75062 FINAL REPORT DHAKA METROPOLITAN DEVELOPMENT PLAN STRATEGIC ENVIRONMENTAL ASSESSMENT Prepared for: The World Bank Washington, DC Prepared by: SENES Consultants Limited In association with Techno Consult International Limited Dhaka Bangladesh July 2007 Printed on Recycled Paper Containing Post-Consumer Fibre Dhaka-Strategic Environmental Assessment TABLE OF CONTENTS Page No. EXECUTIVE SUMMARY....................................................................................... 1 1.0 INTRODUCTION ....................................................................................... 1-1 1.1 Rationale for the Strategic Assessment Study......................................................1-1 1.2 Objectives of the Study ........................................................................................1-3 1.3 Approach and Methodology of SEA....................................................................1-3 1.3.1 Analytical Component..............................................................................1-5 1.3.2 Participatory Component..........................................................................1-6 1.4 Output and Dissemination....................................................................................1-7 1.5 Report Structure ...................................................................................................1-8 2.0 SITUATION ANALYSIS OF DHAKA’S ENVIRONMENT.................... 2-1 2.1 Urbanization In Dhaka .........................................................................................2-1 2.2 Land-use and Land Management .........................................................................2-6 2.2.1 Housing, Slums & Open Spaces ..............................................................2-6 2.2.2 Industries ..................................................................................................2-9 2.2.3 Roads & Transportation .........................................................................2-10 2.2.4 Solid Waste ............................................................................................2-12 2.3 Water Resources and Quality.............................................................................2-13 2.3.1 Water Resources.....................................................................................2-13 2.3.2 Water Pollution ......................................................................................2-14 2.4 Air and Noise Quality ........................................................................................2-16 2.5 Flooding and Drainage .......................................................................................2-18 2.5.1 Illegal Filling of low lying areas ............................................................2-13 2.5.2 Illegal Filling of ditches and drainage channels.....................................2-14 2.5.3 Potential Climate Change Impacts on Dhaka.........................................2-14 2.6 Formulation of Environmental Priorities .........................................................2-222 3.0 URBAN PLANNING IN DHAKA ............................................................. 3-1 3.1 Overall Planning Process in Dhaka......................................................................3-1 3.1.1 Policy Guidance .......................................................................................3-1 3.1.2 High level Planning Focus .......................................................................3-2 3.1.3 Urban Planning for Dhaka........................................................................3-2 3.2 Regional Plans – Structure Plan & Urban Area Plan ...........................................3-5 3.2.1 Detailed Area Plans..................................................................................3-6 3.3 Sectoral Planning..................................................................................................3-7 3.3.1 Water Supply............................................................................................3-8 3.3.2 Sewerage and Sanitation ..........................................................................3-8 3.3.3 Drainage and Flood Protection ............…………… ………………… 3-10 3.3.4 Transportation ........................................................................................3-11 3.3.5 Solid Waste Management.......................................................................3-11 3.3.6 Industrialization......................................................................................3-12 3.3.7 Housing and Slum Improvement............................................................3-13 34445 –Final – Aug 2007 i SENES Consultants Limited Dhaka-Strategic Environmental Assessment 3.4 Institutional Set up for Governance & Urban Planning .....................................3-14 3.4.1 RAJUK – An Institutional Analysis.......................................................3-17 3.5 Analyzing Stakeholder Influence in Planning & Plan Implementation Process 3-21 3.6 Analysis of Planning Framework in Context of Environmental Priorities ........3-24 3.6.1 High urban densification in certain areas ...............................................3-24 3.6.2 Surface water pollution due to discharge of untreated sewage & effluent ...................................................................................................3-25 3.6.3 Depletion of groundwater.......................................................................3-27 3.6.4 Increasing vulnerability of floods ..........................................................3-27 4.0 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK.......... 4-1 4.1 Land and Land use Management .........................................................................4-1 4.2 Water Resources and Quality...............................................................................4-2 4.2.1 Depletion of Groundwater........................................................................4-2 4.2.2 Surface water pollution ............................................................................4-3 4.3 Flooding and Drainage .........................................................................................4-6 4.3.1 Increasing Vulnerability to Floods...........................................................4-6 5.0 SEA FINDINGS AND RECOMMENDATIONS ...................................... 5-1 5.1 Background ..........................................................................................................5-1 5.2 Summary of SEA Findings ……………………………………………………..5-2 5.3 Environmental Priorities that need to be addressed by DAP ..............................5-5 5.4 Recommendations ...............................................................................................5-7 APPENDIX A: Final Consultation Workshop Proceedings 34445 –Final – Aug 2007 ii SENES Consultants Limited Dhaka-Strategic Environmental Assessment LIST OF TABLES Page No. 2.1 Environmental Priorities in Dhaka.................................................................................2-24 3.1 DAP zones and categorization .........................................................................................3-5 LIST OF FIGURES Page No. 2.1 Spatial Growth of Dhaka..................................................................................................2-2 2.2 Administrative Map of the DMDP Region ......................................................................2-4 2.3 Spatial Disposition of Development Zones......................................................................2-5 2.4 Air Pollution from Vehicles in Dhaka............................................................................2-16 2.5 Ranking Matrix for Stakeholder Perception...................................................................2-23 3.1 DMDP and DAP Planning Areas .....................................................................................3-4 3.2 Urban Governance and Flow of Authority.....................................................................3-15 3.3 Interaction between Planning Institutions ......................................................................3-16 3.4 Principal Agencies Related to Urban Planning in DMDP Region ................................3-17 3.5 RAJUK Organizational Structure...................................................................................3-19 3.6 Stakeholder Analysis Matrix..........................................................................................3-22 3.7 Proposed Flood Retention Ponds – FAP 8A ..................................................................3-29 3.8 Proposed Flood Retention Ponds –Structure Plan .........................................................3-30 3.9 Proposed Flood Retention Ponds –Eastern Bypass........................................................3-31 34445 –Final – Aug 2007 iii SENES Consultants Limited Dhaka-Strategic Environmental Assessment ABBREVIATIONS ADB Asian Development Bank AQMP Air Quality Management Project BLD Billion Liters per Day BOD Biological Oxygen Demand BUET Bangladesh University of Engineering & Technology BWDB Bangladesh Water Development Board BWTA Bangladesh Water Transport Authority CETP Centralised Effluent Treatment Plant COD Chemical Oxygen Demand DAP Detailed Area Plan DCC Dhaka City Corporation DEPZ Dhaka Export Processing Zone DIEWRMP Dhaka Integrated Environment and Water Resources Management Project DITP Dhaka Integrated Transport Project DMDP Dhaka Metropolitan Development Plan DND Dhaka Narayanganj Demra DOE Department of Environment DMP Dhaka Metropolitan Police DPHE Department of Public Health Engineering DTCB Dhaka Transport Coordination Board DUTP Dhaka Urban Transport Project DWASA Dhaka Water and Sanitation Authority ECA Environment Conservation Act EPZ Export Processing Zone FAP Flood Action Plan GDP Gross Domestic Product GoB Government of Bangladesh HSD Housing and Settlement Directorate IDA International Development Association IGES Institute of Global Environmental Strategies IPCC Intergovernmental Panel on Climate Change IWM Institute of Water Modelling JICA Japan International Cooperation Agency JNURM Jawaharlal Nehru National Urban Renewal Mission LGED Local Government Engineering Department MLGRDC Ministry of Local Government, Rural Development and Co-operatives MoW Ministry of Housing & Works MSL Mean Sea Level MSW Municipal Solid Waste NWRC National Water Resource Council PM2.5 Particulate Matter <2.5 Micron PM10 Particulate Matter <10 micron PSRP Poverty Strategic Reduction Strategy Paper PWD Public Works Department RAJUK Rajdhani Unnayan Katripakkha REHAB Real Estate Housing Association of Bangladesh RHD Road and Highways Department RMG Readymade Garment Industry SEA Strategic Environment Assessment 34445 –Final – Aug 2007 iv SENES Consultants Limited Dhaka-Strategic Environmental Assessment SMPA Strategic Metropolitan Planning Authority SPZ Special Planning Zones STP Strategic Transport Plan TMC Technical Management Committee UDD Urban Development Directorate UGI Urban Governance Index UNDP United Nations Development Programme UNCHS United Nations Centre for Human Settlement WASA Water and Sanitation Authority WARPO Water Resource Planning Organisation 34445 –Final – Aug 2007 v SENES Consultants Limited Dhaka-Strategic Environmental Assessment EXECUTIVE SUMMARY 1 RATIONALE FOR SEA STUDY Dhaka is one of the ten mega-cities in the world. Growing at a very fast rate, the population of Dhaka urban area is predicted to increase to about 21 million by 2015 from the current population of 11.3 million. Dhaka’s rapid development, its fast-changing urban landscape and the associated critical environmental challenges call for holistic urban planning, strengthening of institutions responsible for urban development and good governance. The rapid unplanned urbanization has raised two sets of environmental challenges in Dhaka: ♦ The first arises from urban development projects in different sectors and industries which treat potential environmental effects as externalities and which only try to mitigate these effects as an afterthought, not as an integral part of the project. ♦ The second stems from the acute pressure on natural resources resulting from the indiscriminate use/misuse of these resources. This given, a high-level Strategic Environmental Assessment (SEA) was proposed by the Government of Bangladesh for the Dhaka Metropolitan Development Planning (DMDP) area with the aim to: ♦ understanding the complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka; ♦ providing future guidance to the urban development process so that it incorporates both urban planning and environmental priorities; ♦ providing strategic inputs to projects like the Dhaka Integrated Environment and Water Resources Management Project (DIEWRMP) which is currently being scoped; and ♦ proposing a strategy by which environmental priorities could be incorporated in Detailed Area Plans (DAPs) currently being executed. The SEA was drawn up as a participative process involving extensive stakeholder consultations. It provided a platform for dialogue between policy makers, planners, stakeholders and civil society at large on environmental priorities; and on how and why these priorities could be affected by the implementation of plans and policies (World Bank, 2005). The SEA findings will enable the World Bank to conduct a policy dialogue with the Government of Bangladesh on urban development issues in Dhaka. 34445 –Final – Aug 2007 1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 2 OBJECTIVES OF THE STUDY The specific objectives of this SEA are to: ♦ recommend policies, institutional arrangements and governance conditions needed for ensuring environmental sustainability of Dhaka’s urban development; ♦ provide overall direction to the DAP formulation and other sectoral projects; and ♦ ensure public participation and dialogue on urban development planning through a process of extensive stakeholder consultations. 3 METHODOLOGY One of the main objectives of this study is to assess the process of formulating the Detailed Area Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the environmental priorities identified by this study and the stakeholders could be incorporated in these plans. As the SEA was being initiated, it became evident that the whole process of preparing the DAPs was, from the start, handicapped by existing systemic shortcomings. Further, it became evident that the current process of DAP preparation would not be able to deliver the expected outcomes. The shortcomings identified were grouped under two headings: 1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated urban planning framework. Additionally, there is a lack of any stated mechanisms for coordinating with other sectoral agencies and their planning processes; and 2. Problems at the implementation level: these are a poorly informed plan preparation process, inappropriate survey design and inadequate allocation of technical resources by RAJUK (Rajdhani Unnayan Katripakkha). In order to analyse and understand these shortcomings and to identify the environmental priorities in the Dhaka metropolitan area, the following methodology was used. The analytical component of the SEA was constituted of three areas of investigations: 1. An analysis of the key environmental problems in the DMDP area based on secondary information available in various published studies and documents and an analysis of their linkages to policies, legislation and plans. 2. An assessment of the adequacy of existing urban plans and the planning process at the strategic level in order to make recommendations for improved planning and governance. 3. An assessment of the efficacy of the on-going DAP formulation process, review of the design and technical planning capacity in RAJUK; and identification of the areas and needs in RAJUK where interventions for capacity development would be beneficial to overall urban management. 34445 –Final – Aug 2007 2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The participatory component of the investigation, with inputs from all major stakeholders, helped to prioritise the environmental concerns. It highlighted the areas of institutional failures in urban and environmental planning and drew attention to issues of governance and the role of vested interests. 4 FINDINGS 4.1 Shortcomings and Gaps at the Strategic Level The Structure and Urban Area Plans do not provide any land use zoning principles which could be applied to design subsequent development. There are contradictions and lack of clear definitions. The Plans demarcate broad areas for future development but inherent contradictions/loopholes have provided scope for manipulation and encroachment. Guidelines have been provided in the Plans, but there are no directives for implementing them; hence, the Guidelines have been ignored by the implementing agencies. The plans have become dated and have limited relevance to resolving the present urban management problems. The sectoral policies in the Structure Plan do not relate them to the urban planning aspects. Most sectoral plans concentrate on finding local and short-term solutions to urban problems, particularly within the DMDP. RAJUK by its constitution, however, has the power to coordinate with the sectoral agencies whose plans affect the urban area. There has been a failure of leadership. Further, the Structure and Area Plans do not contain any discussion on vertical and horizontal transmission of the decision-making process and the decisions themselves. Implementation of urban and regional plans needs considerable co-ordination and collective design and decision-making by all agencies. There are no stated mechanisms for co-ordination or any over-arching planning framework which would have enabled agencies to collaborate and co- ordinate their plans. The result has been fractured, haphazard and environmentally unsustainable urban spread and inadequate infrastructural development. The strategic level plans did not tackle the problem of multiple administrative authorities within the DMDP and how their developmental efforts could be managed at the regional level. Thus, the overall problems noted above are exacerbated by the fact that DMDP is carved up into smaller administrative units (municipalities and Pourashavas). Of concern is that piecemeal planning and un-coordinated infrastructure development are taking place, often to the detriment of long-term environmental sustainability. The haphazard growth is further reinforced by the national funding mechanism for Annual Development Programmes, which include urban projects. The projects are approved by the 34445 –Final – Aug 2007 3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment relevant ministries or the Planning Commission on budgetary criteria. The outcome is that there is limited urban overview of what is happening on the ground. Urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic approaches to development; multiplicity of agencies; collusive relations between government agencies and vested interest groups; low levels of environmental awareness among sectoral and local authority planners; and very limited effort to achieve real public good. The five teams of DAP consultants appointed by RAJUK need additional guidelines for local area plan formulation; increased information on framework for developing a coherent regional approach; better mechanisms to coordinate the plans of adjoining local / sector authorities; and support and coordination from RAJUK to deal with large sectoral organisations like DWASA or with local authorities. 4.2 Plan Development and Implementation Problems The problems at the implementation level relate to: (i) Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened, was gradually downgraded and to this day the Planning Department remains technically understaffed. There has been no updating or enhancement of qualifications of the current planners. Their notions of urban planning are techno-centric and dated, and complexities of social planning do not sit easily in their thinking. In fact they were ill-equipped to design the DAP preparation process. Consequently, the Terms of Reference are over-ambitious. The technical resources allocated are inadequate and dated. Moreover, the planners have not provided any guidelines to the consultants for demarcation of environmentally-sensitive areas where urban development should be restricted. These include wetlands, flood flow zones, retention ponds, canals and natural drainage channels. There is thus the danger that the DAPs could further exacerbate the problems of urban environmental management. In the absence of any directives, and reflecting the generally low environmental awareness, the DAP consultants appear to have limited understanding of the pollution-intensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. Of greater concern is that the DAP preparation is not guided by any strategic level planning framework. This means that the five groups of consultants are each contained within their own 34445 –Final – Aug 2007 4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment zones, rather than within a regional approach. This means that piecemeal development will be continue even under the new plans. (ii) Challenge for DAP consultants: In view of the complexities involved in formulating the DAPs, the SEA team concludes that the local consultants selected for this purpose do not appear to have comprehensive technical capability or the experience to complete the terms of reference. (iii) Poor leadership of the Technical Committee: The DAP planning process was found to have a very weak interface with the sectoral planning agencies and, as a result, is unlikely to produce plans that can be integrated with the sectoral strategies and plans. This is because: (a) the Technical Management Committee which is charged to oversee plan preparation has been ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared; and (b) the DAP consultants have also been unable to establish useful contacts with sectoral agencies to address the sectoral issues of the local level plans. 4.3 Environmental Priorities that Need to be Addressed by DAP The importance of getting the DAP planning process right is underscored by serious environmental problems already affecting Dhaka and its surrounds. The environmental priorities as identified by this study are given below. 4.3.1 Land and Land use Management (i) Increasing overcrowding in the already developed areas: The growth within the already developed areas has taken place in a random manner, sometimes in contravention of existing development control legislation or by using loopholes in the legislation. As a result, land resources within the city have been put under stress, wetlands within the city have become filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress resulting in significant strain on environmental resources. (ii) Unplanned development in fringe areas and encroachment: With decreasing scope for inner city growth, large areas in the environmentally sensitive fringe zone are being targeted as they have been marked for development in the Structure Plan. Such areas have also seen an increase in land prices as a result of speculation and land grabbing, making it difficult to accommodate poor and vulnerable sections of the society in these areas. Indiscriminate land-filling is already leading to loss of natural drainage channels and sink areas that increase the vulnerability to flooding. 34445 –Final – Aug 2007 5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 4.3.2 Water Resources and Quality (i) Surface water pollution: The river systems and the water bodies in the Dhaka Watershed are so contaminated by discharge of industrial effluents and untreated sewage that it cannot be treated to potable standards. The role of the DAP lies in initiating a dialogue with industry and a process to identify locations for future industries. (ii) Reliance on and depletion of groundwater: As surface water cannot be used to supply drinking water, DWASA has become increasingly reliant on abstracting groundwater. As the supply is unable to meet the growing demand, there has been an increase in number of privately owned tube wells. Local authorities outside DWASA area are also dependent on groundwater. Continued abstraction over a long period could lead to contamination of groundwater. RAJUK and DAP have no say in DWASA’s Master Plan. Furthermore, DWASA has made no provisions in its plan to supply the slums areas. 4.3.3 Inadequate Sanitation and Sewage Network At present the sewage network infrastructure being planned by DWASA only takes into account the existing urbanised areas. There are no systematic plans to set up a network in the developing and fringe areas which are marked for future development. In addition, the five new Sewage Treatment Plants that are being proposed as part of DWASA’s Master Plan do not consider additional sewage coming in from developing or fringe areas. As a result, with new areas becoming urbanized, there will be continued discharge of untreated sewage resulting in continued pollution of the surface water resources in and around the city. The DAP preparation process could be used as an opportunity whereby a more comprehensive network covering future growth areas could be designed if DWASA, RAJUK and DAP consultants found a common platform. 4.3.4 Increasing Vulnerability to Floods As far as the role of DAP preparation is concerned, the consultants would concentrate on their respective areas for planning. It is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood retention ponds, which are central to local area plans, would be difficult to undertake, given the compartmentalised planning approach. 34445 –Final – Aug 2007 6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 5 RECOMMENDATIONS In keeping with the main objective of the study, the recommendations have focused on improving the DAP planning process. These have been subsumed under two groups indicating the urgency of action required. 5.1 Immediate Action 5.1.1 Develop DMDP Region Land Use Map and Demarcate and Publish Notification of Ecologically/Environmentally Sensitive Areas Loose planning guidelines and loopholes in the Structure and Urban Plans have allowed the urban encroachment of environmentally sensitive areas which include flood flow zones, wetlands and low-lying areas which act as sink for storm water runoff; natural drainage channels and canals. The local area plans cannot progress unless these areas are clearly identified, demarcated and notified. The proposals and plans on how this demarcation should take place already exist with the responsible agencies and Boards. To overcome this problem, the development of a DMDP Regional Land Use map should be a priority. This map should clearly demarcate eco-sensitive areas and these should be notified through a government gazette as a “no-development zone�. This action is required as a top priority to ensure no more filling of wetlands, destruction of agricultural lands, and the continued haphazard growth of the DMDP Region. 5.1.2 Resolve Conflict Arising From Multiple Functions of RAJUK RAJUK has been very active in promoting and participating in the development of commercial properties like shopping centres and malls. While these developments have been lucrative for both RAJUK and the private developers, they have often overlooked the planning guidelines and have encroached on environmentally sensitive areas. Clearly, there is conflict of interests between RAJUK’s role as a promoter and its role as the principal agency for urban development. To remove this conflict, to introduce sound urban planning and to enhance transparency in the execution of its development functions, its role as a promoter needs to be re-assessed. 5.1.3 Strengthen the DAP Planning Process as there is Too Much at Risk The planning process is incomplete; hence, there is still an opportunity to improve the process and achieve some of the stated objectives. Real value addition to the process will take place if the capacity for environmentally sustainable and socially sensitive planning is enhanced in RAJUK as it is the lead agency. 34445 –Final – Aug 2007 7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Consultants with more appropriate competencies need to be appointed. Plan formulation needs a team with better technical know-how, better understanding of the complexities of urban planning, and which has a critical approach to project execution. The point is to build on the work that has already been completed in the last two years. One of the main problems faced by the present consultants is that they are unable to work with/ have access to, the sectoral agencies. The membership of the Technical Committee, who is charged to provide the link, should be re-assessed for effectiveness and, if necessary, changed. The modus operandi should be made more transparent and information on progress and outcomes disseminated. The leadership of RAJUK needs to be more active in the process. The inability of RAJUK to play a leadership role in the past has led other agencies to take planning initiatives on their own without any coordination with RAJUK. Constitutionally, it has considerable power but has rarely used it for systematic urban management. RAJUK needs to re-direct its energy to facilitate the work of its consultants with sectoral agencies and other local authorities. This will not be easy as the latter are fairly antagonistic to RAJUK. It will therefore, be essential to enable and encourage RAJUK to liase with other agencies and open doors for the DAP process. The issues of slum area development and provision of low income housing are not being addressed either by RAJUK or any of the other sectoral agencies. This means that land allocation and infrastructure planning for these areas might not feature in local area plans. One of the responsibilities of RAJUK is the provision and overview of low income housing. It will be necessary to persuade RAJUK to execute its responsibilities. 