the diarrhoeal disease causedbyinadequate access to safe water, lack o f sanitation andpoor hygiene. Indoor Air Pollution (IAP) inparticular remains almost entirely ignored, and urbanair quality continues to deteriorate, despite a temporary improvement following the 2003 banon two-stroke three-wheelers inDhaka. To help address IAP,the WorldBankplansto providetechnical assistance to explore sustainable delivery models for the information andtechnology necessary to reduce IAPexposure. The Banki s also supporting efforts to better control urban air quality through the on-going Air Quality Management Project, for which a follow-up operation i s under consideration, focusing on gross diesel polluters, fuel quality, and the expansion o f air quality monitoringbothwithin the capital and to other major cities. While exposure to agro-industrial toxics represents a relatively small, but growing share o f environmental healthrisks, the World Bank i s also preparedto assist the DOEaddress this challenge, includingthrough the use o f global resources to identify and control the risks posed by Persistent Organic Pollutants (POPS). 11. Protecting Environmental Quality inDhaka: a Focus on Water Quality 262. Environmental quality inthe capital city faces the triple threat o f air pollution, inadequate solid waste management, and contamination o f surface water. While initiatives are underway to better manage air quality and solid waste withthe support o f the World Bank and JICA respectively, little has yet been done to improve water quality, identified as a priority for World Bank engagement inthe BangladeshCountry Water Resources Assistance Strategy (2005). The total economic cost o f the poor management o f water resources in Dhaka i s estimated at US$670 millionannually, includingimpacts on humanhealth, as well as industrial and natural resourceproductivity. Giventhat economic activity inDhaka contributes about one-fifth o f GDP, environmental constraints to growth inthe capital constitute a national priority. 263. Improving the quality o f surface and groundwater inand around Dhakawill require significant public andprivate investment. The rehabilitation o f the existing sewerage and drainage system i s alone projectedto cost about US$lOO million. Inresponse to the Government's request, the World Bank i s helping prepare a project to improve sewerage, sanitation and storm water drainage services inDhaka. A proposed separate initiative to strengthenthe management o f environmental quality andwater resources would supplement these investments with support for appropriate treatment technologies targeting industrial effluent. Environmental compliance initiatives will form components o f both these projects, as well as planned support for private sector development. 111. Natural Resources under Pressure: Protecting Capture Fisheries 264. Withpopulationdensity among the highest inthe world, pressure onnatural resources inBangladeshi s necessarily high, and this report considers the impact o f this pressure on capture fisheries and soil productivity. As a Forest Sector Review was recently completed, the pressure on forest resources was not considered, although the land area under forest cover i s the second lowest inSouth Asia and most o f the nation's natural forests are significantly degraded. 265. Agriculture accounts for some 21% o f GDP, and the ability o f soil to sustain agricultural productioni s an issue o f national concern. Declines inrice yields insome areas 90 of Bangladeshinthe mid-1990's ledto a decline insoil productivitybeing inferred. The analysis o fmore recent datapresentedinthis report indicates, however, that yieldtrends are stable or increasing, andthat earlier assessments were influenced by a periodinwhich yields were below trend. Nevertheless, there remaincauses for concern, including evidence that fertilizer inputs are imbalanced and nutrient mining is occurring, suggesting that greater attention to the monitoring o f soil quality i s warranted. 266. Bangladesh's fisheries are estimated to provide two-thirds o fthe country's animal proteinneeds, which i s twice the regional average andthe seventhhighest inthe world. Capture fisheries and associatedwetlands play aparticularly important role inthe nutrition andwelfare ofthe poor. There is general consensus, however, that inland and coastal/marine capture fisheries are indecline. Threats include losses o f floodplain habitat due to agriculture andurbanization, lost connections along critical fishmigrationpathways, significant reductions indry seasonriver flows, over-fishing, and rapidly increasing industrial, human andagricultural pollution. Almost 30% ofall inlandfishspecies are insome danger o f extinction, andthere i s a fear that the inlandmajor carps, IndianSalmon and other coastal inshore fisheries, may be indanger o f collapse. The value o fthe productioncurrently lost eachyear i s estimated at about $60 million, with the nutritional and livelihood consequences beingfelt most severely by the poor. 267. The remarkablerecovery ofHilsa in2004, most likely as a result o f Government management activities, demonstrated that recovery o fthe capture fisheries i s possible if political will combines with good management. The actions neededto reverse the decline o f Bangladesh's capture fisheries are reasonably clear, and a framework for their implementation