5.1.4 Engaging Stakeholders in Urban Planning Throughout this project it has been observed that political economy has played a huge part in the haphazard development of the City of Dhaka. Further, the people with vested interests have been hijacking the process of planning due to lack of transparency. It is recommended that during the reform of the planning process including resolving the conflict of mandate within RAJUK, a transplant process for engaging key stakeholders in the planning of regional areas should be put in place. • As pointed out in the workshop, the “ward committees� at the Pourashavas level have been quite effective at engaging local community in local planning initiatives. Similar initiatives are required at Dhaka and municipal level. 34445 –Final – Aug 2007 8 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • Further, transparency can be achieved if the DMDP region landuse plan with demarcation of ‘no development zones’ is notified and made available to the public. The public can use this information and stop illegal development. Public can approach judiciary if necessary to stop development in the no-development zone. 5.1.5 Bring Other Actors on Board Crucial to the success of formulating local area plans is the participation of local authorities. An entry point for dialogue with these authorities could be programmes for capacity building in environmental planning and regional development. Thought needs to be given to what would be the most efficacious way of doing this. DWASA is one of the biggest players in the provision of urban infrastructure. There is currently very little communication between the two organisations. It will be important to bring DWASA, RAJUK and the DAP team to a common platform. The flood management strategies expectedly have a regional approach. However, there are measures which need to be put in place and actions taken at the local level to achieve overall reduction in vulnerability to flooding. In order to incorporate such measures in DAPs, it will be necessary for RAJUK, LGED and other principal organisations responsible for management of water resources to work together to assist the DAP team. 5.2 Actions in Short/medium term 5.2.1 Develop Strategic Planning Directives for Urban Growth The DAP formulation process will ultimately rely on a strategic planning framework to provide the directives, tools and guidance. While the local area plans will be important working tools, change will occur and new plans will have to be formed. This strategic framework would be a point of reference for local authorities; for DAP consultants; and for future urban growth for the stated period. It is recommended that the new framework be coherent, tight and address the inadequacies of the past and current urban planning approaches and processes. 5.2.2 Funding Procedures for Local Development Projects Development projects, which include urban project, initiated by local governments and local level sectoral agencies, are funded by their ministries or sometimes the Planning Commission on strictly budgetary criteria. There is no mechanism to appraise its environmental impact or the sustainability of such projects. For long-term environmental sustainability, it will be important to 34445 –Final – Aug 2007 9 SENES Consultants Limited Dhaka-Strategic Environmental Assessment address this problem. However, mainstreaming environmental issues will be a pre-requisite to initiating any systemic change. 34445 –Final – Aug 2007 10 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 1.0 INTRODUCTION This section of the report establishes the basis for the SEA study. It also explains the objectives and scope of the study and relates it to the future support for the Government of Bangladesh to ensure sustainable urban development. The methodology adopted for the study and the rationale behind it has also been highlighted. 1.1 RATIONALE FOR THE STRATEGIC ASSESSMENT STUDY Dhaka is one of the 10 mega-cities in the world. Growing at a very fast rate, Dhaka’s urban population is predicted to increase from 11.3 million today to about 21 million by 2015. In view of Dhaka’s rapid development, changing urban landscape and critical environmental and governance challenges, the need for institutional strengthening and requisite city planning is becoming increasingly important. Rapid urbanization has raised two sets of environmental challenges in Dhaka. The first arises from specific urban development investments which treat potential environmental effects as externalities. The second set of broad range of environmental issues stem from pressure on water and land resources and indiscriminate use/misuse of these resources. The complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka needed to be assessed in order to ensure that Dhaka’s development follow a sustainable path. It was felt that a holistic urban planning approach that incorporates environmental and sustainability priorities right from the local level can play a significant role to reverse the degradation of the urban ecosystem of Greater Dhaka. Consequently, a Strategic Environment Assessment (SEA) of the urban development plans that focuses on key institutional planning issues — an “institution-centred� SEA (see Box 1.1) — and one that incorporates the political economy dimension in the assessment was seen by the Government of Bangladesh and RAJUK as adding value to the technically-oriented output of the ongoing local level planning in the form of preparation of Detailed Area Plans (DAPs). The understanding was that an institution-centred SEA would provide a platform for dialogue and interaction between policy makers, planners, stakeholders and civil society at large on environmental priorities and on how and why these priorities would be affected by the implementation of plans and policies (World Bank, 2005) and thus formulating strategic actions which can off set these adversities in the plans. The SEA study was launched on November 1, 2006 and is presently nearing completion. 34445 –Final – Aug 2007 1-1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment BOX 1.1 : INSTITUTION-CENTRED SEA Strategic Environmental Assessment (SEA) describes “analytical and participatory approaches that aim to integrate environmental considerations into policies, plans and programmes and evaluate their inter-linkages with economic and social considerations.� Source: OECD (2006, p: 30) As compared to project level EIA, SEA of a high level strategic decision making such as policies or development plans requires understanding of institutional settings and associated “political economy� factors. In the context of weak institutional and governance frameworks, powerful stakeholders and elites often capture policies and plans for their benefit prevailing over other vulnerable stakeholders. An “institution-centred� SEA is a response for environmental assessment of strategic decision making processes heavily influenced by political and institutional factors. The Bank is currently testing and validating this approach through its pilot program on SEA and Dhaka MDP SEA is a pilot. The following key questions have guided the SEA team in assessing the institutional capacity to manage environmental priorities: • Are existing planning processes adequate for the formulation of environmentally sound spatial and urban development plans? and, • Why these plans do not get fully implemented or why they undergo changes during implementation? There have been several other factors that lead to recognizing the need for conceptualizing a Strategic Environmental Assessment of the Dhaka Metropolitan Development Plans (DMDP). They are described below: • RAJUK1, the Dhaka capital development authority, had commissioned five Detailed Area Plans (DAPs) for preparation and delineation of local level urban plans. However, it was felt that an umbrella environmental framework was required to assist in the planning process, in integrating the environmental and stakeholder concerns and other regional and sectoral plans in the DAPs • The World Bank is developing the Dhaka Integrated Environment and Water Resources Management Project (DIEWRMP) which looks at the opportunity to address urban planning issues incorporating environmental and social dimensions to improve the quality of life of people in Dhaka. However, the program has limited scope to address the overall urban planning issues. • The agencies responsible for delivering the urban services feel that the institutional weaknesses and other political economy constraints were a major impediment in the implementation of plans, thus resulting in adverse impacts on the environment. 1 RAJUK was established in 1987. It is the development authority for Dhaka covering an area of 1528 sq Km. The present jurisdiction of RAJUK includes three districts (Dhaka, Narayanganj and Gazipur), five municipalities (Pourashavas of Savar, Kadamrasul, Narayanganj, Tongand Gazipur) and the Dhaka City Corporation Area. 34445 –Final – Aug 2007 1-2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Therefore, RAJUK, a body setup under the aegis of the Ministry of Housing and Urban Planning, evinced their interest in an institution-centred SEA for the DAPs. 1.2 OBJECTIVES OF THE STUDY The SEA is a decision making tool being used for the first time by the Government of Bangladesh (RAJUK and Ministry of Housing and Urban Planning) to strategize and provide direction to the preparation and implementation of the DAPs. It is also a key policy instrument which will enable the World Bank to conduct a focused policy dialogue, provide recommendations for institutional strengthening and address political economy governance concerns in the context of the implementation of DAPs in the Dhaka Metropolis. The specific objectives of the SEA are to: • recommend policies, institutional arrangements and governance conditions needed for ensuring environmental sustainability of Dhaka’s urban development; • provide overall direction to the DAPs for the formulation of mitigation measures of environmental risks associated with urban development in Dhaka; • provide inputs for the project preparation of the DIEWRMP; and • ensure public participation and dialogue on urban development planning through a process of wide stakeholder consultations, including weaker and vulnerable stakeholders. The principal audience of this SEA is the Government of Bangladesh and RAJUK which will benefit from strategic planning directions emerging from the study and the working out of an overall environmental management framework which takes into account the environmental opportunities and constraints within which the DAPs may be prepared and implemented. Other Government agencies (Department of Environment, Ministry of Housing and Urban Planning), sectoral agencies (DWASA, BWDB, etc.) and local government bodies (Dhaka City Corporation, Pourashavas) will benefit by developing a better appreciation of the environmental challenges and opportunities associated with the implementation of various level urban plans. The SEA was developed as a strategic decision-aiding instrument for planners, decision makers and stakeholders to enable them to take planning decisions more transparently in order to achieve the common objective of better quality life of city residents and reconcile development planning challenges with environmental protection and sustainability. 1.3 APPROACH AND METHODOLOGY OF SEA The methodology for the study was adopted through a dynamic and flexible process in order to focus on the key issues related to urban planning and related considerations that has led to the present environmental degradation in Dhaka. Initially, the SEA study was supposed to focus on 34445 –Final – Aug 2007 1-3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment the DAP planning process, presently underway, and propose an environmental management framework through which sustainability considerations could be built into the plans thereby helping to arrest the environmental degradation of Dhaka. However, as the study progressed, it became evident that there were a number of gaps in the planning framework and in the DAP process that were causing delays in the formulation of the DAPs. Principal reasons for this slow development of the DAP formulation process are: (i) the lack of higher level planning strategy; and (ii) over-ambitious Terms of Reference, poor process design and inadequate allocation of technical resources by RAJUK. These findings were then investigated. After an extensive review of the higher level planning framework and an analysis of the institutions responsible for planning, it became evident that there were additional constraints, such as inadequate transmission of plans, lack of regional focus, institutions working at cross-purposes and sometimes in conflicting roles, which, if not resolved through interventions at the higher level would prevent the mitigation of risks to the urban environment. An examination of the Terms of Reference provided to the DAP consultants and a review of the details of DAP formulation process showed considerable shortcomings in design and implementation which needed to be addressed for satisfactory completion of local area land use plans. Consequently, it was thought prudent to focus the SEA upstream on the higher level planning framework and develop a better understanding of the interactions and potential conflicts between different agencies and institutions responsible for Dhaka’s planning and plan implementation functions. As a result, the study focuses on development of an integrated strategic planning framework in both plans and the institutions responsible for formulating them with the end objective of promoting sustainable urban development in Dhaka. To undertake systematic technical analysis of environmental, planning concerns and political- economic considerations in Dhaka and at the same time incorporate the views of the stakeholders in the development of Dhaka the SEA process comprised of the Analytical Component and Participatory Component. The analytical component looked at measures required to incorporate environmental and planning considerations into the preparation and implementation of the DAP; examined how the DAP formulation process could be improved, and also looked at the need for strategic interventions at the higher planning and institutional levels. The participatory component, adopted through a range of deliberations with stakeholder groups, complemented the consultative process of the DAP organized by RAJUK and the DAP consultants, thereby helping to make the planning process for DAPs more transparent and inclusive. 34445 –Final – Aug 2007 1-4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 1.3.1 Analytical Component The analytical component of the SEA has three areas of investigation. One, aimed to make a thorough analysis of the key environmental problems in the DMDP area based on secondary information available in various published studies and documents and analyze their linkages to policies, legislation and plans. Two, assessed the adequacy of existing urban plans and the planning process at the strategic level in order to make recommendations for improved planning and governance. Three, assessed the efficacy of the on-going DAP formulation process; reviewed the design and technical planning capacity in RAJUK; and identified the areas and needs in RAJUK where interventions for capacity development would be beneficial to overall urban management. Thus, the main outputs of these analyses are: • environmental priorities identified; • transmission mechanisms2 of existing planning and institutional arrangements to environmental priorities assessed; • the effects of DMDP and other sectoral plans on environmental priorities assessed, given the institutional and planning framework in Dhaka and considering the potential reactions of stakeholders; • recommendations for adjustments in the planning and institutional framework for DAP to contribute to sustainable urban development of Dhaka; and • recommendations for improving planning capacity in RAJUK and in local authorities. Environmental issues and stakeholders’ environmental concerns have been assessed by environmental components: landuse and land management; water resources and quality; air and noise quality; and drainage and flooding, and by sectors: water supply, sewage and sanitation, solid waste, drainage and flooding, transport, industry; and spatial planning. In identifying environmental concerns, the perceptions of key stakeholders, particularly the most vulnerable, have been incorporated using the participatory component. Following the identification of environmental priorities, based on stakeholder concerns in Dhaka, these were analyzed on a two-pronged approach. On the one hand, the analytical aspects focused on the ability of the institutional and planning framework to address the environmental concerns as urban development was undertaken taking into account the issues of governance, role of vested interests and complicit relations between government agencies and the private sector. On 2 The transmission mechanism from a policy or plan to a priority issue is the manner in which the confluence of institutional, governance and political economy characteristics of a country impact on the interpretation and implementation of the policy or plan and its associated legal instruments and regulations and, thus, will determine to a large extent the effects of the policy or plan on the priority issue. In a situation of weak governance and institutions, changing policy or formulating plans without addressing the underlying transmission mechanism will usually not have any significant effects on the existing outcome with respect to the priority issue. 34445 –Final – Aug 2007 1-5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment the other hand, the views of the stakeholders on the severity of the environmental degradation and the need to bring transparency into the planning process were taken into account while developing the priorities. Issues that have been considered in the assessment comprises of the following: • intra- and inter-institutional planning coordinating mechanisms; • transparency and stakeholder involvement in the planning and approval process; • institutional capacity to identify sustainable development and environmental priorities; • ability to adapt planning processes to changing priorities; • implementation, monitoring and enforcement capacity; and • gaps in high level plans to address environmental priorities such as surface water pollution and under groundwater depletion to guide the formulation of low level plans. The analysis has been subsequently synthesized into institutional and planning strategies with concrete proposals for the short, medium and long-term to be incorporated in the formulation and implementation of spatial planning of DAPs. These analyses will also assist in the preparation of the DIEWRMP and guide RAJUK in the preparation and implementation of the DAPs. 1.3.2 Participatory Component For the SEA process to be successful, the participation of RAJUK, key urban development agencies, and potentially affected stakeholders was considered to be important. Accordingly, the participation of weak and vulnerable stakeholders in the SEA was ensured in order to take into account their concerns on urban planning and how they relate it to environment protection. A detailed inventory of stakeholders to the SEA process was prepared, the linkages that exist between them were studied and their stake and influence on the planning process understood. The workshops also provided important insight into the shortcomings of the DAP formulation process and indicated serious stakeholder concerns about the overall planning and implementation competencies. This was followed by a series of consultations to understand their concerns about planning and environmental issues pertaining to Dhaka urban area. Significantly, the process provided SEA stakeholders with an open and transparent dialogue platform to discuss spatial and urban development planning issues, understand linkages with environmental degradation that the city has experienced and thereafter set a positive direction to the long-term strategic planning of the city. Details of stakeholder consultations are provided in Appendix 1. 34445 –Final – Aug 2007 1-6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment BOX 1.2: THE SEA CONSULTATION PROCESS Appreciating the need for promoting an inclusive and transparent urban planning process for the city of Dhaka, a focused consultation process was planned out and formed an important component the SEA study. The consultation process of the SEA was conducted simultaneously to the consultation carried out by the DAP consultants. While the DAP consultation focused on consultation with the public to understand and incorporate their requirements in the plan preparation process, the SEA consultations focused more on the understanding strategic level issues and considerations like political economy factors that were preventing the preparation or successful implementation of holistic plans, thereby resulting in adverse impacts on the urban environment . The consultations thus focused mainly on higher level i.e institutional/organized stakeholders. However to understand the concerns and viewpoints of the public, especially the vulnerable groups (slum dwellers, rickshaw pullers etc) some group consultations were conducted during the course of the study. Individual Consultations: The individual consultations were conducted with all probable stakeholders to understand their sphere of influence and the knowledge and skill set which they can bring into the SEA Process. Initial Stakeholder Workshop: The initial stakeholder workshop was organized for informing the stakeholders of the objectives of this study and to understand the perception of the citizens about the environmental concerns facing Dhaka. Sensitization Meeting: This meeting was intended to sensitize the members of the Technical Management Committee overseeing the DAP preparation about the SEA. One-on-One Meetings: One–on-One Meetings were organized at the initiation of the assessment of environmental concerns to understand the need and aspiration of the stakeholders from the DAP and SEA process. Sectoral Stakeholder Workshop: The sectoral stakeholder workshop was organized to identify some key action areas and policy level initiatives for their implementation for various urban development sectors. DAP Area Meetings: The results of the sector-wise workshop were disseminated through these meetings to be held in each of the areas where a DAP is being formulated. Stakeholder Workshop: This workshop was held after the completion of the Draft Final Report to broadly discuss the possible recommendations of the SEA. It was convened with participation by the sectoral and DAP area wise stakeholders. The workshop's main result was to draw up a consensus on the recommendations to be incorporated in the SEA. Final Consultation Workshop: This final consultation workshop has been planned for mobilizing the support of the decision makers and further disseminating the recommendations of the SEA among stakeholders and taking feedback about the findings and recommendations of the SEA study before finalizing the SEA report. 1.4 OUTPUT The deliverable from this activity is twofold. The SEA report informs RAJUK and appropriate government agencies with strategic issues and guidelines for the preparation and implementation of DAPs. Secondly, it provides a tool for decision making to Dhaka’s urban development agencies led by RAJUK to discuss and negotiate the institutional and governance requirements for sustainable urban planning. The study will provide specific recommendations for 34445 –Final – Aug 2007 1-7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment institutional and governance strengthening for environmental sustainability of urban development of Dhaka Metropolitan Area. The Technical Management Committee (TMC) set up by the Government of Bangladesh (GoB) for supervising and managing the DAP preparation has been engaged in reviewing the results of this study and would be tasked with implementing policies to address SEA recommendations and monitoring of the implementation of these recommendations. The SEA will also inform the preparation of a Policy Note from the World bank to the GOB on strategic environmental planning in Dhaka. 1.5 REPORT STRUCTURE The remainder of the report is structured as follows: Chapter 2 : Situation Analysis of Dhaka’s Environment Chapter 3 : Urban Planning in Dhaka Chapter 4 : Risk and Opportunities of Planning Framework Chapter 5 : Recommendations from the SEA Study Appendix 1 : Public Consultation in SEA[iflc1] 34445 –Final – Aug 2007 1-8 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 2.0 SITUATION ANALYSIS OF DHAKA’S ENVIRONMENT This section presents the existing environmental situation of the Dhaka urban area. It describes the stressors on environmental resources, their components and its causes. The effect on the various environmental components have been clustered into four subsections, viz. land-use and land management, water resources and quality, air and noise quality, flooding and drainage. The analysis of the present environmental condition would include the views and concerns expressed by the stakeholders including vulnerable groups, and describe how they are impacted as a result of unmanaged urbanization. The section concludes with a summary of prioritized environmental issues based on technical analysis and the perspective of stakeholders gathered through several rounds of public consultations. 2.1 URBANIZATION IN DHAKA Dhaka, the capital city of Bangladesh, has emerged as the main economic nerve centre contributing about one-fifth of the nation’s total GDP. However, with no alternative economic growth centre coming up, the expansion of the city in the last few decades has been very rapid and has been marked by huge influx of population from rural areas of the country. This rapid development, combined with absence of any systematic urban management, primarily during the last two decades has led to a shortfall in urban services infrastructure thereby resulting in severe environmental degradation and strain on resources. In addition, the nature of economic growth and urbanization is skewed resulting in about 37%3 of the city’s population living below the poverty line and 3.4 million people are estimated to be living in slum areas. Furthermore, at present, environmental constraints to growth in the capital city constitute a national priority as pointed out by the Country Environmental Analysis4. The DMDP area, covering a total of 1528 km2, lies in the delta of three major river systems of the Indian sub-continent i.e., Jamuna, Padma and Meghna. The urbanized part of Dhaka and the immediate peri-urban areas mainly occupy the flood plains of a number of smaller rivers which are tributaries of these two (Padma and Meghna) larger rivers and form an intricate system of rivers and natural drainage channels (the watershed formed by Tongi and Turag on the northern side, Sitalakhya and Balu in the eastern side and Buriganga on the western and southern side5). As a result, most of the land within the pear shaped delta forming the DMDP lies about 2-6 m above MSL (Mean Sea Level) except for the Mirpur highlands located along the central axis, where the elevations rise to about 13m. The overall slope of the area and resultantly, the flow of these smaller rivers are from north, north-west to south, south east side. 3 Centre for Urban Studies (CUS) : Slum Studies, 2005 4 Bangladesh Country Environmental Analysis, World Bank, September 2006. 5 However, with rapid urbanization, the Metropolitan Planning Area now encompasses areas beyond the physical boundaries set by the rivers. The areas on the other banks of these rivers, including the municipal areas, are charted for urbanization in the planning period extending till 2015. 34445 –Final – Aug 2007 2-1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The present city of Dhaka has grown from a small settlement of nearly 0.2 million people, spread over an area of approximately 1 km2 during the pre-Moghul period (1600s), on the natural levees of the River Buriganga and Dholai Khal. Presently it has transformed itself into a city having a population of about 12 million. The annual average population growth rate for Dhaka has been as high as 6.9%6 during the period 1975 to 2000 (compared with an annual average of 2.1% for Bangladesh) and subsequently (2001 onwards) the annual growth rate is in the range of 4%7. Experiencing high rate of development and rapid urbanisation, the city is poised to grow into the fourth largest urban agglomeration in the world with a projected population of 21.1 million by 20158. The spatial dimension of growth of Dhaka in the course of the last four centuries (1600-2000) is presented in the figure below. FIGURE 2.1: SPATIAL GROWTH OF THE DHAKA9 Moghul Period : 10 km2 British Period : 22 km2 Pakistan Period : 85 km2 Bangladesh Period (DMDP): 1528 km2 Administratively, the spatial boundary of the DMDP incorporates 3 Zillas10 (Dhaka, parts of Narayanganj and Ghazipur), 5 Pourashavas (Savar, Tongi, Ghazipur, Narayanganj & Kadam 6 World Urbanization Prospects: 1999 Revision, UN Report. 7 Bangladesh Census (Year) 8 DMDP Structure Plan 9 DWASA Presentation 10 Bangladesh is divided into six administrative divisions, each named after their respective divisional headquarters: Barisal, Chittagong, Dhaka, Khulna, Rajshahi, and Sylhet. Divisions are subdivided into districts (zila). There are 64 districts in Bangladesh, each further subdivided into upazila (subdistricts) or thana ("police stations"). The area within each police station, except for those in metropolitan areas, is divided into several unions, with each union consisting of multiple villages. In the metropolitan areas, police stations are divided into wards, which are further divided into mahallas. There are no elected officials at the divisional, district or upazila levels, and the administration is composed only of government officials. 34445 –Final – Aug 2007 2-2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Rasul) and the Dhaka City Corporation area which mainly covers the older parts of the city. A map of the DMDP area delineating the administrative boundaries is presented in Figure 2.2 below. As can be observed, large areas in the fringes of the city covering an area of about 1000 sq kms fall within the administrative jurisdiction of the Union Porishods and are still largely un- urbanised. For the purposes of this SEA study, the urban development of Dhaka has been spatially clustered into three distinct zones11 as described below: • Developed areas: areas in the core of the city, mainly comprising of older parts of Dhaka, where the population densities are very high and has reached near saturation. However, certain pockets within these densely urbanised parts of the city are undergoing redevelopment. • Developing Areas: area adjoining the core areas of the city falling under the administrative jurisdiction of DCC & Pourashavas which has developed as suburban areas and still has some space available for further urbanisation. • Fringe Areas: areas in the fringe of the DMDP area falling under the administrative jurisdiction of the Union Porishads which consist of primarily low lying lands (flood plains) with agricultural landuse. These areas are charted out for urbanisation in future. The spatial extent of these three zones and the distribution of population in each of these three areas are presented in the Table 2.1 and Figures 2.2 and 2.3 below.10,11 11 Developed Area: Old Dhaka city area covering about 186.12 sq. km area Developing Areas: Extended areas in the DCC (part of the 6 Thanas: Demra, Sabujbagh, Uttara, Kamrangirchar, Badda, Shyampur) and Paurashavas (Naraynganj, Kadamrasul, Savar, Tongi and Gazipur) covering an area 309.96 sq. km Fringe Area: Rural Areas under Union Parishad (part of Demra Thana, Sabujganj Thana, Uttara Thana, Badda Thana, Shyampur Thana, Kamrangircahr Thana, Savar Upazila, Keraniganj Upazila, Gazipur Sadar Upazila, Rupganj Upazila, Bandar Upazila and Narayanganj Sadar Upajila) covering an area 1032.96 sq. km. 34445 –Final – Aug 2007 2-3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment TABLE - 2.1: POPULATION DISTRIBUTION AND DENSITIES IN 3 ZONES OF DHAKA Density Density 2001 2006 Area (sq Population (Pop/sq Population12 (Pop/sq kms) 2001 kms) 2006 kms) Developed Area 186 5333571 28657 6439341 34598 Developing Area 310 1551891 5007 1873633 6045 Fringe Area 1032 3190930 3089 3852482 3730 Total 1528 10076392 6590 12165456 7956 FIGURE 2.2: ADMINSTRATIVE MAP OF THE DMDP REGION 12 Population Data : 2001 (Source : Bangladesh Bureau of Statistics, 2001); 2006 : Estimated on Projected Growth rate of 4.15% per annum as per BBS projected Growth Rate 34445 –Final – Aug 2007 2-4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE – 2.3 : SPATIAL DISPOSITION OF DEVELOPMENT ZONES WITHIN DMDP 34445 –Final – Aug 2007 2-5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 2.2 LAND-USE AND LAND MANAGEMENT Like other developing countries in South Asia the urban population of Bangladesh has grown at a much faster rate than the rural population. As a result, in spite of the overall low level of urbanization in the country, there are considerable spatial imbalances, especially when seen in context of the rapid growth of Dhaka. Dhaka as the country’s capital city is home to about 34%13 of the Bangladesh’s total urban population. This is primarily due to its central location and easy accessibility from different parts of the country, presence of administration and government and also being the industrial, trading and commercial hub of the country. The location factors coupled with its high economic potential as also the lack of any alternate urban agglomeration with similar opportunities has resulted in the influx of a large number of people from rural areas of the country into Dhaka. The problem of urban influx is accentuated by extreme rural poverty, uncertainties of agricultural production, landlessness and high rural-urban wage differentials. The rate of such influx is estimated to be about 0.3 – 0.4 million people per year14. To accommodate the increasing pressure of population mainly due to in-migration, the city area has grown spatially over time from about 85 km2 in 1951 (Master Plan) to 1528 km2 in 1995 (DMDP). However, because of inadequate planning to manage urban landuse and its development, most of the urban growth in the last decade has taken place in an unplanned and haphazard manner. Resultantly, existing urban areas have witnessed high levels of population densification with intensification of slums and vertical growth replacing horizontal expansion even though the urban infrastructure required to support such growth has not been upgraded. On the other hand, large parts of fringe areas designated for growth have not been developed for planned urbanisation. This is accentuated by skewed development of the fringe areas being developed in an unplanned manner after filling up of low lying flood plain and agricultural areas by powerful realtor groups using their influence on the government agencies, including RAJUK. Most of these new developments would only be catering to higher-middle and high income groups in the city, thereby reducing the possibility of distributing the population throughout the DMDP area and forcing the intensification of slums as poorer sections of society have no place to go. The various aspects of land-use management and its impacts on various environmental components are briefly discussed in the subsequent sections. 2.2.1 Housing, Slums and Open Spaces The lack of proper housing infrastructure for various sections of the urban society is a crucial problem in Dhaka and assumes significance from the environmental point of view. With a rapid influx of population from the rural areas into Dhaka, the ability of the city to provide proper 13 Centre for Urban Studies (CUS) : Slum Studies, 2005 14 Rate of influx – Bangladesh Bureau of Statistics. 34445 –Final – Aug 2007 2-6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment housing infrastructure to the migrant workers is under severe stress. Even though the Strategic Plan requires the provision of housing for the poor by RAJUK, it was not lucrative for either the government agency or the private sector to do so; hence many parts of the city has witnessed intensification of slums. This increase in the number of slums in the developed parts of the city and disproportionate distribution of residential land is reflected in the fact that 70% of the total urban population live in only 20% of the residential land while the remaining 30% live in 80% of the residential land in Dhaka15. The number of slums in Dhaka has increased from 1125 in 1998 to 4,966 slum clusters in 2005 (CUS 2006). These slums are very densely populated with and average of 2,20,246 [iflc2]16 people per km2 . Spatial analysis of the survey16 shows slums are located all over the DCC17 area, with Zone 1 having the highest proportion (11% slum area), and Zones 2 and 10 having the lowest with less than 1% slum area. Eighty percent (80%) of such slums are housed on privately owned land and many of them are susceptible to flooding. The survey also indicates that a third of the population in DCC area live below the poverty line in these slums and do not have access to basic urban and civic services like drinking water, sanitation, education and health. It is pertinent to add that the slums themselves led to further environmental degradation through discharge of untreated household waste and sewage into the surrounding water bodies. The developed parts of Dhaka and some newly developed areas has witnessed a spurt in demand for apartments mainly targeted for high income groups who comprise a small percentage of the urban population. These apartments are mostly constructed by private realtors who often have high influence within the government agencies and as a result often tend to flout development regulations like the Building Construction Rules. On the other side, the demand for such apartments among high income group people was fuelled by government policy on money laundering which allows undeclared income to be invested in real estate without disclosing the source of income. BOX 2.1: SLUMS IN DHAKA – A GLIMPSE The common slum dwellers of Dhaka mostly comprise migrants from rural areas in Bangladesh to Dhaka in search of a better livelihood and quality of life. Because of the high land prices and the unavailability of housing infrastructure for low income groups, the migrants take shelter in one of the slums within Dhaka, preferably close to their place of work. Most of the slum dwellers work as readymade garment industry workers, rickshaw pullers, household helps, ragpickers, etc., and make an important contribution to Dhaka’s economic growth by contributing labour to 15 Akash & Singha, 2003 16 LGED Slum Survey, 2004-2005 17 The DCC area has been divided into 10 zones Zone 1 –Zone 5 in old Dhaka and Zone 10 is Uttara township newly developed by RAJUK. 34445 –Final – Aug 2007 2-7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment BOX 2.1: SLUMS IN DHAKA – A GLIMPSE business or by providing necessary urban services. The income level of slum dwellers varies between Tk 1200- 3500 per month (for men) and Tk 300-1500 (for women).[iflc3] Even though approximately 30% of the Dhaka’s population lives in slums, access to urban services in squatter settlements are poor. Amongst the poorest people in the slums, only 9% of households have a sewer line, and 27% obtain water through piped supply (compared with 83% of the wealthiest). Spatial mapping shows that only 43 of the 1925 identified slums are within 100 meters of a public toilet. Only 7% of slums have a public health clinic and 26% have a government school. Many of the slums have developed gradually mostly in marginal areas of the city, and in many cases in low lying areas adjoining rivers and drainage khals or by filling up wetlands. Therefore, they are vulnerable to flooding and associated flood risks. Additionally, some of the slums are considered to be illegal and often evicted by government agencies from time to time without any proper rehabilitation. Consultation with the residents of the Karail Basti slums revealed that a parallel informal system for providing basic urban services to slum dwellers has developed. Such services are mostly provided by local toughs who are called mastaans. As a result, slum dwellers, in spite of being economically disadvantaged, often end up paying higher prices in terms of rent, and other services like drinking water supply and electricity. These highly dense slum settlements often have a degrading effect on the quality of adjacent water bodies and the cleanliness of surrounding areas. The slum dwellers area also more prone to various vector borne diseases because of the lack of good quality drinking water and proper sanitation facilities. As a direct effect of the unplanned urbanisation and lack of development control, Dhaka has very little open space in form of park18, gardens etc, (approximately 310 hectares)19. Of the total land area, the developed area (primarily under DCC jurisdiction) has only 14.5% open space when ideally such large cities should approximately have around 25% open space[iflc4]. Importantly, some of the areas demarcated for parks have been illegally occupied by encroachers having political influence to set up temporary markets, bus stops, slums, etc. This in spite of the fact that 18 Some other important open spaces in the city are Osmani Uddayan, Bahadur Shah Park, Botanical Garden, Suhrawardi Uddyan, Ramna Park, etc 19 Aboriculture Department, Ministry of Housing and Public Works 34445 –Final – Aug 2007 2-8 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Bangladesh Open Spaces and Wetland Protection Act 2000 does not allow parks open spaces and wetland to be converted for any other uses. 2.2.2 Industries Two important drivers of environmental degradation in the Dhaka watershed have been the export–oriented economic growth, which has often been associated with use of inappropriate technology and the lack of enforcement of environmental standards by the Department of Environment. The focus of discussion here is the resultant industrial pollution. There are two points of relevance here. One is the rapid growth in the number of industries in the last decade; and two, the growth and dispersal of pollution intensive sub-sectors, making management of industrial pollution difficult. Growth of Industries: BKH20 estimated that in 1994 there were 221 industrial units in the six clusters in Dhaka. DIEWRMP noted that in 1998 there were 2,200 industrial units in and around Greater Dhaka. IWM (2007) notes that there are now 3,000 units in Dhaka and over 7,000 in the watershed area. There are nearly 60 different types of industry but the base is dominated (60%) by the garment industry. It subsumes a number of processing activities, like dying, washing and printing of fibre and fabric, which are carried out in factories of different sizes. Other medium and small-scale industries include: jute mills, tanneries; metal, cement, rubber, chemicals processing units; pharmaceuticals, petroleum refining, distillery, plastics and brick manufacturing. These industrial units have come up alongside or adjacent to residential houses, shopping centers, schools, play grounds, parks and hospitals. The wastes, emissions and noise from these industries have the potential to affect the health of the residents in such areas. Pollution intensive sub-sectors and their dispersal: Prior to independence in 1971, all industrial activity in Dhaka was restricted to Tongi and Fatulla industrial estates. In 1995 the Dhaka Structure Plan noted that these industrial zones where under-utilised as they were poorly maintained and managed by BSCIC and did not provide the services required. With a change of policy, it allowed ‘footloose’ industries to locate outside the designated areas. Given the rising cost of land, industry was quick to disperse throughout the watershed. Review of several studies (Dasgupta and Marr: 2007) showed that some of the most pollution-intensive industrial activities are dyeing, printing and washing of fabrics; chemical and oil processing. A predominant number of industries discharge untreated waste, thus externalizing the cost of cleaning up. It is useful to 20 BKH Consulting Engineers et al (2001) Techno-economic Study for Setting up a Common Effluent Treatment Plant in the Tannery Cluster of Hazariabagh. UNIDO and Government of Bangladesh. 34445 –Final – Aug 2007 2-9 SENES Consultants Limited Dhaka-Strategic Environmental Assessment note that the garment and apparel industry shifted to Asia as environmental regulations in the west made it very costly to carry out certain stages of garment production. The end result is that industry accounts for 60% of the pollutant load in the watershed. This pollutant load is constituted of organic and inorganic waste, including heavy metals. The gravity of the problem lies in the fact that surface water is too polluted to be treated to potable standards. This has meant increasing reliance on groundwater and high abstraction rates by DWASA and the private housing developments (these are discussed in detail in section 2.3). Furthermore, IWM (2007) have noted that geography of the watershed facilitates the interaction between polluted surface water and groundwater, thereby increasing the threat of groundwater contamination. All major cities have areas designated for manufacturing and processing industries. The implication here is the need for DAP planners and consultants to understand the issues behind delineating industrial zones. There are two sets of problem that have to be tackled. One, is how to control and manage the industrial clusters which have already developed; and two, how to spatially manage future industrial growth. Discussion with industry is fundamental to developing ideas which would work and would not impose additional costs on industry. BOX 2.2: LOCATION OF INDUSTRIES IN DHAKA Traditionally, the industries were located in old Dhaka Area e.g. Postagola, Laxmibazar, Imamganj, Gandaria Farashganj, Faridbad, Shankaribazar, Nawabganj, Amingola, Tantibazar, Patuatuly, Hazaribagh and Tejgaon areas. Recently, industrial units have also developed in Narayanganj, Fatulla, Panchabatee, Kachpur, Rupashi, Tarabo, Hotabo, Sonargaon, Araihazar, Rupganj on the eastern and southern side of the DMDP area and along the Dhaka-Chittagong Highway. In addition to these, a number of designated industrial areas have also come up e.g. the Tejgaon Industrial Area promoted by the erstwhile DIT (Dhaka Improvement Trust) and the Savar EPZ promoted by DEPZ Authority for small and medium industries. The industrial units operating from these areas include dyeing/printing factories, edible oil factories, paper and pulp mills, chemical industries, jute mills, textile mills, printing, garment manufacturing, engineering, moldings, welding, repairing, chemicals, packaging, used lubricant processing, washing, water bottling and many others. 2.2.3 Roads & Transportation As in many major cities, transportation corridors play an important role in defining directions of growth of a city. In Dhaka, most of the major transportation corridors have developed in a north- south direction. This is primarily because of the growth of the city along the central highland 34445 –Final – Aug 2007 2-10 SENES Consultants Limited Dhaka-Strategic Environmental Assessment axis. However, at present to create space for urbanization, the low-lying areas in the eastern and western sides are also planned to undergo urbanisation. The transportation system in Dhaka is predominantly road based. However, the roads of Dhaka still occupy only 8%21 of the total area, even after the implementation of the Dhaka Urban Transport Project (DUTP) and the Dhaka Integrated Transport Project (DITP), whereas ideally at least 25% of the total city area is required as road space to facilitate a smooth transport system in a modern city. Further, the growth of road space has been slower than growth of vehicles (80% in the last decade). In addition, the mixing of different modes of transport i.e. both motorized and non-motorized transport (rickshaws 3,00,00022 in number accounting for 15.2% of the traffic and occupying 73% of the road space) has been cited as a major reason for congestion in the city. The congestion is further aggravated by incidences of on-street parking in absence of adequate off-road parking spaces in the city. The problem is acute in old high-density area of the city like Dhanmondi and the Central Business Districts causing severe congestion in these areas. It has also been reported that the tendency to construct multi-storey buildings along the major transport corridors without adequate arrangements for parking of construction vehicles, storage of constructions materials etc. in contravention to the building rules23, has resulted in aggravating congestions on certain important corridors. In addition to the road-based transportation, there are two other major transport systems operating in the city. A railway line operates in the north south direction of the city. Bangladesh Railway operates standard gauge passenger trains on this route but the frequency of operation of this mass rapid transport system is relatively low. The BWTA operates ferry service to transport passengers from areas south of Dhaka till Sadar Ghat but this system has no extensions in the north. The potential of these two modes of transport have not been fully utilized. Further the inter-linkages between the three modes of transport, Railway, Roadways and Waterways is poor. As a result the passenger dispersal system from the railways and waterways is dismal and results in localized problems. This also contributes to these systems not being used as a preferred mode of transport in Dhaka. The main points emerging from this analysis are the lack of collaboration and co-ordination between different transport agencies and an absence of an integrated transport planning approach.[iflc5] 21 National Encyclopedia of Bangladesh (Banglapedia), 22 Officially records with DCC indicate the total number of rickshaws in Dhaka to be around only 88,000 23 The Building Construction Rules 1996, and The Building Construction Rules 2006 34445 –Final – Aug 2007 2-11 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 2.2.4 Solid Waste It is estimated that the Dhaka city area generates approximately 350024 tonnes/day of residential, commercial and institutional Municipal Solid Waste (MSW). With rapid urbanization, increasing per capita incomes and changing lifestyles, the rate of increase of MSW generation is also likely to increase. At present, biodegradable organic matter constitute approximately 60% of the waste. The city corporation and Pourashavas are responsible for providing urban services related to solid waste in their respective areas. DCC has established a Solid Waste Management Division to manage the solid waste but this has still to affect its solid waste management strategy. The Pourashavas are still dependant on a conservancy-based approach25. There has been very little effort both at the city as well as in Pourashavas to minimize (recycle/ reuse) the waste. It was reported that about 50% of the waste being collected and disposed from the city, i.e. approximately 1400 tonnes/ day of waste are delivered to dumping sites from the city. Till recently, DCC had one authorized dumping site at Matuial (3 km south-east of the DCC central office) and remaining were dumped on private lands in Berri Bund and Uttara. DCC has recently acquired a new site at Amin Bazar and is in the process of converting the open dumping at Matuial into a sanitary landfill. The principal dump site Matuial is more than 25 km from many parts of the city. Even though the “Clean Dhaka Master Plan� recommended upgrading of the Matuial site and acquisition of a new disposal sites at Amin Bazar, the siting of these landfills remains an issue of concern even though these sites have been cleared by both DOE & RAJUK. The DMDP Urban Area Plan questions the feasibility of the selected sites considering the spatial growth projections suggested in the Structure Plan. Thus scarcity of land is leading to selection of landfill sites for waste disposal which are environmentally unfeasible. Further, there is no comprehensive system for collection and management of bio-medical waste and industrial waste. Most of these special wastes are either disposed into the public waste bins or are disposed off in open areas and in watercourses. The JICA (?) study26 indicates that industrial wastes are not categorized as hazardous or non-hazardous and are disposed at the Matuial dumpsite together with ordinary municipal waste. The environmental concerns associated with landuse and land management are: 24 JICA Clean Dhaka Master Plan Study assuming population of 6.3 million and waste generated is 0.56 kg/capita/day.(2004) 25 The conservancy based approach primarily depends on collection of solid waste from secondary location and disposal at a some other location. 26 The Study on the Solid Waste Management in Dhaka City, JICA, 2005. 34445 –Final – Aug 2007 2-12 SENES Consultants Limited Dhaka-Strategic Environmental Assessment BOX 2.3: LANDUSE AND LAND MANAGEMENT ENVIRONMENTAL CONCERNS • Incompatible development patterns leading to environmental stresses • High urban densification in certain areas resulting in strain on urban services • Intensification of slums resulting in environmental & health risks • Selection of environmentally unsound solid waste dumping sites due to non availability of suitable land parcels • Low ecological diversity as a result of degraded habitats 2.3 WATER RESOURCES AND QUALITY 2.3.1 Water Resources Even though Dhaka is surrounded by rivers on all sides and fall within the watershed of three major rivers of the Indian subcontinent, the water supply of the city is predominantly based on groundwater resources for reasons already explained in section 2.2.2. The demand for potable water in the city is estimated to be over 1.5 billion litres per day (BLD) of which about 20% is supplied from the Sitalakhya river via two water treatment plants located at Chandighat and Saidabad. The rest of the water is supplied by 453 borewells operated by DWASA for supplying water to the city. In addition, there are also a number of privately established borewells which supply water to numerous apartments distributed throughout the city and it is estimated that approximately about 1300 privately owned deep tube wells operate within the city. In the fringe areas, water supply is from bore wells operated by Pourashavas, private operators and industries. Thus, cumulatively more than 80% of the total water requirement in the DMDP area is dependent on groundwater. The over dependence on groundwater for supply results partially from the lack of infrastructure to treat and distribute surface water, but essentially the poor quality of surface water in the Dhaka watershed. Such intensive use of groundwater throughout the Dhaka watershed has resulted in depletion of the groundwater levels by approximately 2-3 m/year27. In addition to the concerns of the rapidly depleting water table established through a number of studies28, the stakeholders in Dhaka have expressed serious apprehensions about the quality of water supplied from both surface and groundwater sources. Recent reports indicate that 27 Dhaka State of Environment Report 2005 28 Industrial Environmental Compliance & Pollution Control in Greater Dhaka –Phase I, IWM March 2007 34445 –Final – Aug 2007 2-13 SENES Consultants Limited Dhaka-Strategic Environmental Assessment groundwater has been found to be contaminated by chemicals (mainly heavy metals) and dissolved solids, in the upper aquifers near Hazaribagh and other industrial clusters strongly indicating contamination from industrial sources. In addition, high levels of organics in influent water at the intake of the Saidabad treatment plant affects the plants capability to treat water to levels which adhere to drinking water standards29. The water supply to the slums and poorer sections of the society is limited with only about 27% having access to piped water supply, mostly through standposts. Consequently, large sections of slum dwellers are forced to buy water from local tube well owners either at high prices30 or use polluted surface water for their daily needs resulting in serious health concerns. 2.3.2 Water Pollution The rivers and streams flowing adjacent to Dhaka are highly polluted. The surface water quality in the rivers and other surface water bodies e.g. khals and ponds, etc have very high BOD31, COD and e-coli content indicating discharge of untreated industrial effluents and sewage in these water bodies (khals, ponds). As a result of the high pollution levels, many sections of the rivers and canals in the city and surrounding areas are biologically dead during the dry season, and the water available is unfit for any human use, or even for irrigation. As a result, surface water pollution from discharge of untreated effluents impacts a considerable section of Dhaka’s residents either in terms of higher health care costs associated with water borne disease or because of lost productivity. It is estimated that loss of amenity associated with contaminated surface water amounts to about 0.5% of the region’s GDP32. One of the prime reasons for high organic pollution of the rivers and water bodies is the poor state of sewerage and sanitation system of the Dhaka urban area. Presently, the underground sewer network covers only 30% of the area of the existing urban areas of the city, and 20% of the population residing in it. For the remaining areas, especially areas lying in the developing areas, which are witnessing rapid development recently, are mostly serviced by localized sanitation facilities like septic tanks and soak pits. During consultations, it was reported by stakeholders that in number of cases the sanitation facilities like septic tanks and soak pits are poorly or inadequately designed33. The sanitation facilities in slum are even poorer. A large amount of domestic and human waste is held in situ these areas, some of which gets washed into the water 29 Country Environmental Analysis, 2006, WB 30 Slum dwellers reported paying as much as Tk. 2 per bucket of water, several times the price paid by those who had legal connections (the official price charged to consumers in Dhaka was Tk. 4.33 per 1,000 litres). 31 IWM study on Industrial Pollution (2007) indicates 330,000 kg of BOD5 are discharged into the river systems in the Dhaka watershed everyday. 32 Bangladesh Country Environment Analysis - Para 89, page 29. 33 The supernatant waste from these units is often drained into adjacent storm-water channels and drains. In addition, for these facilities, there is no systematic way of collection of sludge and often the same is drained into nearby water bodies polluting them. 34445 –Final – Aug 2007 2-14 SENES Consultants Limited Dhaka-Strategic Environmental Assessment bodies during the wet season. Access and adequacy to sanitation facilities have been a serious concern expressed by the vulnerable stakeholders. Only a small percentage of sewage is collected by the underground sewer network, mostly from the southern parts of the city and is transported to the Pagla Treatment Plant. The Pagla Sewage treatment plant runs on non-conventional treatment technology of facultative ponds and treatment in such ponds is aided by “duckweeds�. The plant has an installed capacity of 120 MLD and presently operates at a third of its capacity. As the existing sewer system is blocked and/or leaking, only a small portion of the collected sewage is treated in the Pagla Sewage Treatment Plant and the rest either leaks into or is discharged without treatment into the surface water system. There are 19 primary discharge points to the rivers and at least 41 secondary discharge points within the city. Many of these discharge points also drain mixed effluent including untreated wastes from industrial units like tanneries, dying and bleaching units. The efficiency of treatment in this particular system is not very high and the BOD load in effluent from the plant has been recorded to be as high as 200 mg/lit in previous studies undertaken34. It is understood that being a biological treatment system, the efficiency of treatment plant is hindered by toxic wastes which flow into the system from industrial units, especially tanneries in the Hazaribagh area, where effluents are discharged without treatment into the sewer system. BOX 2.5: WATER POLLUTION FROM INDUSTRIES IN DHAKA WATERSHED[iflc6] Water bodies in Dhaka are polluted by a number of industry sectors, some of which are in the unorganized[iflc7] sector. The main sectors discharging untreated effluents into water bodies, rivers and streams are tanneries, dyeing and bleaching units. The discharged effluents consist of high organic loads or toxic chemical constituents which are used for tanning, dyeing and bleaching. There are 270 registered tanneries in Bangladesh with 90%of them being located at Hazaribag on about 25 hectares of land. Most of these are non- or semi-mechanized units using old processing methods and produce effluents having high organic and toxic loads. The dyeing and bleaching units are distributed throughout the present urban area, with concentrations in Narayangang, Tongi and Savar. Some of the industries also drain effluents directly into agricultural fields thereby polluting them. The main industrial clusters and effluent hotspots of the rivers are: Buriganga River - tanneries at Hazaribagh, Sayampur and Fatullah industrial clusters in Dhaka South and Narayanganj; Balu River - Tejgaon Industrial Area; Tongi Khal - Tongi Industrial Area, Sitalakhya River - currently developing heavy industry strip. 