i s providedbythe Government's draft InlandCapture Fisheries Strategy. The Aquatic Biodiversity Conservation Project (closed in2005) andthe FourthFisheries Project (closing in2006) were supported bythe World Bank, and among other achievements ledto the development ofthis strategy. The Bank is prepared to provide further assistanceto support the implementation o fthe strategy and strengthencommunity management o f fisheries, as well as regional collaboration for the managemento fmarine and coastal resourcesinthe Bay o f Bengal. IV.' EnvironmentalGovernance: an Over-ArchingConcern 268. An over-arching theme that emerges from this report is the needto improve environmental governanceto strengthenincentives for behaviour andinvestments that lead to better environmental quality. The most important governance elements to support such incentives are access to environmental information, transparency and consultation for accountable decision-making, adequate institutional capacity for credible enforcement, and economic policies that promote improvedenvironmental performance. 269. Strengthening environmental managementinBangladeshwill require actionon a number o f fronts, from enhancedinter-sectoral coordination bythe NationalEnvironment Council, through mainstreaming o f environmental managementcapacity insectoral agencies, down to wider public consultation byUnionParishads. It i s clear, however, that essential requirements for better environmental managementinBangladesh are additional resources for the DOE,andimprovements inthe transparency o f its functioning. Despite its critical and wide-reaching mandate, the DOEcurrently receives less than 1%o fMoEF's annual budget, which itself i s less than 0.5% o fthe Government's total revenue and development budget. 91 Withthe support o fCIDA, DOErecentlyundertook an institutional assessment and developed a Strategic Planto clarify its goals, expectedresults andmajor initiatives. Securingthe financial support necessary to implement DOE'S Strategic Planwill be challenging, and must be accompanied by improvements intransparency and accountability to enhance the credibility o f the effort. 270. Giventhe continued availability o f technical assistance resources for DOE, particularly from CIDA and UNDP, the most important role for the World Bank will be to help address the revenue budget implications o f the Department's Strategic Planthrough dialogue with the Ministry o f Finance and the World Bank's ongoing program o f development policy lending. Such efforts may be complemented by planned World Bank support for the strengthening o f local govemment, which provides an avenue to increase consultation and accountability for environmental decision-making at this level. V. Prioritiesfor AdditionalActionandWorld BankSupport 271. Among the environmental challenges considered inthis report, a number are being addressed through a range o f initiatives that are already underway or planned, and a few pose risks that are relatively less pressing. The following three concerns emerge, however, as priorities currently receivinginsufficient attention given their relative significance: the threat o f air pollution to humanhealth; the needto better controlurbanandindustrial effluent inDhaka; and the continuing decline o f capture fisheries. The economic losses associated with these three environmental challenges alone may amount to more than 2.7% o f GDP, ineach case with the poor suffering disproportionately as a result. Inadditionto these three sectoral priorities, anover-arching concern i s the needto strengthenenvironmental governance. 272. To better address these challenges, this report recommends that the World Bank provide additional support for action ineach o f these three areas. Such support could take a variety o f forms: to reduce exposure to IAP, it would be appropriate at the current stage o f understanding for the World Bank to provide further technical assistance to explore sustainable delivery models for the necessary informationand technology. As urban air quality continues to deteriorate, the Bank will maintain support for the on-going Air Quality Management Project, as well as a possible follow-on operation; inresponseto the Government's request for assistance inbettermanagingeffluent in Dhaka, the World Bank is helpingprepare a project to improve water supply, sewerage, sanitation and storm water drainage services inDhaka. Inaddition, the World Bank would be preparedto support a separate initiative targeting industrial effluent, drawing on proposed further analysis o f industrial environmental compliance and pollution control inthe city. Environmental compliance initiatives may also form a component o fplanned support for private sector development; 92 0 with the FourthFisheries Project closing in2006, the Bank is preparedto provide M e r assistanceto support the implementation o fthe InlandCapture Fisheries Strategy developedunderthis project, and to strengthen communitymanagement o f fisheries. The Bank i s also prepared to support the development o f a strategic action planfor the managementofmarine and coastalresourcesinthe Bay ofBengal, for which an ecosystemapproach would be adopted to foster regional collaboration in addressingthe transboundary issues. To help strengthen environmental governance, the World Bankwill use the ongoing program o fdevelopment policy lendingto help addressthe revenue budgetimplicationso fthe DoE's Strategic Plan. The needto implement the DoE's Strategic Plani s reflected inthe policy matrix for the series o fDevelopment Support Credits supported bythe World Bank, and will continue to be incorporated infuture development policy lendingdiscussions. Inaddition, proposed support for the strengtheningo f local government provides anopportunity to increase consultation and accountability for environmental decision-making at the local level. 