34 Study conducted by JICA in November, 1997. 34445 –Final – Aug 2007 2-15 SENES Consultants Limited Dhaka-Strategic Environmental Assessment In addition to sewage and untreated industrial effluents, inefficient solid waste management system resulting in open dumping of municipal and industrial wastes also contributes to pollution of surface water bodies and shallow groundwater aquifers. The concerns influencing the water quality and resources of can thus be summarized as: BOX 2.6: WATER QUALITY ENVIRONMENTAL CONCERNS • Depletion of groundwater due to overdependence on groundwater resources • Surface water pollution due to discharge of untreated sewage and effluent • Contamination of land and shallow aquifers due to open dumping of municipal & industrial solid waste 2.4 AIR AND NOISE QUALITY Like other major metropolises in developing countries, deterioration of air quality in the Dhaka area is a key environmental concern. Though considerable policy level initiatives were undertaken during the last decade to improve the air quality of Dhaka, the air quality improvements achieved through initiatives like the baby-taxi ban are being rapidly offset with increasing urbanization. The results from continuous monitoring of the air quality obtained from the AQMP project indicate that PM10 and PM2.5 levels are considerably above standards, especially in dry season, and they also show an increasing trend. Studies35 have revealed that while motor vehicles, re-suspended dust, biomass burning (in brick kilns and by low income groups as fuels), and fugitive emissions are major contributors to PM10, transport is the major source of PM2.5. Unplanned development and siting of air polluting industries in areas adjoining the residential area and location of the brick kilns adjacent to the DMDP area have aggravated the situation. Contribution of air pollution FIGURE 2.4: AIR POLLUTION from different sectors is summarised FROM VEHICLES IN DHAKA below: TRANSPORT: Analysis of the emission inventory presented in figure above indicate that the diesel vehicles contribute approximately 80% of the air pollution from mobile sources. The ageing fleet of diesel vehicles along with the high sulphur content in diesel is considered as prime reasons for such high levels of air pollution. CNG Taxis and 3-wheelers also contribute to 35 Begum et al 2005below 34445 –Final – Aug 2007 2-16 SENES Consultants Limited Dhaka-Strategic Environmental Assessment the NOx load. Poor maintenance coupled with poor fuel quality, traffic congestion, poor transport infrastructure planning and lack of coordination between the agencies involved in planning and executing of land use and transport planning add to the vehicular air pollution in the city. SOLID WASTE: The practice of burning of a part of the municipal solid waste collected contributes to air pollution. The existing municipal solid waste landfill sites (both temporary and permanent) are sometimes put on fire and emit fumes and gases contributing to air pollution including methane and non-methane organic compounds, for example benzene, etc. BRICK KILNS: Large number of brick kilns has been setup in the fringe areas of the city, especially in the northern parts and all along Tongi and Turag river banks. The significantly high levels of air pollution from these kilns has substantial impacts on the air quality especially during dry winter months INDUSTRIES: Industries in Tejgaon Industrial Area are a major source of industrial air pollution. Also, the Tanneries and hide dealers in Hazaribagh area, which is a predominantly residential area, discharge effluent and emit foul odour (decaying carcasses and treatment chemicals), impacting the health of workers and residents. The rolling mills in Fatullah also pollute the air in this region. BOX 2.7: ROLE OF RICKSHAW PULLERS IN URBAN TRANSPORTATION Rickshaw pullers form an important constituent of the transport system of Dhaka and they form the single most important mode of non-motorized transport which does not directly cause pollution. They mostly serve the needs of short to medium distance transportation, especially providing feeder services from houses to the arterial routes. At the same time though, this mode of transport has been identified as the main cause of traffic congestion on city roads. During discussions with rickshaw pullers in the Gulshan area, it was revealed that most of them are landless labourers and have migrated to the city for livelihood leaving their families behind. Living in Theks (Bachelor Hostels), they rent the rickshaw on a daily basis from an owner at a daily rent of around TK 50- 80/day. During consultations with them, it came to light that their income ranges between TK 200 – 300 /day and they usually remit most of the income to their families either weekly or fortnightly. The remittance of income is usually carried out through a network of local telephone booth networks. The concerns expressed by the rickshaw pullers are: • They complained that their livelihood suffer because they are not allowed to ply on certain portions of some of the main roads. • They are usually unaware of the traffic restrictions and face inconvenience because of any sudden change of these restrictions. • They do not receive any training on traffic rules and signs from any authority. 34445 –Final – Aug 2007 2-17 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The air and noise pollution related issues are: BOX 2.8: AIR AND NOISE ENVIRONMENTAL CONCERNS • Deterioration of air quality due to vehicular & industrial emissions 2.5 FLOODING AND DRAINAGE Because of its location in the flood plains of three major river systems, the urban areas of Dhaka, most of which are low-lying areas except for the Mirpur highlands, have historically been flooded during periods of heavy rainfall in the upper catchments of these rivers. Once the rivers reach their hydraulic draining capacity, they tend to backflow into the city through the interconnected drainage channels and the peripheral rivers (Turag, Tongi, Sitalakhya, and Balu) thereby flooding the low-lying areas in and around the city. As a result, the Dhaka urban area has repeatedly witnessed flooding events. Severe river floods have occurred periodically during 1954, 1955, 1974, 1987, 1988 and 1998. In 1988, most of Dhaka was inundated by the flood except for the DND area, which was protected by embankment constructed earlier and the part of the city near Mirpur. Following the floods of 1988, the western embankment was constructed under FAP 8B (Dhaka Integrated Flood Protection Project). After construction of western embankment, the western portion of Dhaka i.e. west of the central highland has now become almost flood free, but the eastern fringes of the city is still very much vulnerable to floods resulting from the backflow of primarily the Balu River. Due to the flooding from the Balu River in 2004, 40% of the area on the eastern side of the city was inundated for approximately a fortnight. The urban flooding problem in Dhaka may get aggravated because of two main causative factors and they are briefly discussed below: 2.5.1 Illegal Filling of Low Lying Areas The DMDP fringes areas mainly comprise of riverine flood flow zones. As most areas in the city i.e. the DCC areas have already been urbanized the fringe areas would have to be developed for making space for future growth (accelerated Growth Policy as per DMDP). Most of these areas are low lying areas and are presently inundated annually during the monsoon months as the water level in the rivers around Dhaka rises. To make these areas suitable for urbanization, these areas have to be raised by filling up to 2-3 m. As per 34445 –Final – Aug 2007 2-18 SENES Consultants Limited Dhaka-Strategic Environmental Assessment existing regulation, development permission from RAJUK is mandatory before developing any land as per the Land Development Act for Private Housing 2004. However, the weak institutional structure and the lack of political will of RAJUK to implement the provisions of the act (regulated filling and protection of low-lying areas etc) have resulted in unplanned land filling in these fringe areas of Dhaka for the purpose of setting up large real estate projects, targeted only at the affluent sections of the society who comprise about 5 - 10% of Dhaka’s population. Most of these proposed real estates do not have required approvals from appropriate authorities, including the RAJUK or have obtained the same using their political influences or using unfair practices. In addition, without there being any systematic plans by RAJUK for land development and development control in such fringe areas, the intrinsic ability of these flood flow zones to retain or store excess water during periods of high rainfall is getting reduced. As a consequence, the risk of flooding continues to increase in Dhaka and adjoining low lying areas which are now being charted for future development. The private developers' body (REHAB) through a public appeal had suggested to regularize through the Detailed Area Plans (DAPs) all the ongoing housing projects in such areas, many of which are in violation with provisions of law. This move had been strongly criticized by the civil society and environmental groups but still no action has been taken against the erring land developers by RAJUK. Even though the law permits action against the land developers who violate the provisions of the act or even publish public advertisement without obtaining clearance from RAJUK under the Land Development Act, cases have been booked against only a few errant land developers. It was reported by an expert from BUET in one of the workshops that in a recent study conducted in Boro Beraid, Santarkul, Kathaldia and Dumni moujas in the city's eastern fringe areas, severe socio-economic impacts have been reported on the original residents due to the earth filling. These people now face forced displacement from their ancestral homes as well as their traditional livelihood based on agriculture. Even though they are provided compensation amounts, in the absence of any comprehensive rehabilitation policy and with the low skill sets of the displaced people, the signs of impoverishment are even more pronounced. It has even been reported that due to the unlawful modalities adopted by the land developers, 53.2% of the affected locals are forced to sell their lands due to the tactics adopted by the developers, while 25.8% were compelled to sell just because their lands were turned into enclaves within areas filled up by developers. 34445 –Final – Aug 2007 2-19 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 2.5.2 Illegal filling of ditches and drainage channels Dhaka is surrounded on all side by river systems and crisscrossed by drainage channels. The highland areas within the city have already been developed. Population pressures and requirement for more urban land within the city boundaries have resulted in encroachment of the water canals and wetlands which acted as flood retention ponds. These facts were highlighted at the stakeholder consultations during the Cross Sectoral Workshop where the representatives for civil societies presented the case of encroachments in the Hatirjheel and Begun Bari Khal, two important wetlands in the central and southern parts of the city. These two canals are linked to the Norai Khal which drains water from a large part of the city. Both these wetlands have already been encroached; approximately 1200 illegal encroachments have been enumerated by RAJUK in Hatirjheel area. Most of these were constructed by influential people. In addition, during the tenure of the last elected government, land was allocated to Hotel Hilton International, Federation of Bangladesh Chambers of Commerce and Industry (FBCCI), International Arbitration Centre and a few CNG filling stations for setting up offices etc. even though the Wetland Protection Act 2000 prohibits filling up of low lands. It has been reported that land was allotted to Federation of Bangladesh Chambers of Commerce and Industry (FBCCI) at nominal price of Tk 1 lakhs[iflc8] without any public bidding even though it is mandatory as per the procedures of the Government of Bangladesh. Some government agencies, including RAJUK, DWASA, and Dhaka City Corporation (DCC), have also submitted proposals for constructing a link road or a circular road in the area to reduce traffic congestion in the city. The proposals also include constructing other structures over these wetlands. Implementation of these projects would result in greater inundation of the city’s central areas. 2.5.3 Potential Climate Change Impacts on Dhaka The city of Dhaka lies at the focal point of three of the largest rivers of the Indian subcontinent in South Asia. Lying in the lower flood plains of the rivers Bramhaputra, Ganga and the Meghna, this area in central Bangladesh itself forms a part of a dynamic and active delta system. Such deltaic systems involve complex interaction between climate, catchments, deltaic deposition, tectonic subsidence and coastal regimes. At the same time, this region in Bangladesh supports an immense human population and contributes strongly to the regional and national economy. 34445 –Final – Aug 2007 2-20 SENES Consultants Limited Dhaka-Strategic Environmental Assessment However, being a part of such a complex natural system also means that this region is extremely vulnerable to natural events like floods, cyclones and coastal surges. The vulnerability in case of Dhaka is heightened because of the large and concentrated population that it supports and the rapid urbanization that has already caused immense stress on environmental resources. Climate change effects are anticipated to add to such stress with possible adverse impacts on city’s population, especially the economically disadvantaged sections of the society. The onset of potential climate change effects in near future as predicted in the recently published IPPC report may result in a number of interrelated adverse impacts in Bangladesh involving complex interactions between physical processes. The combined effects of subsidence and sea level rise could result in increasing vulnerability to flooding events, serious drainage and sedimentation problems, in addition to coastal erosion and land loss. These changes may result in more frequent tidal surges which may potentially affect many coastal areas, cause inland fresh water resources to be affected by salinity causing serious drinking water supply concerns and limit irrigation over large areas because of reduced flow of fresh water resources from the rivers having sources in the Himalayan glaciers. A combination of such effects will have immense socio-economic impacts in the region. In quantitative terms, for example, a one metre rise could flood almost 30,000 km2 of Bangladesh, affecting over 13% of the population, mostly in the lower deltaic regions of the south.36 At the Dhaka level, the height of the DMDP area varies between 2- 6 m above sea level. The area is also known to be undergoing tectonic subsidence at an average rate of 0.62 mm/year, but can reach up to 20 mm/year37, thus effectively lowering height compared to the sea level. In addition, a large part of the fringe areas of Dhaka comprising about two-thirds of the DMDP area are characterized as flood flow zones. These areas are extremely prone to flooding and remains under water for most parts of the monsoon season due to overflow of the channels of the rivers as discussed before. As a result of climate change effects, Dhaka may get adversely impacted in the following way: • Increase in flood vulnerability in the surrounding low-lying areas would act as a disincentive for the city to expand spatially and disperse the urbanization process to accommodate the rising urban population thereby coming in the way of expansion of the city which may in turn impede the economic growth linked with the capital city; 36 Source: IPCC Special Report on The Regional Impacts of Climate Change An Assessment of Vulnerability, Bert Bolin, Robert Watson, Marufu Zinyowera, Narasimhan Sundararaman, Richard Moss,1996 37 Alam, 1996 34445 –Final – Aug 2007 2-21 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • The increase in flooding potential would aggravate flooding problems within the city. It has been established during earlier flood events that the aggravation of flood situation in the city has been as a result of backflow from the larger rivers which again could not drain out excess water because of tidal influences. In the case of an increase in sea water levels, this problem may get more severe thus putting the present and proposed flood management system of the city under risk; and • The associated problems of climate change leading to loss of land and livelihood for economically disadvantaged people residing in the surrounding regions of Dhaka is expected to result in creation of a large inflow of refugees into Dhaka, which is the only large city in the area that can provide them alternative livelihood opportunities. The concerns influencing the flood and drainage of can thus be summarized as: BOX 2.11: FLOODING AND DRAINAGE ENVIRONMENTAL CONCERNS • Increasing vulnerability of floods due to unplanned filling up of drainage channels, wetlands, low lying areas and climate change. The analysis above has helped to formulate the environmental priorities discussed below. It was also clear from the above discussion that main causal links leading to environmental degradation are institutional failures, lack of enforcement, policies which provide disincentives for environmental conservation and governance constraints. These issues are discussed in Chapter 3. 2.6 FORMULATION OF ENVIRONMENTAL PRIORITIES The situation analysis informed the identification of environmental priorities associated with urban development in Dhaka that guided the SEA. As per the methodology adopted, the shortlisting of priorities is the outcome of an analysis of the key environmental issues affecting urban development in Dhaka, which were discussed in this chapter, and the degree of concern attached to them by the stakeholders. As said before, Dhaka’s environmental issues associated with urban development were identified based on review of secondary information, visual surveys and discussions with stakeholders. These issues summarized in boxes 2.3, 2.6, 2.8 and 2.11 were analytically assessed against the following criteria: • spatial and temporal extent of pollution; • reversible/irreversible depletion of environmental resources; • impacts of environmental degradation on vulnerable groups; • existence and effectiveness of pollution control mechanisms. 34445 –Final – Aug 2007 2-22 SENES Consultants Limited Dhaka-Strategic Environmental Assessment This analysis led to a categorization of environmental issues as of having high, medium and low level priority (see third column 3, table 2.1) These issues were also considered by the SEA stakeholders that ranked them as high, medium and low priority concerns (see second column, table 2.1). For the identification of priority environmental concerns, the perceptions of key stakeholders, particularly the most vulnerable to environmental degradation, were assessed through one-to-one meetings, focus group discussions and workshops following a public participation and consultation plan for the SEA. At the Interim Workshop the stakeholders ranked the concerns based on the order of priority of the concern. The stakeholders’ perception was subsequently ranked into high, medium and low. Subsequently, environmental priorities were categorized as high, medium or low priorities applying the criteria presented in the ranking matrix of figure 2.5 (see fourth column, table 2.1) FIGURE 2.5 RANKING MATRIX FOR STAKEHOLDER PERCEPTION[iflc9] Analysis of stress on environmental receptors High Medium Low Stakeholder perception of High dergree of concern Medium Low High Priority Medium Priority Low Priority Table 2.1 shows the results of the prioritization exercise. The following are, therefore, the high environmental priorities associated with urban development in Dhaka identified in this SEA: • Surface water pollution due to discharge of untreated sewage & effluent. • Depletion of ground water due to overdependence on ground water resources. • Increasing vulnerability of floods due to unplanned foiling up of wetlands, low lying areas and climate change. • High urban densification in certain areas resulting in strain on urban services. 34445 –Final – Aug 2007 2-23 SENES Consultants Limited Dhaka-Strategic Environmental Assessment TABLE 2.1: ENVIRONMENTAL PRIORITIES IN DHAKA 34445 –Final – Aug 2007 2-24 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 3.0 URBAN PLANNING IN DHAKA Urban planning can be closely linked with the improvement of quality of life of citizens in a city. The quality of life again has a direct relate to the condition of environmental resources in an urban area and the footprint that intense developmental pressure have on them. Urban planning and the implementation of these plans through an appropriate institutional setup are critical to influencing environmental priorities highlighted in the previous section. The soundness of the overall urban development strategies, plans and programs and the effectiveness of their implementation through an efficient and improved institutional setup would govern the success of how environmental priorities will be addressed through a strategic planning framework as also DAP level planning for Dhaka. This chapter of the SEA would analyse the overall urban planning approach that has been adopted for the Dhaka urban and peri-urban area comprising the DMDP area, the focus of the regional plans in the form of the DMDP and the sectoral plans like strategic transport plan, sanitation and sewerage master plan etc. along with the hierarchy of institutions involved, their strengths and weaknesses. The existing coordination between the various institutions to take into account cross-sectoral issues in the planning process has also been dealt with. This has been followed by a discussion of the key stakeholders involved in the planning process and an analysis of their influence on key aspects of planning. This chapter concludes with the analyses of the plans and the institutions involved with reference to plan transmission mechanisms, including governance considerations, institutional weaknesses as well as political economy issues and how these factors affect the key environmental priorities. 3.1 OVERALL PLANNING PROCESS IN DHAKA 3.1.1 Policy Guidance At the apex, the planning approach for development in Bangladesh flows from various high level policies which are complemented by a host of legislations, strategies, plans and programs. However, the Government of Bangladesh is yet to formulate a definite policy with the intent of providing broad based guidance for urban development for key urban centres like Dhaka and Chittagong. Presently, though an effort is being made through an ADB supported urban reform program to formulate a National Urban Sector Policy to delineate the approach to be followed in the process and guide the pattern of urbanization in Bangladesh. There are certain other national and regional level policies which can be related to various other aspects of urbanisation and are listed below: • National Water Policy • The Industrial Policy 34445 –Final – Aug 2007 3-1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • National Housing Policy • National Environment Policy • National Policy for Safe Water Supply and Sanitation 3.1.2 High level Planning Focus The Bangladesh Planning Commission through the Five Year Development Plans (FYPs)38 also played a role for setting the overall planning direction for growth and development of the urbanized areas in the country. The Planning Commission acted under the general guidance and control of the National Economic Council (NEC), which is the highest policy-making body in matters of socio-economic development. The development planning of the country including urban development was done through Annual Development Programmes (ADP) within the FYP. Additionally, development projects initiated at the level of government agencies, divisions, departments, local government bodies are channelled upward through the relevant ministries to the Planning Commission. The administrative ministries concerned are authorized to approve (under recommendation from the Planning Commission) projects involving costs up to a designated level. Projects involving costs beyond that level are recommended to the Planning Commission for consideration, approval and allocation of funds. However, at present Five Year Planning has now been discontinued in favour of a long-term perspective plan. 3.1.3 Urban Planning for Dhaka In Bangladesh, the concept of regional planning co-exists with a primary sector planning approach. Regional plans in the form of Master Plans were first developed for large metropolitan regions like Dhaka and Chittagong in the late 1950’s and 1960’s. The first Master Plan for Dhaka was prepared in 1959, for 20 year period covering roughly 830 km2 with a target population little over one million assuming an average annual population growth rate of 1.75% in the city areas. However, the rate of growth of population of the city surpassed the plan targets by almost three times even during the planning period i.e., in 1981 the population of Dhaka was 3 million. So by the time the thinking for a new master plan was initiated in the early nineties, the earlier Master Plan had long become irrelevant. During this time, RAJUK was established as a development and planning authority for Dhaka in April 30, 1987 by replacing the Dhaka Improvement Trust (DIT) and was given the responsibility for the metropolitan area of Dhaka covering an area of 1528 km2. During the early nineties, RAJUK delineated a broad based Dhaka Metropolitan Development Plan (DMDP) with 38 After the fifth Five-Year Plan covering 1996–2001, the five-year development planning has been discontinued and planning has been guided by a poverty reduction strategy paper or PRSP that was adopted in October 2005 for 2005–2015. However, unlike the Five-Year Plans, the PRSP does not make any provision for urban and regional planning nor does it place any emphasis on comprehensive development of cities. 34445 –Final – Aug 2007 3-2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment assistance from the UNDP/UNCHS. The development plan for DMDP, prepared in 1995, has a three-tier structure. They include: i) The Structure Plan - a long-term strategy (1995 – 2005); ii) Urban Area Plan- interim mid-term strategy (1995 – 2005); and iii) Detailed Area Plans – providing detailed planning proposals for specific sub-areas. The Structure Plan and the Urban Area Plan was developed subsequently and notified in 1995. The Detailed Area Plan (DAP) was conceived as the third and lowest tier of the DMDP planning hierarchy shown in Figure 3.1. As per the design laid down in the TAPP document for “Preparation of Structure Plan, Master Plan and Detailed Area Plan for Dhaka: (BGD/88/052)� prepared with assistance from UNDP in 1990, the DAPs were to be prepared in house within RAJUK after building adequate capacity planning in the planning department. However, due to institutional failures and inability to develop internal capacity, the DAP preparation process had been set back by more than ten years. Ultimately, the DAP preparation was outsourced to consultants about two years back and is expected to be completed by August 2007. For the purpose of DAP preparation, the entire DMDP area was divided into 26 Special Planning Zones (SPZs) which was later consolidated in the form of five planning areas (see Table 3.1) after combining the SPZs and the planning work has been awarded to four firms of consultants. 34445 –Final – Aug 2007 3-3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.1: DMDP AND DAP PLANNING AREAS 34445 –Final – Aug 2007 3-4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment TABLE 3.1: DAP ZONES AND CATEGORISATION Specific Area Area (km2) DAP Zones Covered Developed Developing Fringe Total Tongi, Gazipur Pourashava, Gazipur Sadar and Rupganj Group A Upazila 103 341 445 Narayanganj and Kadamrasul Pourashava, Bandar Group B Upazila 26 198 224 Group C Most of the DCC area 186 21 207 Keraniganj Upazila Group D 181 181 Savar Pourashava and Group E Savar Upazila 62 254 316 Restricted Airport & Cantonment Area39 69 Total 186 213 976 1445 3.2 REGIONAL PLANS – STRUCTURE PLAN & URBAN AREA PLAN The Structure Plan and the Urban Area Plan (UAP) form the higher and middle level plans of the DMDP planning framework and were completed in the early 1990s with the objective of recommending measures for promoting balanced growth within the DMDP area. It was to be followed up by the formulation of an extensive set of micro level detailed area plans (DAPs) for different zones of the city. At the middle level though, the original intent was to actually prepare a Master Plan, but that got altered to a UAP during the plan preparation process for reasons that have not been fully explained in the planning documents. The non-preparation of a Master Plan meant that higher level area wise development control was not incorporated into the planning process thereby making the task of preparations of DAPs more difficult. The intent of the Structure plan was to provide a long-term strategy (20 years) for the development of the DMDP Area with a population target of 15 million. The Structure Plan thus provides a policy level approach at two levels: Spatial Policies: a set of policies that were attributed by geographic areas like pre-established areas, urban fringe areas and areas demarcated for new development and looking into their uses like agriculture, flood flow zones, flood retention ponds, special areas, etc. The Structure Plan provided neither land use zoning nor any policy prescriptions that would direct subsequent urban 39 Restricted area comprises of the Cantonments and Airports. 34445 –Final – Aug 2007 3-5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment development. In fact it was a series of guidelines which were either not mandatory nor were instruments for implementation specified. Sectoral Policies: a set of polices listed under their subject or sectoral headings like industrial area development, informal sectors, institutional and public administration, transportation, etc. The Urban Area Plan was subsequently prepared as a strategy document that was intended to provide mid-term directions i.e. ten years for the planning of Dhaka. It was expected to be an interim development management solution until the Detailed Area Plans were prepared. The UAPs covered the areas of Flood Action Plan (FAP) components 8A and 8B as well as the Tongi-Gazipur and Savar-Dhamsona areas. Both planning documents emphasized suitable capacity building within RAJUK or the creation of a new planning organisation for effective implementation of the DMDP planning concept. The ambiguities and imprecision in the Plans, combined with the powers bestowed on RAJUK by its constitution, allowed the latter to ignore the Plans and to engage with the private sector developers to the benefit of both, but to the detriment of the environment. In the absence of any institutional support for the Plans from RAJUK or any other planning agency, both have remained static paper documents and have become redundant with time. Consequently, as a fallout of non-implementation of the higher level plans, the preparation of the lower level plans in the form of the DAPs have also got jeopardised. 3.2.1 Detailed Area Plans The Detailed Area Plans (DAPs) which are currently under preparation for five sub-areas within the DMDP are supposed to build more detailed planning provisions for each specific sub-area and be in compliance with the Structure Plan and the Urban Area Plan. At the same time, the DAPs are expected to forge close linkages with various sectoral plans as may be relevant to the specific area. Importantly, till the DAPs are prepared for each sub-area and notified, land use management functions are supposed to be exercised through the policies, guidelines, and rules found in the Structure Plan and the Urban Area Plan. However, with more than ten years of gap, these guidelines and rules at the higher level have become irrelevant because of fast paced unplanned development witnessed by Dhaka. Furthermore, RAJUK did not undertake any in- house planning capacity enhancement as recommended in the UAP. As a result, the DAPs are now being executed by RAJUK through external consultants mainly as a standalone project. Reviews of the current DAP planning process have brought to light the following issues: • The DAP preparation is not guided by appropriate strategic level planning framework as the Structure Plan and the Urban Area Plan do not have any relevance at present. As a 34445 –Final – Aug 2007 3-6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment result, the DAPs for the five zones would not reflect a regional development approach for the overall development and growth within the DMDP area. • The DAP planning process was found to have a very weak interface with the sectoral planning agencies and as a result, is unlikely to produce a plan that can be seamlessly integrated with the sectoral strategies and plans. This is because, on one hand the Technical Management Committee which was charged to oversee plan preparation was ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared. On the other hand, the DAP consultants have also been unable to establish useful contacts with sectoral agencies for formulating respective sectoral aspects of the local level plans. In addition, as many of the sectoral plans do not have coverage over the entire DMDP area, especially the fringe areas, and therefore the DAPs for these fringe areas do not have any sectoral planning guidance at all. • In our assessment, the Terms of Reference for the preparation of the DAPs are extremely ambitious and under-resourced; and the local consultants selected for plan formulation do not appear to have the technical capability or expertise to complete the task. • The DAP consultants have not been provided any guidelines on demarcation of sensitive areas where urban development should be restricted because of environmental and flood related sensitivities (wetlands, flood flow zones, retention ponds, canals and drainage channels) which may lead to faulty demarcation on land use maps and thus putting such zones at risk. • Furthermore, the DAP consultants appear to have limited understanding of the pollution- intensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. 3.3 SECTORAL PLANNING Sectoral planning in the urban areas of Bangladesh run mostly as a parallel process with a weak interface to urban or regional development plans. As a result, most of the sectoral plans concentrate on finding localised and short term solution to urban problems in a particular area within the DMDP. In many cases, the sectoral organisations do not have the mandate to provide services throughout the entire DMDP area resulting in exclusion of some areas like those falling under Municipalities and Pourashavas. As a result, these bodies formulate disjointed and fragmented sectoral plans for their own areas which often do not conform to the higher level sectoral policy and planning guidelines. In the section below, the key sectoral plans that relate to the environmental issues of concern are briefly discussed. 34445 –Final – Aug 2007 3-7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 3.3.1 Water Supply The Dhaka Water Supply and Sanitation Authority (DWASA) is responsible for providing water supply within the DCC and Narayanganj municipal areas. In the remaining four municipalities i.e. Savar, Tongi, Gazipur and Kadal Rasul, the responsibility is with the respective urban local bodies. The DPHE is responsible for planning and commissioning of water supply schemes in areas outside DWASA areas. DWASA is also planning to include Gazipur, Savar, Tongi Ruganj and Purbachal in its service area. The DWASA water supply strategy aims at providing clean water supply in its service area i.e. DCC & Narayanganj and presently provides for about 1.5 BLD of water to the Dhaka water supply system. The strategy proposed for the water sourcing in the short term (till 2010) is primarily dependant on groundwater sources. It has proposed that 231 MLD would be extracted from the deeper aquifers, to be implemented under the Dhaka Water Supply Project; while 131 MLD would be extracted from the arsenic free aquifers of Singair Upazila (25 km from Dhaka). However in the medium term (till 2015), DWASA intends to rehabilitate and augment the Saidabad WTP to increase treatment to 675 MLD from the present 275 MLD. In addition, to meet the additional supply requirements DWASA plans to develop four new treatment plants at Purbachal, Khilkhat, Keranigonj and Pagla I as also source water from Padma and Meghna. As a long-term strategy, the authority plans to source water from Meghna (17 km) and Padma (45 km) by 2015 and 2020 respectively. The plan also aims at providing 100% water supply coverage to the urban poor as indicated in the Dhaka Water supply guidelines recently published by the Government of Bangladesh (GoB). Further in an effort to manage water resources, DWASA intends to reduce the operational losses from leaks in pipes and has made roof top rainwater harvesting mandatory in the clearance provided to private housing and land developers. The urban local bodies in the DMDP region intend to extend the coverage area of the water supply network to the entire municipal/jurisdictional areas. However they have not yet developed any master plan for this purpose. There are also no current plans to utilize surface water sources in the pourashava areas and fringe areas. 3.3.2 Sewage and Sanitation Planning for sewerage and sanitation sector has been traditionally a weak area compared to other aspects of urban planning in Dhaka and its adjoining areas. The Dhaka Master Plan of 1951 prepared by Dhaka Improvement Trust (DIT) or the DMDP Structure / Urban Area Plans did not lay emphasis on the sewerage sector and did not take into account the extensive urbanization of 34445 –Final – Aug 2007 3-8 SENES Consultants Limited Dhaka-Strategic Environmental Assessment the city and related contextual problems that may arise in this sector. More recently, the National Water Policy 1999, mandated that relevant public agencies would be responsible for management of the sewerage and sanitation facilities in cities and urban areas and the emphasis on building necessary sewerage and sanitation infrastructure was also reiterated by the Millennium Development Goal set by the Bangladesh Government. Similarly, when the DWASA was set up in 1963, as a public sector utility to cater for potable water, sewerage and storm water drainage for the city, it prepared a Sewerage Master Plan on the basis of maximum of 2-story housing which became irrelevant with time and rapid rate of rise of population. In the late nineties DWASA carried out a number of feasibility studies to look into ways of improving the sewage management in the city and based on the results has subsequently launched a number of augmentation projects, both for increasing the sewer network and also for treatment of sewage at new sewage treatment plants to be set up. As part of these efforts to augment the sewer system in the city, five new sewage treatment plants (Diabari, Tongi, Uttarakhan, Baderteik and Kamrangir Char) along with pipelines and ancillary structures are planned to be developed. An initiative has also been undertaken to promote integrated water pollution management in the watershed of the DMDP region. Recently two initiatives namely Dhaka-Chittagong Water Supply & Sanitation Project and Dhaka Integrated Environmental Water Resources Management Project (DIEWRM) are being undertaken with assistance from the World Bank. Under these projects the sewage master plan would be updated along with improvement and rehabilitation of the sewage system in Dhaka along with construction of new sewer lines and treatment plants. A number of other activities would also be undertaken for improvement of the storm water drainage and treatment of industrial effluent under these two funding initiatives. However, till date, there is no updated Master Plan for waste water management of Dhaka that takes a comprehensive look at the problems of sewage management in the Dhaka urban area. A bidding process has currently been initiated by DWASA under funding support from International Development Association (IDA), to prepare a Master Plan for this sector. In terms of providing low cost sanitation for the economically disadvantaged section of population, the sanitation policy40 recommends the development of individual and community latrines for providing sanitation facilities in slums and other informal settlements but such efforts are yet not prominent in the DMDP areas. The development of such sanitation facilities have been further emphasized in the National Water Management Plan, 2001 which recommends individual and local community facilities e.g. pit latrines, household latrines with septic tanks, community sanitation facilities and small bore sewerage system. However, no major initiatives 40 National Policy for Safe Water Supply & Sanitation, 1998 34445 –Final – Aug 2007 3-9 SENES Consultants Limited Dhaka-Strategic Environmental Assessment have yet been taken in the city or in the peri-urban areas for development of community latrines and other sanitation facilities in slums and other informal settlements. 3.3.3 Drainage and Flood Protection Planning for flood prevention and mitigation has been an area of high priority in Bangladesh because of the country’s high vulnerability to floods during the monsoon season. The causes for such vulnerability can be mostly attributed to natural causes with topography in a large part of the city being 2-3 metres above sea level and the high rainfall the area receives from the southeast monsoon system. This vulnerability is likely to increase with impacts of Climate Change being felt all around the world. Most of the low lying areas in Bangladesh are likely to be submerged or remain under water for several months in a year. This calls for urgency in implementing coordinated flood prevention and mitigation programs to combat this issue. The National Water Management Plan41 drawn up by the Water Resources Planning Organization (WARPO) has clearly indicated that gravity-based drainage should be given preference for draining storm water from complex urban centres like Dhaka. The same principles have been reiterated in the DMDP Structure Plan42, where special emphasis has been laid on the protection of the natural drainage systems e.g. water channels and ponds and reduce dependence on the mechanical systems e.g. pumping out of water after flooding being a reactive response to the problem. To protect the city against floods, a number of other plans and programs have been prepared. Prominent among them are FAP-8A & FAP-8B prepared for the BWDB by consultants under funding support in the early 1990’s. After the floods of 1988, the FAP 8B was implemented and as a result the western embankment was prepared under the Dhaka Integrated Flood Protection Project. In addition to the embankment, three pumping station were constructed and one retention pond have also been developed. However, the FAP 8A has not yet been implemented due to lack of funds. To reconsider the project, the BDDW has recently conducted a study that looks at the integration of the Eastern Bypass Multipurpose Project with the Eastern Embankment Project. The principal organisations responsible for flood control are NWRC, WARPO, BWDB, LGED, RAJUK, and IWM. In addition to the above institutions, the organisations responsible for urban flood also are DWASA, Pourashavas and DPHE as they are involved in the storm water management in their respective areas of control. In the case of river floods even though there are 41 National Water Management Plan, 2001, WARPO 42 The DMDP Structure Plan (1995-2015) 34445 –Final – Aug 2007 3-10 SENES Consultants Limited Dhaka-Strategic Environmental Assessment a number of institutions who have authority, no coordination between these organisations exist because of the absence of an apex organization coordinating these efforts. 3.3.4 Transportation The Strategic Transport Plan (STP) documents i.e. DITP and DUTP have stressed on the need for development of a road based transportation system for the city. Similarly the Structure Plan in 1995 has also stressed on a road based transport system, but considering a long-term strategy it has also highlighted the need for development of inland water transport as a parallel mode of transportation. Moreover, in 2005 the apex planning document43 recognizing the major role played by the road sector in expanding44 the passenger movement in Bangladesh stressed on the need for shifting the focus of promotion of transport infrastructure in urban centers from road based surface modes. It points out the limitations of expanding the surface modes of transport in an urban center like Dhaka where the ownership of vehicles is increasing more rapidly than the population growth of the city. Taking into consideration the regional focus, the Strategic Transport Plan was developed for the entire Greater Dhaka Region45. The plan was formulated to bring about a coordinated planning in the transportation sector in the region. The plan has stressed on development of a multi-modal transport system for the city with a combination of roads, bus rapid system and a rail based mass rapid system. A number of new roads have been proposed including a major east-west link and peripheral roads which would reduce the transportation problems in the city. However, due to the high cost involved in developing an underground metro system, it is not presently considered to be a priority. Even though the transport sector has developed a regional approach in planning with the development of the Strategic Transport Plan and formulation of the Dhaka Transport Coordination Board some of the municipalities in the DMDP region have developed their local transport master plan, under the UGI Project funded by the ADB, without any interaction with the DTCB. Such misdirected planning would severely affect the gains from the regional plan. 3.3.5 Solid Waste Management The Dhaka City Corporation Ordinance, 1983 and The Pourashava Ordinance, 1977 have entrusted these institutions with the function of removal and disposal of solid waste in their respective areas. These regulations however do not make it binding upon the institution to 43 Unlocking the Potential , The National Strategy For Accelerated Poverty Reduction, October 2005 44 The passenger movement has increased from 35 billion passenger km. in 1984/85 to 72 billion passenger km. in 1996/97 45 It consists of the area between the Padma and Meghna Rivers . The area contained between the V shape formed by the confluence of the two rivers is wholly contained within the Dhaka division and comprises of six district namely Dhaka, Ghazipur, Narsingdihi, Manki ganj, Munshiganj and Narayanganj. 34445 –Final – Aug 2007 3-11 SENES Consultants Limited Dhaka-Strategic Environmental Assessment undertake house-to-house collection, transportation, treatment and disposal of waste. Thus, management of solid waste has been weak in the city and also in the fringe areas. There are no regulations in Bangladesh for management of either Municipal Solid Waste or Hazardous and Bio-Medical Waste. The apex-planning document46 recognizes solid waste management and untreated industrial waste disposal as major problems of urban environment and emphasizes the development of a solid waste management system for reduction of environmental problems. The regulatory framework must be strengthened and implemented strictly with provisions for proper and adequate incentives to entrepreneurs to ensure that all industrial wastes are properly treated before disposal. The Clean Dhaka Master Plan 2005 that has been adopted by DCC encourages collection of solid waste from households but does not place any added emphasis on segregation of waste and treatment/ recovery of the waste. Composting as a method of disposal is well recognized and has been successfully implemented by “Waste Concern� an environmental NGO. It has introduced Barrel Type composting in slums and traditional composting in non-slum areas in two wards in the DCC area. However in other areas, no such initiatives have been taken or have been encouraged by the Clean Dhaka Master Plan. Many of these areas still depend on dumping of MSW directly to the existing dumping sites. 3.3.6 Industrialization Though there are no heavy manufacturing industries in the DMDP area, the number of pollution intensive industries has grown rapidly in the last decade. The effluent and emissions from the existing small and medium scale industries are a major reason for water and air pollution in Dhaka. The Environment Policy 1992 and the Environment Conservation Act 1995 has laid strong emphasis on the control of industrial pollution. The policy states that a systematic environment assessment has to be undertaken before starting any industrial operation. Guidelines for project level Environmental Impact Assessment were also established drawing power from the Environmental Conservation Rules, 1997. All projects are categorized into one of four groups: Green, Orange A, Orange B and Red. The environmental clearance applications submitted by the project proponent are verified47 by the 46 Unlocking the Potential , The National Strategy For Accelerated Poverty Reduction, October 2005 47 For Green and Orange A category projects, once the inspector submits his report (typically within 5-7 days) the divisional head makes a decision within three days of receiving the report. Files for Orange B and Red category projects are sent to the Senior Chemist/Assistant Director. 34445 –Final – Aug 2007 3-12 SENES Consultants Limited Dhaka-Strategic Environmental Assessment divisional offices and sent to the Environmental Clearance Committee of the DOE48 in Dhaka and then passed on to the Director General for clearance. The clearance conditions make it mandatory to renew the environmental clearance annually, but this aspect of legislation has not been enforced. The Environment Assessment process also requires the project proponent for industries to obtain site clearance before initiating any construction activity on the ground. However, the process has proved to be ineffective because of technical in-competencies in DOE and due to collusive relationships between industry and the DOE. Even though the DOE has initiated some modification to the legislations e.g. Environment Court Act 2000 (amended 2002) to ensure stricter compliance with environmental legislation, there has been no initiative by the department to enact legislation in some important areas e.g. Treatment and Disposal of hazardous waste, Siting Guidelines of Industries, Management of Solid Waste (Municipal and Industrial), Effluent Discharge Standards for various types of industries etc. 3.3.7 Housing and Slum Improvement The need to provide housing for the low income group was recognised in the Structure Development Plan. Annex-B of the Plan provides the principles for Guided Land Development. Among others, it notes that the demand for low income housing should be met. Clearly this has not happened. More recently, for low income groups, the National Strategy for Accelerated Poverty Reduction (PSRP) links inadequate housing as one of the reasons for poverty. It considers housing problem of the poor as an integral part of poverty reduction programme and recommends a number of strategies like provision of housing loan at cheaper rates and stress on implementation of program for resettlement of slum-dwellers, the disadvantaged, the destitute and the shelter less poor. The government has also initiated a housing loan scheme, called the Housing Fund with the intent of improving the quality of life of the poor people by providing loans to construct safe and durable houses. However, even though the apex plan and programs lays stress on the housing problem, there have been no follow up action at the action plan level to address the requirements of housing for the urban poor and vulnerable sections of the society. NGOs and Civil Society Groups have also not taken up any worthwhile programme in this regard. In several Asian countries and in the UK the problem is being tackled more directly and effectively. Real estate developers are required to allocate a specified proportion of land being developed for low income housing. RAJUK, as the main urban development authority, has set no 48 DOE offices in each of the six divisions receive applications and issue Environmental Clearance Certificates for proposed investments within that division. The divisional offices verify supporting documents and pass it on to the divisional head, who assigns an inspector for follow-up 34445 –Final – Aug 2007 3-13 SENES Consultants Limited Dhaka-Strategic Environmental Assessment such stipulations on the developers. This is explicable by the fact that it is not so profitable to get involved in the provision of low income housing. 3.4 INSTITUTIONAL SET UP FOR GOVERNANCE & URBAN PLANNING Bangladesh is a parliamentary democracy with the president as the head of state and prime minister and council of ministers in charge of the executive functions49. The ministries and its associated bodies responsible for policy formulation and execution are presented in Figure 3.2. At the same time, local self-governance is also encouraged in the constitution. A number of ministries and associated departments are involved in the planning and administration of Dhaka. As many as 55 organizations of national, sectoral and local levels are effectively involved in planning and development of urban affairs in Dhaka Metropolitan Development Area. The key functions of urban planning and development is with two ministries and a wide range of central department’s, utility agencies, development authorities and urban local bodies. The two ministries primarily responsible are Ministry of Housing & Public Works (MoW) and Ministry of Local Government, Rural Development and Cooperatives (MLGRD). Physical planning, development, control, and housing functions are under the MoW, while urban utilities, infrastructure and urban administration are the responsibility of the MLGRD. Urban programs of the MOW are implemented through the Public Works Department (PWD), the Urban Development Directorate (UDD), and the Housing and Settlement Directorate (HSD). Among the other institutions involved in planning and implementation of the city management, the more comprehensive responsibilities lie with RAJUK and DCC. Other organizations have specific sectoral roles and responsibilities e.g. National Housing Authority - housing, Dhaka Water Supply and Sanitation Authority (DWASA) - water and sewerage, Road and Highways Department (RHD) - major intra and inter city roads, the Dhaka Metropolitan Police (DMP) - traffic management and maintenance of law and order; and the Department of Environment (DOE) - Environment. 49 Interim Government: Bangladesh is presently being governed by an Interim Caretaker Government which is headed by the last retired Chief Justice of the Supreme Court as its Chief Advisor (with status of Prime Minister) and advisors with status of ministers assisting him with governance. 34445 –Final – Aug 2007 3-14 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Figure 3.2 : Urban Governance Setup & Flow of Authority[iflc10] The design and development of water supply and sanitation systems is the responsibility of the Department of Public Health Engineering (DPHE), except for Dhaka and Chittagong, where autonomous Water Supply and Sewerage Authorities (WASAs) are operational. These authorities are independent of the local municipal governments and their Chairman reports directly to the Secretary of the MLGRD. Maintenance responsibilities of most of the physical infrastructure built by the developmental authorities are passed on to the local governments. In addition, two kinds of local government institutions operate in the urban areas of Bangladesh and share responsibilities with the other department and agencies for the urban planning and plan implementation functions. Municipalities (locally called Pourashavas) or Corporations form the urban local body and operate under the jurisdiction of the MLGRD. In addition, special purpose developmental authorities like the Rajdhani Unnayan Kattripakha (RAJUK) for the larger cities have been created under the MoW and are charged with the preparation of master plans and have legal powers covering developmental planning and execution. [iflc11]These development authorities can also undertake infrastructure works and land development together with estate management of commercial and residential schemes. The interactions between the planning and administrative institutions have been illustrated in the Figure 3.3 below. 34445 –Final – Aug 2007 3-15 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.3 : INTERACTION BETWEEN PLANNING INSTITUTIONS RAJUK Pourashavas, City Corporation, Union Porishods Sectoral Agencies (DWASA, BTWA, DOE, etc However, in practice, coordination and sharing of information pertaining to planning and plan implementation between various agencies have been very weak and non-transparent. Though the mandate of RAJUK was to build such coordination between various other departments and local bodies and develop common strategies for urban development in Dhaka, RAJUK has been unable to perform its role in this direction because of absence of leadership. 34445 –Final – Aug 2007 3-16 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3-4 : PRINCIPAL AGENCIES RELATED TO URBAN PLANNING IN DMDP REGION 3.4.1 RAJUK – An Institutional Analysis RAJUK was established in April 30, 1987 by replacing Dhaka Improvement Trust (DIT) as the development authority for Dhaka Metropolitan Development Plan area and has been accorded legal powers for developmental planning and execution. At present, RAJUK is the key urban agency responsible for overall planning for the DMDP area in coordination with other sectoral agencies. It is also responsible for the formulation and monitoring of the Detailed Area Plans (DAPs) in accordance with the overall guidance provided by the higher level plans (Structure and Urban Area Plans). The main functions of RAJUK include: • Responsibility for planning and development of the city in consideration of the existing policies and the multi-sector investment programs of different related agencies. • Undertake activities like construction of roads, culverts and bridges and also development, excavation, and filling of land as required for the development of Dhaka. 34445 –Final – Aug 2007 3-17 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • Project level planning and design (including conceptual design, selection of materials, design and construction codes and standards, etc.), feasibility studies, project programming and time scheduling etc. • Exert development control as per the provisions of the Building Construction Rules; this includes providing approval for new area development, land filling, etc. • Approve any use of land or any type of construction by issuing land use clearances from its authorized sections. • Provide metropolitan development management leadership, and is entrusted with development of strategic planning function and promotion of poverty alleviation-oriented programs. RAJUK is now a public body managed by a board comprising of a chairman and not more than five members. The chairman is the principal executive of RAJUK and the other members are government officials. All members of the Board are full time officials with specific responsibilities within the broad framework of the organization set-up having five different divisions. The approved organization structure of RAJUK along with estimated number of staff per division is presented in Figure 3-5 below: A review of the organizational setup of RAJUK indicates that the division responsible for development has staff strength of about 50% of the total staff followed by the planning department with about 28% staff. However, within the planning division, only the planning department is primarily responsible for the DMDP plans and therefore for formulation of the DAPs. Though there are 51 approved staff for this department, in effect, there are only 4 planners in RAJUK to plan and also oversee the DAP planning process for an area as large as 1,500 km2. 