273. The technical assistance, investment andbudgetsupport operations discussedabove are reflected inthe World Bank's CountryAssistance Strategy (CAS) for the periodFY06- 09. Appendix I11provides a summary o fthe relevant products, and indicates the principal environmental managementoutcomes associatedwith each. Such initiativeswill complement the investment support andtechnical assistancebeingprovidedby other development partners to strengthen environmental management inBangladesh. 274. The activities proposed abovewill help the Government fulfil its strong commitment to the MDGs as reflected inthe National Strategy for Accelerated Poverty Reduction, in particular the Goals related to child mortality and environmental sustainability. Meetingthe target for reduction inchildmortality under Goal 4 will require efforts to reduce respiratory infections, which account for 18% o funder-fivedeaths, up to halfo fwhich may be associatedwith IAP. Meetingthe targets to ensure environmental sustainability under Goal 7 will require renewed efforts to reverse the degradation o furbanenvironmental quality, particularly inDhaka, better managenatural resources, including capture fisheries, and strengthen environmental governance. Initiatives to undertake the keyactions summarized above wil1,not only bringBangladesh closer to achieving its targets under the MDGs, butwill significantly contribute to the removal o f environmental constraints to poverty-reducing growth. 93 Appendix I:Dhaka Environment Programme Prioritized Portfolio of Water Quality Solutions #1 Improvement of Water Supply (Participants: all Dhaka residents and businesses; building developers; DWASA; Department of Public Health Engineering; Department o f Environment; RAJUK; DCC). Complete repairs to the DWASA supply system. Control groundwater extraction; shift to increasing surface water supply; examine long-term supply options for Saidabad, including an intake on the Meghna River. Promote rainwater harvesting. Examine options for reservoir development inMadhupur Tract. Develop guidelines on rainwater percolation. 0 Examine feasibility o fborehole aquifer recharge. #2 Treatment and Disposal of Sewage (Participants: all Dhaka residents andbusinesses; building developers; boat andship operators; DWASA; Departmentof Environment; RAJUK;DCC). Rehabilitatethe sewage collection systemandthe Pagla sewage treatmentplant. Construct four new sewage treatment plants. Banhangingandpitlatrines; use dry compostingtoilets. 0 Constructed wetlands insmaller settlements. Treat ship-based sewage. #3 Treatment and Disposal of Industrial Waste (Participants: Department of Environment; industries; DWASA;DCC; MinistryofIndustry;BSCIC; RAJUK). 0 Moratorium on industrial development inDhaka. Move tanneries to Savar; remediation o f Hazaribagh. Constructed wetland for Tejgaon wastewater. Settling ponds and reedbeds for textile industry clusters. Turn-key common effluent treatment plants. Flow control from proposed Madhupur Tract reservoirs. Fertilizer plantrunoff diverted. Regulations to control discharge o f cooling water. #4 Handling andDisposal of Solid Waste (Participants: all Dhaka residents andbusinesses; DCC; DepartmentofEnvironment). 0 Incineration o fhospital waste. 0 Three new landfill sites; remediationo f Matuail. Solid waste management at source. 0 Enforcebanon polythenebags. 0 Ditch and drain management. 94 #5 Flood Management, Dredging, and Improving River Navigability (Participants: Joint River Commission; Water Development Board; villagers inupstream watersheds; brick kiln operators; Department of Forests; RAJUK; DCC; DWASA; BIWTA; Dhaka residents and businesses; buildingdevelopers; private dredgers; Department ofEnvironment). Rehabilitate the Dhaka canal system. Dredging guidelines and enforcement o f encroachment guidelines. Reservoir and flood flow zone management. Landuse controls; management o fsediments duringconstruction. #6 Management of Household Liquid Waste (Participants: all Dhaka residents and businesses; Department of Environment; DCC). 0 Bandisposal o fliquidhazardous materials. 0 Domestic and restaurant grease traps. 0 Recycling o f grey water. Banphosphate-based detergents. #7 Management of Ship Oily Waste (Participants: boat and ship operators; shipyards; Department of Environment; BIWTA; Ministryof Shipping). Regulate treatment and disposal o fbilge water. 0 Guidelines on ship fueling. Waste oil management programme at ship yards. River oil spill contingency plans. #8 ImprovingAesthetics and Opportunities for Recreation(Participants: all Dhaka residents and businesses; buildingdevelopers; RAJUK;DCC; DWASA;BIWTA;WDB). Enforce the 50-metre buffer zone. Local area river management committees. 0 Improve ghat facilities for recreation. 0 Recreationalopportunities inproposedMadhupur Tract reservoirs. 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