34445 –Final – Aug 2007 3-18 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3-5 RAJUK ORGANIZATIONAL STRUCTURE RAJUK - SWOT ANALYSIS STRENGTHS • Mandated to be principal planning authority for the entire DMDP region and have been legally accorded powers to fulfill the mandate. • Broad based regional level planning has already been undertaken under RAJUK and notified in the form of Structure Plan and Urban Area Plan. The plans are supposed to govern urban development of Dhaka till 2015. • It is a cash rich organisation as its collection rate is high. Its main sources of income are from selling and developing commercial plots; land auctions; interests from deposits put down by prospective buyers; fees for providing planning permission; penalties levied on illegal construction; and from interest earned when fees and fines are not paid on time. WEAKNESSES • Weak ownership of the DMDP plans. • The planning department of RAJUK is under-resourced and not appropriately staffed. • The five members of RAJUK are direct central government appointees, some of whom have little background in urban planning and development. These direct appointments have led to the politicization of membership. • It has transformed into a centralized organisation with limited reach at the ground level resulting in weak implementation and supervision of the plans. 34445 –Final – Aug 2007 3-19 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • RAJUK was mandated to build coordination between various departments and local bodies and develop common strategies for urban development in Dhaka. It has been unable to perform its role in this direction because of absence of leadership. • Has a poor track record of coordination with the other planning and implementing agencies. • Has been ineffective in formulating detailed development control guidelines on number of critical aspects, including demarcation of areas to be land filled, sensitive zones, etc. • There is an un-questioning and uncritical approach to implementation among the senior bureaucrats and professionals. OPPORTUNITIES • Has been provided the authority to sanction plans in the entire DMDP area under the Building Construction Rule 2006. • The Planning wing is being gradually revived and currently DAPs are being prepared under the supervision of this department. • The formulation of DAPs is an opportunity to amend policies and improve overall urban environmental management. THREATS • Acts both as planner and developer, resulting in conflicting roles. • Has conflicting roles with Pourashavas and DCC with respect of land development and permitting; • In perception of the stakeholders, it has not taken adequate initiatives in improving the city’s environment or the quality of life of the citizens, especially the poor and the vulnerable. • Stakeholders are of the opinion that the organization’s actions favour the powerful sections of the society with political influences and its staff is therefore prone to engaging in corrupt practices. In addition, an analysis of the overall institutional setup for urban planning highlighted the following weaknesses in the system which impedes effective planning for the DMDP area: • While the Planning Commission is responsible for allocating government expenditure and approving high value urban development projects, it generally does not coordinate at a level below the national level. As a result, funds for urban development within DMDP area are allocated to multiple agencies, including the urban local bodies, leading to some plans working at cross-purposes. • Major urban functions are distributed between two different ministries (MOHW and MLGRD), neither possessing lead powers for urban development. As a result, a major institutional conflict arises from the distribution of key urban activities between these ministries. Even though planning, housing, development control and certain land development functions are carried out by the MOHW through RAJUK, some of these activities are also undertaken by the urban local bodies which are under the MLGRD. Thus in absence of a body with appropriate legal and financial powers, there are no over- all planning and implementing mechanisms. 34445 –Final – Aug 2007 3-20 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • The inability of RAJUK to play a leadership role in urban planning and exercise strategic influence on other sectoral agencies has resulted in other agencies taking up planning initiatives on their own without any coordination with RAJUK. In addition, coordination between the various agencies (more than 55 in number) is very poor in spite of having overlapping responsibilities and a role to play in terms of planning or plan implementation in Dhaka. • The government agencies and urban local bodies who have jurisdiction of the DMDP area have inadequate capabilities of urban governance and lack of transparency in terms of planning and project implementation. In many cases distinct vested influences in governance can be observed in favour of interest of people close to power and especially, the members of the ruling political party. • The Ministry of Environment and Forests in general and the Department of Environment in particular, lack the resources and trained manpower to effectively monitor compliance with environment management and pollution control legislation, even at the Dhaka level. They also do not have the power to play the role of a watchdog agency, especially when other government agencies (for example DWASA) are in non-compliance with standards. 3.5 ANALYZING STAKEHOLDER INFLUENCE IN PLANNING AND PLAN IMPLEMENTATION PROCESS The prevailing urban planning process did not attach much importance to the views and opinions of key stakeholders thus promoting a system that was neither transparent nor accountable to the stakeholders of concern. As one of the objectives of the SEA process is to factor in the opinions and concerns of relevant stakeholders into the planning process and make it more responsive to their needs, it was planned to carry out a systematic analysis to understand their stakes or interests, the importance of their priorities and the extent of influence they can bear upon the urban planning process. The analysis can also be considered to be significant because for the first time, the DAPs currently being prepared in parallel emphasize on establishing a more inclusive planning process for local level plans through a process of consultations with all stakeholders who may benefit or may be affected by implementation of such plans. Hence, it was felt that the stakeholder analysis would provide a clearer understanding of the current status of the stakeholders, vis-à-vis the planning process while at the same time equip the SEA process with vital information on their capacity to facilitate or oppose reform in urban planning and bring about environmental improvements through recommendations that emerge from this study. The result of the stakeholder analysis is presented in the form of a Stakeholder Matrix in Figure 3.6 and main stakeholder-wise findings are also briefly discussed in the section below. 34445 –Final – Aug 2007 3-21 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.6: STAKEHOLDER ANALYSIS MATRIX[iflc12] • RAJUK: Though RAJUK was mandated to play the role of the apex planning institution for the Dhaka DMDP area, it did not build up internal capacity to undertake urban planning for a rapidly growing and complex city like Dhaka. As a result of this inability to mature into an institution for formulating strategic and regional level plans for the DMDP area and continually adjusting them when required according to ground realities, it has been unable to exercise its leadership role and bring about coordination between the numerous sectoral agencies and departments responsible for urban development in Dhaka. Gradually the focus and the priorities of the organisation have shifted to the more lucrative functions and it now takes more interest in development and approving related work, in the process it has downgraded its own position as the apex planning authority for DMDP area. Consequently, it is now accorded considerably lower importance in the planning process of the DMDP region. In addition, though RAJUK is successful in exerting some influence on the development pattern of Dhaka because of powers vested in it through legislation, stakeholders consider such influence to be primarily favouring powerful and economically stronger sections of the society, thereby weakening its neutral standing and credibility as a planning and development organisation. • Urban Elites and Realtor Groups: The urban elites and the realtor lobby have been able to incorporate their priorities into the planning process, sometimes by circumventing 34445 –Final – Aug 2007 3-22 SENES Consultants Limited Dhaka-Strategic Environmental Assessment legislative provisions which do not favour them. This is in spite of the fact that they form a small percentage of the urban population. They have also been able to leverage the planning process in their favour by maintaining close ties with the elected representatives and by influencing the administrative setup, sometimes by using unfair means and tactics. • Technical / Academic Institutions[iflc13]: The technical and academic institutions who could have played a important advisory role by providing technical support to urban planning process and also at the same time, could have played a neutral role in monitoring their implementation, have been unable to do so because they lack influence on the administrative setup. For example, important institutions like the Bangladesh University of Engineering and Technology (BUET) or its alumni have been unable to make any significant contribution in the DMDP or DAP plan preparation process or its monitoring and supervision in spite of having a regional planning department. • Department of Environment (DOE): DOE is mandated to be the agency responsible for protecting the environment, but lacks the importance that should be accorded to a monitoring and watchdog institution as per various environment legislations, including the Environment Conservation Act. This is largely because DOE has failed to be an effective monitoring agency. Moreover, given the low priority that is accorded to environmental issues by various other government agencies and other stakeholders like industrial operators, and lack of internal capacity to highlight such issues to the stakeholders of concern for taking priority action, it is also unable to exert its influence to implement environmental protection measures in general and specifically those which are related to urban development in Dhaka. • Vulnerable and Economically Disadvantaged Groups: In spite of forming the majority of Dhaka’s urban population, they have traditionally been accorded very low importance and bear minimal influence on Dhaka’s urban planning process. The reason can be attributed to the fact that a significant percentage of them are migrants to Dhaka and do not have voting rights. [iflc14]As a result, in spite of making a considerable contribution to Dhaka’s economic growth and making provision for much needed urban services at very low costs (housemaids, waste pickers, rickshaw pullers) their efforts are often not recognised by stakeholder groups who are powerful and influential and are considered to be a part of a large informal system. They can exert little or no bargaining power with the political and governance system to win their basic rights pertaining to housing, water, sanitation, health, electricity etc. for living decently within the city. • Civil Society Organisations: The Civil Society Organisations have not yet been able to build a strong case for environmental protection and improvements and get sufficient 34445 –Final – Aug 2007 3-23 SENES Consultants Limited Dhaka-Strategic Environmental Assessment support from the masses or affected stakeholder groups to build pressure on the government setup or on players contributing to environmental degradation. Part of the problem seems to be the low levels of education and environmental awareness among a large section of Dhaka’s urban population. 3.6 ANALYSIS OF PLANNING FRAMEWORK IN CONTEXT OF ENVIRONMENTAL PRIORITIES Analyses in the previous sections have shown that a large number of institutions and sectoral agencies can influence the nature of urban growth and the environmental priorities in Dhaka. It is necessary to understand the strengths and weakness of the different plans and institutions. Additionally, an insight is required into the causative institutional and governance factors which have prevented the formulation and/or the implementation of most plans; thus leading to environmental degradation. These understandings will inform the design of interventions that address the weaknesses and governance issues. This section analyzes the linkages between different components of the planning framework, their associated institutions and the perception of stakeholders with respect to the environmental priorities. 3.6.1 High urban densities and strain in urban services The DMDP Structural Plan has provided directives to optimize land resource development through infilling of under-utilized land, redevelopment of land in lower density communities and upgrading of the physical and social infrastructure to affordable and appropriate levels in accordance with densities. The Structural Plan has also emphasized the densification targets which accompany infrastructure consolidation targets for development of fringe areas and new urban growth areas. Though the onus of directing the development was primarily with RAJUK, being the apex planning authority in DMDP, these policies have failed. RAJUK has found it inconvenient to prioritize any development area for improvements in Developing and Fringe Areas as most illegal land-filling are found in these areas. Majority of the urban growth is only restricted in the developed area, as a result there is severe stress on physical and social infrastructure in the already over-crowded area. Coordination with different sectoral agencies for development of physical and social infrastructure in the Developing and Fringe Areas and planned urban growth in these areas was to be carried out by RAJUK. The sectoral agencies being under different ministries, RAJUK has very little influence over these agencies, hence, the inputs of these agencies in the planning process has not been available. The absence of any agency in DMDP, which wields powers 34445 –Final – Aug 2007 3-24 SENES Consultants Limited Dhaka-Strategic Environmental Assessment cross-cutting all ministries has resulted in comprehensive regional plans not being developed for Dhaka. Local level plans i.e. DAPs, which are expected to delineate the land use, infrastructure development etc., have been delayed by more than ten years. Thus, the city has developed without micro-level planning during the last decade. Therefore, certain areas within the city have witnessed increased overcrowding; new areas developed in the Fringes Areas are mainly low lying and are inundated each year by floods. Furthermore, land development activities have resulted in filling up of wetland and low lying areas with consequent loss of natural features e.g. sink for storm water runoff. Legislations have been developed in Dhaka to control problems through the Building Construction Rules 2006 and the Land Development Act 2004. Even though the Rules are comprehensive and can be effective instruments for controlling development throughout the watershed, the implementation of the Rules has been delayed. Stakeholders feel that the influences of vested interests on the implementing agency as well as the conflict between jurisdictions of the local bodies and RAJUK have set back the planned development process. The conflicts in jurisdictions of the agencies arises from the planning and approval powers provided to the local government under the Town Improvement Act and the Building Construction Rules which have designated RAJUK as the sole authority for issuing permits within DMDP area. To control development of the Fringe Area the Land Development Act makes it mandatory for the private housing infrastructure developers to take permission from RAJUK after clearly delineating the level of filling required and demarcating and developing appropriate plans for protecting natural drainage channels. This act could have been effectively used for regulating the unplanned filling in fringe areas and address the associated problems due to changes of topography of the area. However, lack of political will of the implementing agency has resulted in these legislations being unable to control the unplanned development in the fringe areas. 3.6.2 Surface water pollution due to discharge of untreated sewage & effluent The issue of surface water pollution in Dhaka which has been identified as a priority in the SEA has been addressed through the existing planning framework primarily through the spatial plans (e.g. DMDP Structure Plan), Sectoral plans (e.g. DWASA Sewerage Master Plan, ad hoc sanitation plans of Pourashavas) and national level policies and legislations. National Policies have mandated treatment of sewage before discharge and have directed local bodies to develop sanitation facilities within their areas of jurisdiction to protect surface water bodies from pollution. The DMDP Structure Plan stresses the prevention of pollution of surface 34445 –Final – Aug 2007 3-25 SENES Consultants Limited Dhaka-Strategic Environmental Assessment water sources around Dhaka so that they can be used as a sustainable source of drinking water. However, no regional plans have been formulated for abatement of surface water pollution in the Dhaka Watershed. Though some sectoral plans like the DWASA Sewerage Master Plan have been formulated and this has planned for coverage of the DWASA service area through sewer networks and also for construction of five new STPs. Since this infrastructure has only been planned for the DWASA service area (developed area) it would cover only 30% of the DMDP area. In areas outside DWASA service area, under the local bodies50 (developing and fringe areas) ad hoc plans based on low cost sanitation facilities are being prepared because of the institutional incapability in formulating plans for sewerage of the area under their jurisdiction. Thus large areas of the DMDP comprising of the developing and the fringe areas do not have any plans for treatment of sewage clearly indicating that transmission of policies into plans in DMDP has been weak, and also indicating that no single agency is responsible for planning for sewerage in the entire area. Some programs e.g. Dhaka Chattagong Water supply & Sanitation Program which includes the construction of a CETP for Tejgaon and the Dhaka Integrated Environmental Water Resources Management Project[iflc15] for management of industrial wastewater in Dhaka watershed have been formulated. Even though these are positive steps, it has been observed in the past that lack of incentives for involvement of stakeholders in these programs has often resulted in limited success of these projects. A case at point is the scheme launched recently by DOE whereby the industries have been provided with incentives in the form of reduced duties on imported equipment for installation of effluent treatment mechanism. The scheme met with limited success, as there were no disincentives for the industries to discontinue from the present process whereby they can externalize the cost of treatment. The Environment Conservation Act 1995 (amended) also emphasizes control and abatement of environmental pollution. Even as part of the permitting process of real estate development DWASA has developed guidelines which make it mandatory for developers of housing projects to develop sewage infrastructure at every housing project. The multiplicity of organisations involved in permitting (RAJUK and DWASA), weak institutional setup of RAJUK and DOE as well as no clear mandate of a single organisation for supervision of the permitting conditions seriously limits the effectiveness of DWASA guidelines. Even though the surface water pollution could be restricted by the Act of 1995 weak institutional setup of DOE, prevents effective monitoring, and also curtails the effectiveness of this legislation. 50 Kadam Rasul, Gazipur Pourashava and the union Porishads in DMDP area 34445 –Final – Aug 2007 3-26 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 3.6.3 Depletion of groundwater Depletion of groundwater resource due to over dependence on groundwater has been identified as a priority environmental problem in Dhaka. Under the existing planning framework the National Polices (National Water Policy 1999), regional plans (DMDP Structure Plan), Sectoral plans (e.g. DWASA Sewerage Master Plan, ad-hoc sanitation plans of Pourashavas) and legislations have provided directions for addressing the concern of over use. The National Water policy and the DMDP structure plan specifically emphasize that the groundwater resource should be protected and the main source for water supply to urban areas should be surface water. It also directs the government to identify the scarce groundwater zones and restrict abstraction in such areas. In spite of such stringent policy level guidelines, no regional plans demarcating the groundwater conservation areas have been developed in the DMDP. Even the DWASA master plan is dependent on groundwater, for the short term (till 2010) and medium term (2010- 2015) for water supply. The dependence on groundwater would reduce in the long-term (beyond 2015) with the sourcing of water from Meghna and Padma but considerable amount would still be extracted from groundwater sources. However, outside the DWASA service area, no comprehensive plans for water supply have been developed. The water supply is still based on ad hoc plans which are dependent on groundwater as source. To restrict the abstraction of groundwater, The Groundwater Management Ordinance, 1985, was promulgated which mandates the licensing of tube wells by the Thana Parishad. However the Thana Porishads as other institutions in DMDP, did not have the institutional capability for implementation of such legislation. In the absence of a single planning authority for water supply in the DMDP, comprehensive water supply master plan for the entire area cannot be undertaken. 3.6.4 Increasing vulnerability to floods The issue of increasing vulnerability to flooding due to unplanned filling up of wetlands and low lying areas, which has been identified as a priority in the SEA, has also been addressed through the existing planning framework. This is primarily through the spatial plans (e.g. DMDP Structure Plan), sectoral plans (e.g. Eastern Embankment Project, ad-hoc drainage plans of Pourashavas) and national level policies and legislations. The National Water Management Plan has given emphasis on gravity based drainage system. However, none of the major projects like Flood Action Plans or Detailed Area Plans have stressed on the protection of the natural drainage system. In the already developed areas, number 34445 –Final – Aug 2007 3-27 SENES Consultants Limited Dhaka-Strategic Environmental Assessment of natural drainage channels has been encroached by the land developers with the help of their powerful political influences. At times the natural drainage system has been lost due to wrong implementation plans by the sectoral agencies. These deviations to the DMDP Structural Plan have occurred even though the plan restricts the land development to avoid obstructions to flood flow, within the designated flood plain areas. This has been possible as agencies mandated with the task (BWDB, RAJUK) have not developed guidelines for preparation of lower level plans (e.g. demarcation of flood flow zones on RS & CS maps) and formulate a mechanism for restricting development of these areas. The DAPs, as being prepared presently, may also result in shrinkage of flood retention as the terms of reference for the DAPs suggest gradual phasing out of major retention ponds. Shrinkage of flood retention ponds would result in emphasis on engineering solution like pumping. The lack of appropriate technical capability of the planning process would further reduce the effectiveness of the plans even as they are prepared. The proposed eastern embankment project has been formulated for the construction of embankment only along the western side of the Balu River. However, a large portion, area between the Balu and Sitalakhya Rivers would still remain unprotected, and is vulnerable to flooding. Other than these mega projects, local level drainage projects have been undertaken by local bodies for the problem of water logging purely on an ad-hoc basis. Only in few cases technical expertise of specialized organisations for water modelling and flood control e.g. IWM have been utilised, but in most other cases, these projects have been developed with the local knowledge and myopic vision of the elected representatives who are inclined to develop short term solutions as they need to keep the electorate happy. To protect the wetlands and open spaces, the Urban Areas Open Space and Natural Wetland Protection Act, 2000, also has provision for demarcation and notification of wetland. However, agencies responsible or having ownership of these areas (RAJUK, Land Revenue Department, Fisheries Department, BIWTA, DWASA) have neither demarcated wetlands nor notified on the RS & LS maps. In the absence of legal notification, numbers of wetlands are filled up by the developers and also allowed encroachment by the slums. It is felt that political economy considerations have played a part in the delay of notification of the wetlands. The following three pictures represent the flood retention ponds being retained or created based on three different plans. They highlight the inherent problem of coordination between regional agencies and line ministries and the lack of a single planning authority responsible for flood prevention and control in the DMDP area[ad16] 34445 –Final – Aug 2007 3-28 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.7: PROPOSED FLOOD RETENTION PONDS AS DEMARCATED IN FAP 8A 34445 –Final – Aug 2007 3-29 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.8: PROPOSED FLOOD RETENTION PONDS AS DEMARCATED IN DMDP STRUCTURE PLAN 34445 –Final – Aug 2007 3-30 SENES Consultants Limited Dhaka-Strategic Environmental Assessment FIGURE 3.9: PROPOSED FLOOD RETENTION PONDS AS DEMARCATED IN EASTERM BYPASS PROJECT 34445 –Final – Aug 2007 3-31 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 4.0 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK This section of the SEA report analyses the risks associated with the environmental priorities given the existing planning framework and institutional weaknesses identified. The focus of analysis would be (i) on the gap that exists between the higher and lower level planning mechanisms and the risks that have resulted because of the absence of Detailed Area Plans in the city to control and regulate the urban development process; and (ii) the possible environmental threats that may emerge in future because of the lack of coordination between governmental agencies responsible for urban development and their inability to integrate regional and sectoral plans into a holistic planning framework. 4.1 LAND AND LAND USE MANAGEMENT High urban densification and strain on urban services - One of the key environmental priorities that has been identified through the systematic environmental analysis and stakeholder consultation process pertains to the high densification of population in already developed areas while leaving out fringe areas from the ambit of planned and structured development. Because of the weak implementation of higher level strategies and absence of proper landuse plans, the growth within the already developed areas have taken place in a random manner, sometimes in contravention of existing development control legislation or by using loopholes in them. As a result, land resources within the city have been put under stress, wetlands within the city have got filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress thereby resulting in a consequent strain on environmental resources and components. Unplanned development in fringe areas and encroachment - With decreasing scope of large area development within the already developed parts of the city, large areas in the developing and fringe areas are being taken up in line with the overall direction set by the higher level urban policies (accelerated growth and new area development in fringe areas). However, in the absence of specific and systematic growth plans for this very large fringe area (compared to the existing urbanised area), the new development runs the risk of being mismanaged. Such development will also happen without the provision of adequate urban services and infrastructure thereby in contravention of the lower level planning framework to be prepared for these areas. As a result, the following would exacerbate the existing priority environmental risks: • Lack of proper urban services and infrastructure for newly developed areas that will prevent its ability to urbanise to the optimal level. • Increase of land prices as a result of speculation and land grabbing making it difficult to accommodate poor and vulnerable sections of the society in these areas. • Indiscriminate land filling could further affect natural drainage channels and sink areas. 34445 –Final – Aug 2007 4-1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Thus, the opportunity for planned and systematic growth is being lost and appropriate intervention at this stage would be beneficial in the long term. 4.2 WATER RESOURCES AND QUALITY 4.2.1 Depletion of Groundwater • It has emerged from the analysis that RAJUK has little or no control on the regional level planning of water supply formulated by DWASA. In the absence of a more integrated planning approach the water supply strategy would primarily be based on the DWASA’s existing plans of continuing dependence on groundwater sources in the short to medium term within the DWASA service area. Outside this area, in the adjoining developing and fringe areas, planning for water supply would continue to be ad hoc in nature and primarily dependant on groundwater sources. In addition, a considerable section of population in these areas would not have access to safe drinking water. Therefore, without integrated planning and enhancing the capability of DWASA to serve larger population across a wider area, there is a high risk of not meeting the total requirement of supplying clean potable water to a large section of the population in the DMDP area. • With present short and medium term plans for water sourcing, depletion of groundwater resources would continue to occur at a very fast rate both within the DMDP and adjoining areas (Singair area to the west of DMDP). This may result in further lowering of levels of groundwater aquifers, a natural resource already under high stress and which will take very long time to recover its original state, if proper remedial measures are adopted. The high rate of withdrawal of groundwater may also result in contamination of sourced water by naturally occurring minerals like arsenic, as is prevalent in many parts of Bangladesh due to underlying geology of the gangetic delta region. The continuous sourcing of groundwater from underlying aquifers may also affect the water sourcing potential of tube wells which play an important role in supplying water to large sections of unprivileged people living in slum squatters. • Long-term plans relating to sourcing of surface water usage may increase the risk of providing unsafe water to end-users, if the river systems from which such water is sourced is polluted from discharge of industrial pollutants or sewage upstream of the intake point. The clean-up of rivers would have to be planned and it would have to include all sources in the river watersheds. If successful, this would lead to greater reliance in water supply from surface water sources which would also reduce the dependence of vulnerable sections of society on shallow groundwater often contaminated, thereby resulting in decreasing environmental health risks. 34445 –Final – Aug 2007 4-2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • With the current DWASA master plans, no special provision has been made for supply of clean drinking water to the vulnerable population living in the slums. These slum- dwellers are forced to pay higher prices for sourcing potable water. Without a specific targeted scheme for water supply to this section of the society their vulnerability to water borne diseases increases, affecting livelihoods and increasing health costs. [iflc17] 4.2.2 Reducing water pollution[iflc18] As discussed in earlier sections, due to critical gaps in planning, institutional weaknesses and lack of resources, the surface and groundwater resources of Dhaka have been severely impacted by industrial growth and urbanisation. If adequate efforts are not made to correct or address the present gaps in the higher plans for treating sewage, industrial effluents and sound disposal of wastes, the risk to the water environment, a key environmental priority, would continue be very high in terms of scale and severity in the short, medium and long term. Some of these impacts, like the contamination of groundwater, would also be irreversible, or would take a very long time to remediate through natural processes. Some of the specific risks to the water environment are briefly presented below: • At present the sewerage network infrastructure being planned by DWASA only takes into account the existing urbanised areas and there are no systematic plans to set up sewerage infrastructure in the developing and fringe areas which are charted for rapid development in the near future. In addition, the five new Sewage Treatment Plants that are being proposed as a part of the DWASA Master Plan are not holistic and do not consider additional sewerage coming in from developing or fringe areas. With new areas getting urbanized, the sewage treatment capacity will soon be overwhelmed resulting in continual pollution of the surface water resources in and around the city increasing the existing risks on surface water quality in the medium to long run. • The approach for effluents treatment presently adopted only looks at end-of-the-pipe treatment after sewage is collected by a dedicated sewerage network. Other non- conventional methods of sewage treatment like oxidation ponds, biological treatment through pisciculture ponds, etc. which are being practiced in similar socio-economic conditions in cities like Kolkata, India could be considered for replication. Furthermore, experiences of operating conventional treatment plants by sector agencies such as DWASA in developing economies have not yielded desired results and many such plants are not run efficiently because of lack of monitoring or proper maintenance of the facilities. This also aggravates the risks of water degradation in the medium to long run. 34445 –Final – Aug 2007 4-3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • Presently, the plans for industrial effluent treatment and water pollution control being formulated by the industry associations and the Department of Environment stresses on combined treatment of effluents generated by industry clusters. If implemented properly, this arrangement would enable industrial sectors like tanneries and dyeing units to treat their wastes in a common facility against payment of user charges and thus create a system to reduce pollution load being discharged into surface water. However, as a strong institutional setup will be required to construct, operate and maintain such common effluent treatment infrastructure along with proper monitoring from DOE, there remains a risk to surface water contamination Without the implementation of adequate capacity building and institutional strengthening for management water and urban development. • There are number of small and medium units which are not clustered and discharge their effluents into common sewers. A CETP is not feasible and relocation of these small and medium units would also be difficult considering their limited financial capacity. Thus these units would continue to pollute unless some concrete measures are taken to rehabilitate them in areas with adequate infrastructure to treat their wastes before discharge into surface water bodies or schemes developed to help these units to adopt cleaner technology. • To ensure efficient management of solid waste DCC has undertaken the “Clean Dhaka� project which targets collection and disposal of solid waste. This would improve efficiency of collection of solid waste thus positively impacting the water quality of the inland water bodies. However, the Clean Dhaka project is limited to the DCC area and no similar initiatives have been taken in the remaining parts of the DMDP. Thus risks of pollution of surface water from improperly managed waste dumps and open landfills would continue in such areas. In addition, the absence of guidelines for management of municipal solid waste as well as for biomedical and hazardous waste seriously impedes the development of technically sound waste disposal systems. The risks of pollution of both surface and groundwater would thus continue in the DMDP region even though the “Clean Dhaka� project is implemented. • The Clean Dhaka SWM project places an overall stress on the “landfill based approach� which might turn counterproductive as most of the land in the region is prone to floods. The risks would further be aggravated since the local bodies other than DCC have limited technical and financial resources to undertake initiatives of such nature. Regional cooperation involving City Corporation and the Pourashavas for solid waste management however is difficult because of political-governance reasons. As a result, though there would only be limited opportunities from better collection of waste and lesser littering, 34445 –Final – Aug 2007 4-4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment the risk to surface and groundwater resources would continue due to improper waste disposal practices. Though the DAPs are expected to plan for local level sewage and wastewater collection systems before being drained into surface water bodies, the risk to surface water bodies cannot be reduced without proper integration or interface with the larger DWASA collection and treatment systems within their service area. This would require the DAP consultants to work in close collaboration with DWASA before giving shape to local level sewerage and waste water treatment systems. In areas outside the purview of DWASA, DAP consultants would have to suggest a combination of treatment suited to the respective DAP zone concerned. The onus of cleaning up existing clusters of polluting industries lies with the DOE and industrial associations. The formulation of DAP is an opportunity to initiate dialogue between DOE and industry as to the appropriate location of future industrial zones. An opportunity that, thus far, has not been taken advantage of due to lack of institutional coordination and an integrated development planning framework for Dhaka. 34445 –Final – Aug 2007 4-5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 4.3 FLOODING AND DRAINAGE 4.3.1 Increasing Vulnerability to Floods The physical location of most of the low lying areas within the DMDP and the proneness of adjacent riverine systems to flooding exposes Dhaka to high flood risks. Engineering plans in the form of embankments have been able to considerably reduce the effect of flooding in the main city. New proposals to build more such embankments on the eastern side of the city are presently under consideration. Though this engineering solution has certain inherent advantages, other factors discussed below continue to increase the risk of flooding in Dhaka. Effects of climate change may also appear and long-term impacts of related phenomena are likely to be higher water levels and more frequent incidences of flooding and submergence. • The proposed flood management plans in the form of the eastern embankment cum multi purpose project overemphasize engineering solutions without adequately considering the capacity of natural water bodies to absorb excess flood water and the need to establish some kind of connectivity among existing water bodies for water within the city area to flow out during floods. The implementation of the embankment will impede natural drainage patterns and will intensify flooding in the areas within DMDP lying to the east of the Balu River. Similar effects have been experienced in Tongi River where the intensity of flooding has increased on the other side after the construction of the western embankment. Therefore, the eastern embankment may help to reduce flood risk for a limited area (west of the Balu) in the short term, but may prove counterproductive in the long term from the point of view of other areas located on the fringes of the DMDP. Also, in the case that this embankment is breached because of a high intensity flooding event, it would result in severe flooding within the city. • The cause of urban floods in Dhaka is also as a result of the city loosing its capacity to absorb high intensity rainfall. The loss of the low-lying areas, progressive blocking of inland water bodies and drainage channels to drain excess water have together resulted in the city loosing its sink capacity. Implementation of the regulation for protection of these areas has been weak as most of these wetlands and drainage channels have not been demarcated and notified primarily due to political-economy considerations. Even though the DAPs are expected to demarcate the water bodies, open spaces and playgrounds absence of clear guidelines for identifying them would limit the identification process. Thus, with the loss of existing wetlands and low lying areas, resultant risks associated with water logging and urban flooding would continue to aggravate. As the DAPs would concentrate on their respective areas for planning, it is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risk in the entire 34445 –Final – Aug 2007 4-6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment DMDP area. Even the identification of flood retention ponds which figure in the scope of the DAPs would be difficult to undertake on a compartmentalised planning area basis without proper regional studies that take into account the extent of urbanisation and an assessment of land that can be made available for development of such retention ponds. 34445 –Final – Aug 2007 4-7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 5.0 SEA FINDINGS AND RECOMMENDATIONS 5.1 BACKGROUND One of the main objectives of this study was to assess the process of formulating the Detailed Area Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the environmental priorities identified by this SEA could be incorporated in these plans. As the SEA progressed, it became evident to the SEA consultants that the whole process of preparing the DAPs, was from the start, handicapped by existing systemic shortcomings. These shortcomings were grouped under two headings: 1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated urban planning framework. Additionally, there is a lack of any stated mechanisms for coordinating with other sectoral agencies and their planning processes; and 2. Problems at the implementation level: These are poorly informed plan preparation process; inappropriate survey design and inadequate allocation of technical resources by RAJUK. This has led to over-ambitious Terms of Reference for DAP preparation. Extensive review of these categories of shortcomings was undertaken. This informed the identification of environmental priorities to establish the scope of building into the DAPs, strategies to address these priorities. Institutional and plan analyses, the review of the DAP planning process, and the complexity of environmental problems led the SEA team to conclude that the current process of DAP preparation would not be able to deliver the expected outcomes. By August 2007, progress would have been made on demarcation of plan boundaries, but no plans would have been formulated. This chapter first gives a summary of the findings of the SEA relating to the shortcomings and policy gaps at strategic, urban and local levels which will continue to prevent the satisfactory development of local area plans. It then highlights the environmental priorities that need to be addressed by DAP. The chapter concludes with the recommendations which are based on the findings of this study and flags the issues which need attention. Contribution of this Strategic EA: This study has shown that successful completion of most of the tasks assigned to DAP consultants is contingent on strategic decisions being taken at institutional and regional level. Concurrently, it has identified areas for capacity development; provided pointers to inform/reform the planning process; and to improve the links so that planning at DAP level can successfully complete the tasks assigned. 34445 –Final – Aug 2007 5-1 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 5.2 SUMMARY OF SEA FINDINGS The findings are presented under the two groups noted above. 5.2.1 Shortcomings and Gaps at the Strategic Level The Structure and Urban Area Plans do not provide land use zoning principles and guidelines that are currently applicable. There are contradictions and lack of clear definitions. The Plans demarcate broad areas for future development. However, there are inherent contradictions/loopholes as in some cases the areas marked for development are low-lying and act as sinks during the wet season. Since there are few notifications of land-use of fringe areas, it provided scope for manipulation and encroachment. Guidelines have been provided in the Plans with respect to development of housing for the low income groups and community participation in planning. However, there are no directives in the Structure Plan for implementing these guidelines, hence they have been ignored by the implementing agencies. Moreover, these plans have become dated and have limited relevance to resolving the present urban management problems. The sectoral policies in the Structure Plan do not relate to the urban planning aspects. As result the sectoral policies run as a parallel process with a weak interface to urban and regional development plans. Most sectoral plans concentrate on finding localised and short term solutions to urban problems, particularly within the DMDP. RAJUK by its constitution, however, has the power to coordinate with the sectoral agencies whose plans affect the urban area. There has been a failure of leadership. Implementation of urban and regional plans needs considerable co-ordination and collective design and decision making with all agencies working together. There are no stated mechanisms for co-ordination or any over-arching planning framework which would have enabled agencies to collaborate and co-ordinate their plans. The result has been fractured, haphazard and environmentally unsustainable urban spread and inadequate infrastructural development. The strategic level plans did not tackle the problem of multiple administrative authorities within the DMDP and how their developmental efforts could be managed at the regional level. Thus, the overall problems noted above are exacerbated by fact that DMDP is carved up into smaller administrative units (municipalities and Pourashavas). In many instances, sectoral agencies do have the mandate to provide services throughout plan area. A result some areas get excluded. However, of greater concern is that piecemeal planning and un-coordinated infrastructure development is taking place, often to the detriment of long-term environmental sustainability. 34445 –Final – Aug 2007 5-2 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The haphazard growth is further reinforced by the national funding mechanism. Development planning, including urban projects, in Bangladesh is done through the Annual Development Programmes (ADP) for each financial year. Development projects are initiated at the level of government agencies, divisions, departments, local government bodies. These are then channelled upward to the relevant ministries, and then to the Planning Commission if necessary. The administrative ministries concerned are authorized to approve projects involving costs up to a designated level. Projects involving costs beyond that level are recommended to the Planning Commission for consideration, approval and allocation of funds. The outcome of both these procedures is that no one has an urban overview of what is happening on the ground. Clearly urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic approaches to development; multiplicity of orthocentric agencies; collusive relations between government agencies and vested interest groups; low levels of environmental awareness among sectoral and local authority planners; and very limited effort to achieve real public good. The five teams of DAP consultant appointed by RAJUK have no higher level guidelines for local area plan formulation; no framework for developing a coherent regional approach; no mechanism to coordinate the plans of adjoining local authorities; and limited ability to deal with large sectoral organisations like DWASA or with local authorities who are antagonistic to RAJUK. 5.2.2 Plan Development and Implementation Issues The Detailed Area Plans were conceived as the third and lowest tier of the DMDP planning hierarchy. As per the design laid down in the preparation document of Structure Plan, Master Plan and Detailed Area Plan for Dhaka, the DAPs were expected to be prepared in-house by RAJUK after adequate planning capacity had been built up. Due to institutional failures and reluctance to develop its internal planning capacity, there has been a 10-year delay. DAP preparation was finally outsourced to consultants in 2005 and is expected to be partially completed by August 07. For the purpose of DAP preparation, the entire DMDP area had been divided into 26 Special Planning Zones (SPZs) and was later consolidated to form 5 planning areas (see Table 3.1). The work has been awarded to four firms of consultants. The problems at the implementation level relate to (i) planning capacity. These include insufficient groundwork, inadequate research and understanding of urban planning in RAJUK; and poor design of the DAP process; (ii) the competence of the DAP consultants; and (iii) poor support and leadership from the Technical Committee charged to oversee the plan preparation process. Each of these is briefly summarised below. 34445 –Final – Aug 2007 5-3 SENES Consultants Limited Dhaka-Strategic Environmental Assessment (i) Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened, was gradually downgraded and to this day the Planning Department remains technically understaffed. Moreover, there has been no updating or enhancement of qualifications of the current planners. Their notions of urban planning are technocentric, dated and complexities of social planning do not sit easily in their thinking. In fact they were ill-equipped to design the DAP preparation process. Consequently, the Terms of Reference are over-ambitious. The technical resources allocated are inadequate and behind the times; for example, the Geographical Positioning System is not used to determine coordinates of boundaries; it was done manually leading to mismatch of boundaries drawn by two groups of consultants and consequent delays. Moreover, the planners have not provided any guidelines to the consultants for demarcation of environmentally sensitive areas where urban development should be restricted. These include wetlands, flood flow zones, retention ponds, canals and natural drainage channels. There is thus, the danger that the DAPs could further exacerbate the problems of urban environmental management. Furthermore, in the absence of any directives, and reflecting the generally low environmental awareness, the DAP consultants appear to have limited understanding of the pollution-intensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. Of greater concern is that the DAP preparation is not guided by any strategic level planning framework. This means that the five groups of consultants are each contained within their own zones, rather than within a regional approach. This means that piecemeal development will continue even under the new plans. (ii) Challenges of DAP consultants. In view of the complexities involved in formulating the DAPs, the team concludes that the local consultants selected for this purpose do not appear to have comprehensive technical capability and the experience to complete the tasks. What is also surprising is that the consultants did not question the Terms of Reference or whether the outputs were achievable in the given timeframe and with the resources allocated. (iii) Poor leadership of the Technical Committee: The DAP planning process was found to have a very weak interface with the sectoral planning agencies and as a result, is unlikely to produce plans that can be integrated with the sectoral strategies and plans. This is because (a) the Technical Management Committee which is charged to oversee plan preparation has been ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared; and (b) the DAP consultants have also been unable to establish useful contacts with sectoral agencies to 34445 –Final – Aug 2007 5-4 SENES Consultants Limited Dhaka-Strategic Environmental Assessment address the sectoral issues of the local level plans. In addition, many of the sectoral plans do not cover the entire DMDP area, especially in the fringe areas. The DAP consultants working in these areas do not have access to any sectoral planning guidelines. 5.3 ENVIRONMENTAL PRIORITIES THAT NEED TO BE ADDRESSED BY DAP The importance of getting the DAP planning process right is underscored by serious environmental problems already affecting Dhaka and its surrounds. The environmental priorities as identified by this study are given below. 5.3.1 High Urban Densification and Land use Management Increasing overcrowding in the already developed areas: The growth within the already developed areas has taken place in a random manner, sometimes in contravention of existing development control legislations or by using loopholes in them. As a result, land resources within the city have been put under stress, wetlands within the city have got filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress resulting in significant strain on environmental resources. Unplanned development in fringe areas and encroachment: With decreasing scope for inner city growth, large areas in the environmentally sensitive fringe zone are being targeted as they have been marked for development in the Structure Plan. Additionally, in the absence of any detailed and systematic growth plans the new developments run the risk of being mismanaged. It is expected that these developments will also be without adequate provision of urban services and infrastructure. Such areas have also seen an: • Increase in land prices as a result of speculation and land grabbing making it difficult to accommodate poor and vulnerable sections of the society in these areas; and • Indiscriminate land filling which could lead to loss of natural drainage channels and sink areas and increase the vulnerability to flooding. 34445 –Final – Aug 2007 5-5 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 5.3.2 Water Resources and Quality Surface water Pollution: The river systems and the water bodies in the Dhaka Watershed are so contaminated by discharge of industrial effluents and untreated sewage that it cannot be treated to potable standards. The problem of industrial pollution has to be addressed by DoE. It is also being addressed by the World Bank under DIEWRMP. The role of the DAP lies in initiating a dialogue with industry and a process to identify locations for future industries. Reliance on, and Depletion of Groundwater: As surface water cannot be used to supply drinking water, DWASA has become increasingly reliant on abstracting groundwater. Additionally, as the supply is unable to meet the growing demand, there has been an increase in number of privately owned tube wells. Local authorities outside DWASA area are also dependent on groundwater. Continued abstraction over a long period could lead to contamination of groundwater. RAJUK and DAP have no say in DWASA’s Master Plan. Furthermore, DWASA has made no provisions in its plan to supply the slums areas. 5.3.3 Inadequate Sanitation and Sewage Network At present, the sewage network infrastructure being planned by DWASA only takes into account the existing urbanised areas. There are no systematic plans to set up a network in the developing and fringe areas which are marked for future development. In addition, the five new Sewage Treatment Plants that are being proposed as part of DWASA’s Master Plan do not consider additional sewage coming in from developing or fringe areas. As a result, with new areas becoming urbanized, there will be continued discharge of untreated sewage resulting in continued pollution of the surface water resources in and around the city. DAP preparation process could be used as an opportunity whereby a more comprehensive network covering future growth areas could be designed if DWASA, RAJUK and DAP consultants found a common platform. 5.3.4 Increasing Vulnerability to Floods The increased vulnerability to flooding as been documented in this report and elsewhere. As far as the role of DAP preparation is concerned, the consultants would concentrate on their respective areas for planning. It is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood retention ponds, which are central to local area plans, would be difficult to undertake, given the compartmentalised planning approach. 34445 –Final – Aug 2007 5-6 SENES Consultants Limited Dhaka-Strategic Environmental Assessment 5.4 RECOMMENDATIONS In keeping with the objectives of the study, the recommendations have focused on improving the DAP planning process. These have been subsumed under two groups indicating the urgency of action required. Action in Short Term 1 Develop a DMDP region landuse map; demarcate and publish notification of ecologically/environmentally sensitive areas It was heard several times during the final consultation workshop from all quarters that there was no comprehensive land-use map of DMDP Region and there was a definite need to create a document that depicts all the land uses, demarcates eco-sensitive areas, and indicates potential development areas with different landuses like industrial, agricultural, residential, mixed landuse, etc. Further, loose planning guidelines and loopholes in the Structure and Urban Plans have allowed the urban encroachment of environmentally sensitive areas which include flood flow zones, wetlands and low-lying areas which act as sink for storm water runoff; natural drainage channels and canals. The local area plans cannot progress unless these areas are clearly identified, demarcated and notified. The proposals and plans on how this demarcation should take place already exist with the responsible agencies and Boards. To overcome this problem, the development of a DMDP Regional Land Use map should be a priority. This map should clearly demarcate eco-sensitive areas and these should be notified. This action is required on top priority to ensure no more filling of wetlands, destruction of agricultural lands, and continued haphazard growth of the DMDP Region. This comprehensive exercise should be undertaken immediately as the DMDP development with existing outdated Structure and Area Plan and under development DAPs will not be comprehensive and will likely repeat mistakes of the past planning processes. This DMDP Region Plan should be developed in consultation with all the sectoral and local planning bodies. However, the local plans will be only guidelines and will be finalised by individual local governments like Pourashavas, Union Porishads at the local level. 2 Resolve conflict arising from the multiple functions of RAJUK RAJUK has been very active in promoting and participating in the development of commercial properties like shopping centres and malls. While these developments have 34445 –Final – Aug 2007 5-7 SENES Consultants Limited Dhaka-Strategic Environmental Assessment been lucrative for both RAJUK and the private developers, they have often overlooked the planning guidelines and encroached on environmentally sensitive areas. Clearly, there is conflict of interests between RAJUK’s role as a promoter and its role as the principal agency for urban development. This issue can be resolved only by either divesting RAJUK of all its developmental responsibility and making it an exclusive planning and monitoring body; or, RAJUK can be a development body and a new authority should be created to carry out the planning and monitoring function. An institutional assessment needs to be carried out to define the mandate of the proposed agency, its location within the myriads of agencies, ministries and authorities that exist in Dhaka/ Bangladesh and how it will function. However, this authority has to be able to get support and cooperation of various sectoral agencies and should be able to control and monitor the planning of entire DMDP region. 3 Strengthen the DAP planning process as there is too much at risk The detailed area planning process is incomplete, hence, there is still an opportunity to improve the process and achieve some of the stated objectives. Real value addition to the process will take place if the capacity for environmentally sustainable and socially sensitive planning is enhanced in RAJUK as it is the lead agency. Additionally, consultants with more appropriate skill sets need to be appointed. Plan formulation needs a team with better technical know-how, better understanding of the complexities of urban planning, and which has a critical approach to project execution. The point is to build on the work that has already been completed in the last two years. One of the main problems faced by the present consultants is that they are unable to work with/ have access to, the sectoral agencies. The membership of the Technical Committee, who is charged to provide the link, should be re-assessed for effectiveness and if necessary, changed. The modus operandi should be made more transparent and information on progress and outcomes disseminated. This can be achieved by engaging stakeholders more effectively and communicating decisions at various levels to public and key stakeholders so that the process remains open and accessible. The leadership of RAJUK needs to be more active in the process. The inability of RAJUK to play a leadership role in the past has led other agencies to take planning initiatives on their own without any coordination with RAJUK. It is clear that constitutionally the organisation has considerable power but has rarely used it for systematic urban management. RAJUK needs to re-direct its energy to facilitate the work of its consultants with sectoral agencies and other local authorities. This will not be easy 34445 –Final – Aug 2007 5-8 SENES Consultants Limited Dhaka-Strategic Environmental Assessment as the latter have developed their internal procedures and these procedures exclude any interaction with RAJUK. It will therefore, be essential to enable and encourage RAJUK to liaise with other agencies and open doors for the DAP process. The issues of slum area development and provision of low income housing are not being addressed either by RAJUK or any of the other sectoral agencies. This means that land allocation and infrastructure planning for these areas might not feature in local area plans. One of the responsibilities of RAJUK is the provision and overview of low income housing. This issue will be part of the institutional reform of RAJUK and will have to be dealt within the scope of that process. 4 Engaging stakeholders in urban planning Throughout this project it has been observed that political economy has played a huge part in the haphazard development of the City of Dhaka. Further, the people with vested interests have been hijacking the process of planning due to lack of transparency. It is recommended that during the reform of the planning process including resolving the conflict of mandate within RAJUK, a transplant process for engaging key stakeholders in the planning of regional areas should be put in place. o As pointed out in the workshop, the “ward committees� at the Pourashavas level have been quite effective at engaging local community in local planning initiatives. Similar initiatives are required at Dhaka and municipal level. o Further, transparency can be achieved if the DMDP region landuse plan with demarcation of ‘no development zones’ is notified and made available to the public. The public can use this information and stop illegal development. Public can approach judiciary if necessary to stop development in the no-development zone. 5 Bring other actors on board Crucial to the success of formulating local area plans is the participation of local authorities. An entry point for dialogue with these authorities could be programmes for capacity building in environmental planning and regional development. Thought needs to be given to what would be the most efficacious way of doing this. DWASA is one of the biggest players in the provision of urban infrastructure. Currently there is very little communication between the two organisations and RAJUK has little 34445 –Final – Aug 2007 5-9 SENES Consultants Limited Dhaka-Strategic Environmental Assessment say in the Master Plans developed by DWASA. It will be important to bring DWASA, RAJUK and the DAP team to a common platform. The flood management strategies expectedly should have a regional approach. However, there are measures which need to be put in place and actions taken at the local level to achieve overall reduction in vulnerability to flooding. These include among others, freeing up encroached canal systems, rehabilitating flood retention ponds, improving connectivity between water-bodies etc. In order to incorporate such measures in the DAPs, it will be necessary for RAJUK, LGED and other principal organisations responsible for management of water resources to work together to assist the DAP team. Actions in Medium Term 6 Develop strategic planning directives for urban growth The DAP formulation process will ultimately rely on a strategic planning framework to provide the directives, tools and guidance. While the local area plans will be important working tools, change will occur and new plans will have to be formed. This strategic framework would be a point of reference for local authorities; for DAP consultants; and for future urban growth for the stated period. It is hoped that the new framework will be coherent, tight and address the inadequacies of the past and current urban planning approaches and processes. 7 Funding procedures for local development projects It has been noted in the report that development projects, which include urban projects, initiated by local governments and local level sectoral agencies are channelled up to the relevant ministry for funding, and further up to the Planning Commission if they are beyond a designated cost level. In either case, the funding provided is based on budgetary criteria. There is no mechanism to ensure that the project has been environmentally appraised or the sustainability of such projects has been established. Furthermore, there could be duplication of effort in two adjoining authorities leading to waste of valuable resources. For long-term environmental sustainability, it will be important to address this problem. This requires the mainstreaming environmental issues prior to initiating any systemic change. The Environmental Assessment regulations already exist in Bangladesh and linking funding to the EA approvals maybe one of the approaches that maybe considered. 34445 –Final – Aug 2007 5-10 SENES Consultants Limited Dhaka-Strategic Environmental Assessment APPENDIX A FINAL CONSULTATION WORKSHOP PROCEEDINGS 34445 –Final – Aug 2007 5-11 SENES Consultants Limited Dhaka-Strategic Environmental Assessment Final Consultation Workshop on Strategic Environmental Assessment of Dhaka Metropolitan Development Plan 16 August 2007 Venue: Dhaka Sheraton Hotel WORKSHOP PROCEEDINGS The Final Consultation Workshop on the SEA was held on 16 August 2007 at Dhaka as the final round of consultations with key stakeholders to discuss the draft Final Report of Strategic Environmental Assessment of DMDP and to seek concluding feedback. Workshop Objectives The principal objectives of the workshop were as follows: • Apprise stakeholders of the findings and recommendations of the Strategic EA study; • Develop broad consensus on the recommendations with the stakeholders of concern; • Explore potential for assessing whether a consensus existed for setting up a regional (DMDP wide) strategic planning authority; and • Discuss ways to kick-start institutional reform and carry out strengthening of key urban planning agencies responsible for planning and plan implementation in the DMDP region. Inaugural Session The workshop commenced with a recitation of the Holy Quran. This was followed by the inaugural address of Chief Guest, Mr A S M Rashidul Hai, Secretary, Ministry of Housing and Works. Mr Hai accepted in his speech that urban planning in Dhaka is presently constrained by a number of systemic shortcomings including lack on planning capacity within the apex planning agency RAJUK; inadequate coordination between various agencies; absence of land use zoning; and the non-existence of an overarching planning guidelines and planning document to guide urban development. This has resulted in fractured, haphazard and environmentally unsustainable urbanisation of Dhaka. He also opined that it was unlikely for the DAPs planning process alone to solve the present problems of lack of urban infrastructure and associated environmental degradation until some action is taken at the strategic level to 34445 –Final – Aug 2007 5-12 SENES Consultants Limited Dhaka-Strategic Environmental Assessment provide overall direction to urban planning in Dhaka. He said that such strategic planning needs to consider the entire DMDP area for dispersal of population, setting up of crucial infrastructure like sewage treatment plants or looking at ways for flood protection and control, keeping in mind long-term scenarios. He also pointed out current scenario was unacceptable and the proposed changes provided an opportunity to build improvements that promote environmentally sustainable and socially sensitive planning. Importantly, he also conveyed that the Government was prepared to consider appropriate reform in the institutions that play a key role in urban planning for Dhaka and also improve their planning capabilities through systematic strengthening and capacity building. He noted that the workshop was represented by members of key stakeholder groups and wanted it to be the platform to discuss the need for such new approaches and try and arrive at a consensus for taking the recommendations forward. Chief Guest Mr A S M Rashidul Hai delivering his address in the Inaugural session In her welcome address to the workshop by Ms Nayeema Khatun, Project Director SEA, she provided a brief outline of the planning process within the DMDP area and the presently ongoing DAP plan preparation process. She stressed on the need for environmentally-sound planning and underlined that this has prompted RAJUK in initiating this study with support from the World Bank. She explained that the SEA study was intended to undertake a detailed review of the existing DMDP and sectoral plans, understand their linkages with priority environmental issues and complement the DAP preparation process by providing an overall environmental framework for the DAPs. She requested the participants to come forward with opinions on the findings and recommendations of the study after reviewing the Executive Summary provided to the participants. She also expressed hope that the deliberations of the workshop would go a long way in drawing up inclusive and participative Detailed Area Plans in close collaboration with various other sectoral agencies and administrative authorities and would help the city to grow and prosper in an environmentally sustainable way. Dr A K Ghosh, Senior Environmental Specialist of SENES briefly outlined the approach taken by the study team and explained the key conclusions reached. He explained that the that the priority environmental issues and constraints in the city of Dhaka were related primarily to the use of land and 34445 –Final – Aug 2007 5-13 SENES Consultants Limited Dhaka-Strategic Environmental Assessment water resources and how their management have been factored into the recommendations that have been proposed by the study. He stressed on the need for drawing up a regional planning perspective taking the entire DMDP area and the immediate need for mapping of the present landuse and the establishment of a landuse control system for the city. In his inaugural speech, special guest to the workshop Mr A H M Rezaul Kabir ndc, Secretary Ministry of Environment & Forest briefly referred to the magnitude of the environmental problems present in Dhaka and pointed out that many of these environmental problems being encountered were a direct result of decades of unplanned and haphazard growth that the city has witnessed with scant regard to environmental considerations and issues. He noted that though the country had established project level EIA system, it has not worked to the satisfaction of the Ministry to be an effective mechanism because of the lack of proper monitoring and enforcement machinery within the government. In this context, he observed that higher-level (strategic) environmental assessments can play an important role to help decision makers to take important urban planning decisions that would help in arresting further environmental degradation in Dhaka and make progress towards building a cleaner and sustainable city that will provide it residents with a better and healthier quality of life. In his inaugural speech, the Guest of Honour, Mr Xian Zhu, Country Director, The World Bank expressed his satisfaction at the way that Bangladesh is making steady progress with regard to a number of development indicators and said that the World Bank is extremely happy to be a partner in its advancement. He observed that the SEA study has played a crucial role in highlighting the gaps in the planning process and the institutional weaknesses that have hindered the planned development of the city in accordance with DMDP formulated in the early nineties and have brought into focus high potential risks to the environment and the vulnerable sections of the society. For example, he said that the study has pointed out the high risk of flooding to certain fringe areas of the DMDP can be further aggravated by climate change impacts in the medium to long term and has consequently highlighted an urgency to draw up integrated regional plans accounting for the entire DMDP area. He also noted that the study has also pointed out a need for institutional reforms and strengthening of key planning agencies like RAJUK in order to ensure that urban planning in Dhaka is undertaken in a holistic manner and factoring the requirements of the weaker sections of the society whose interests have been neglected in the current planning process. The World Bank, he said, would be happy to support the Government of Bangladesh in this process. After this, a detailed presentation was made by Mr Debanjan Bandyopadhyay, Deputy Team Leader of the SEA Team on the findings and recommendations that have emerged from the study. He explained the specific objectives of the study and the methodology adopted. In doing so, he explained the reasons for the study to have metamorphosed into an “institution-centric� study from an environmental one. He elucidated the four priority issues that were short listed based on technical analysis and after receiving inputs from stakeholders on the environmental issues. Subsequently, the significant risks arising as a result of the gaps in the existing planning framework, weaknesses in the institutional setup and political economy considerations were explained. The high risk of progressing with the DAPs without having a higher level strategic planning guidelines based on current landuse and proposed landuse were also 34445 –Final – Aug 2007 5-14 SENES Consultants Limited Dhaka-Strategic Environmental Assessment highlighted. This was followed by a presentation of the recommendations and requested the participants to freely speak up as the SEA team was open to receiving suggestions and feedback on both the findings and the recommendations of the study. Subsequently, Mr M A Qasem, Director General, Local Government and Rural Development said in his speech that he agreed with the findings of the SEA and many of the key environmental problems are influenced by political economy factors and little coordination between institutions responsible for plan implementation and monitoring. He observed that until some interventions were made at high level, finding solutions through “end-of-the-pipe� methods after the problems have already been created as result of faulty planning or inadequate coordination between institutions would only be superficial and is unlikely to solve the issues. He concluded by saying that there is a need to explore ways through which such coordination between RAJUK and the Dhaka City Corporation, Pourashavas and Sectoral Agencies like DWASA can be effected and agree on whether the Government should consider setting up of a higher level body to provide leadership in this regard or strengthen existing institutions appropriately to improve their planning capabilities and establish better systems for bringing about effective collaboration between all concerned departments and agencies. The inaugural session of the workshop was chaired by Mr K A M Haroon, the Chairman of RAJUK. In his concluding remarks to the inaugural session, he thanked the distinguished speakers for being present at this important workshop and for expressing their views on the SEA study. He noted that the deliberations at the inaugural session have confirmed that if proper thought is given at the planning and decision making level, many of the environmental problems of Dhaka can be solved more effectively. He also observed that if the strategic assessment had been undertaken earlier, it may have resulted in better understanding of the weaknesses in the planning system and prevent some of the environmental damages that have already taken. After taking note of the earlier discussions, he was in broad agreement with the study’s recommendations and hoped that they can help in making necessary corrections in the DAP preparation process that are presently underway and also requested considering the establishment of a regional planning authority to guide the DAP consultants and associated sectoral agencies in carrying out the planning task effectively and efficiently. Before concluding the session, he also thanked the World Bank to support such a study. Technical Session The participants were divided into two groups to discuss the following two topics. After an hour and half of discussion the groups came back and presented their consensus on taking this study forward: Group A: Strategic Environmental Planning Framework for Dhaka • The need for a higher level urban policy for delineating broad directions of growth, based on assessment of existing landuse in the DMDP, was felt required to adequately guide the local level DAP planning process. 34445 –Final – Aug 2007 5-15 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • It was discussed that the present DAP consultants would be able to complete the DAP formulation process with existing capabilities, in spite of certain hurdles being faced. The participants requested the SEA consultant to bring out the positives of the DAP planning process. • Opinion was expressed by the DAP consultants that the Terms of Reference for the DAP planning studies need to be modified taking into consideration ground level planning requirements and constraints. • The planning capabilities of RAJUK should be strengthened and in spite of the apparent weaknesses, it was agreed that with proper capacity building, it can play an important role in the urban planning process of Dhaka. • However, the group also agreed that RAJUK should not be responsible for both planning in the area as well as in developing projects. This was viewed as being in conflict of interest. It was pointed out RAJUK was more keen on development as it yielded more revenues. • A pressing need was felt by the group to improve coordination between RAJUK and the various sectoral and utility organisations that play a role for the development of Dhaka. Group Discussions in the Technical Session in progress Group B: Engagement of Stakeholders in Urban Planning • Three levels of engagement were proposed by the group: o National level for developing policies and guidelines in urban planning for the country; o Regional Level – DMDP for developing regional level plans based on a national strategy; and o Lastly, local level engagement through ward-committees and other mechanism; • There was consensus that Television was the media of choice for creating awareness amongst the Bangladesh masses and this media was never used to let people know what was being proposed for DAPs. The recommendation was to make se of this media for awareness building and seeking feedback. 34445 –Final – Aug 2007 5-16 SENES Consultants Limited Dhaka-Strategic Environmental Assessment • Other media like Internet websites should also be effectively utilized for seeking feedback. • There was a strong need felt for building awareness among all sections of society including government agencies, NGOs and public on environmental sensitive areas and how the unplanned infrastructure development was causing problems on several front including water pollution, floods, poor air quality etc. This was felt necessary for the public to effectively provide feedback as well as fight the system to ensure this does not go on. Panel Discussion Professor Nazrul Islam, the Chair for the panel and a distinguished urban planner, set the tone for the discussions by briefly relating his appreciation of the progression of urban plans for the city of Dhaka. Taking part in the discussions, Mr Md. Nasiruddin, RAJUK, Member Planning accepted the weaknesses in RAJUK that were pointed out in the study and the need to take the opinion of experts present to bring in necessary reforms in the planning system and within RAJUK. He said that in spite of the apparent lapses, with appropriate support from other agencies and with proper reinforcement of planning capacity, RAJUK as the key agency can play an important role to undo some of the environmental damage that has already been done. Expressing his views, Dr. Ainun Nishat, Director - IUCN pointed out that the SEA consultations should have been more encompassing and thorough. He expressed the need for protecting existing environmentally sensitive areas like wetlands and other natural habitats with the city through proper landuse zoning and implementation of landuse control plans. Prof Nazrul Islam expressing his views at the Panel Discussion Dr A K Ghosh referred to a case study from Kolkata where the east Kolkata wetlands, now a Ramsar declared protected site, and adjoining agricultural fields, played an important role in the urban ecology of a large metropolitan city. He expressed the opinion that such approaches need to be considered at the 34445 –Final – Aug 2007 5-17 SENES Consultants Limited Dhaka-Strategic Environmental Assessment highest strategic level before deciding upon the development and landuse of about 1000 km2 of fringe areas of Dhaka which comprise primarily of agricultural areas, flood flow zones and wetlands. Mr K M Minnatullah from the World Bank noted that the World Bank is planning to take an integrated program for improvement of water quality in the entire Dhaka watershed through the DWINRP project and the overall urban plans of the city has to be drawn up in a manner that it complements the project. As a result, he felt that the RAJUK would have to play the role of an important stakeholder in the project and the World Bank is ready to extend support to RAJUK and build necessary capacity within the organisation. Mr Murali Ganapathy from SENES clarified requests of various stakeholders on why only four priorities were presented in the Executive Summary and that air quality, noise, transportation and industrial pollution were all discussed in the detailed report. He further highlighted that implementing a strong environmental impact assessment system and procedure for infrastructure projects can address key environmental impacts of key urban infrastructure projects and at the same time result in increasing public awareness and participation in the development process. The panel discussion concluded with Prof Nazrul Islam summarizing the individual speakers and stressed on the following key issues: • Developing a regional urban planning guidelines to ensure uniformity all across the region; • The need to draw up a landuse plan for DMDP region highlighting all key sensitive areas; • Removing the current conflict of planning and development by the same agency; and • Carry out adequate reform of RAJUK and reinforce its capacity to undertake planning and monitoring effectively. The Workshop was concluded with a Vote of Thanks by Mr Neaz Rahman, SEA Team Leader. He thanked all the distinguished guests and the stakeholders for providing the SEA team with the benefit of their views and felt that this feedback will immensely help in further refining the final report of the study. 34445 –Final – Aug 2007 5-18 SENES Consultants Limited Dhaka-Strategic Environmental Assessment News Coverage of Workshop: The Daily Star Incorporate environmental issues into city’s dev process Speakers tell workshop Staff Correspondent Speakers at a workshop have underscored the need for incorporating environmental issues into the city’s overall development process to enhance the quality of life of its dwellers. The workshop titled ’Strategic Environmental Assessment of Dhaka Metropolitan Development Plan’ was held at a city hotel on Thursday to disseminate the objectives of Strategic Environmental Assessment (SEA). The government has proposed the SEA for Dhaka Metropolitan area to shed light to complex interactions between environmental, social, economic and institutional factors linked to urban planning and development. World Bank is supporting the government in framing the draft SEA, and Rajuk would be the implementing agencies. Terming the urban planning of Dhaka a ’quagmire’ of poor planning process and plans, Dr AK Ghosh, senior environmental specialist, said low level of environmental awareness among sectoral and local planners and very limited efforts to achieve real public good were evident in the urbanisation process. Stressing on bringing other actors like the utility service providers on board, he further said as Rajuk is active in the development of commercial areas like shopping centres and malls, it very often overlooks the planning guidelines and encroaches on environmentally sensitive areas. AHM Rezaul Kabir, secretary to environment and forest ministry, laid emphasis on regional consensus on environmental issues and said a strategic plan to this end may act as baseline policy for future planning of the city. Lauding the timely approach of the government, Zhu Xian, country director of the World Bank, said as urban plans are being formulated for six regions of Dhaka Metropolitan area, it is considered to be an ideal time to undertake an independent assessment about the possible environmental consequences of the implementation of such plans and build corrective measures wherever required. MA Qasem, director general of LGRD, laid emphasis on coordinated and concerted efforts by all the concerned institutions. ASM Rashidul Hai, secretary to housing and public works ministry, KAM Haroon, chairman of Rajuk and Nayeema Khatun, project director of SEA also spoke on the occasion. Debanjan Bandyopadhyay, team leader, made a presentation on draft SEA report. 34445 –Final – Aug 2007 5-19 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The Daily Independent, Bangladesh Unplanned urbanisation responsible for water crisis in city STAFF REPORTER Speakers at a workshop yesterday said that unplanned urbanisation and in discriminate use of underground water are responsible for the recent natural disaster like water logging and water crisis in the city. "The capital city expanded without planning and eighty per cent of the people of Dhaka city lifted their usable water from underground. So, the excessive use of underground water has brought down water level day by day", experts at the workshop said. "Violating laws and the lack of coordination between RAJUK and Dhaka City corporation (DCC) for development activities in city are the main reasons for environmental disaster, the environmental specialists also said. They made their remarks at a workshop on "Strategic environmental assessment of the detailed area plan," held at Sheraton Hotel in the city. The RAJUK and World Bank jointly organised the daylong workshop before publishing its final report. ASM Rashidul Hai, secretary of housing and public works was present as chief guest while AHM Rezaul Kabir, secretary of ministry of environment and forest, Muhammed Abul Quasem, director general of local government division also addressed the inaugural session. KAM Haroon, chairman of RAJUK chaired in the inaugural session. Housing and public works secretary Rashidul Hai said that the political economy of the then governments has created this manmade natural disaster like water logging in the city. "We have taken necessary steps to stop artificial natural disaster like water logging in the city", he added. World Bank country director Xian Zhu presented the keynote paper at the workshop on the draft report of the Strategic Environmental Assessment (SAE) and said that all the residents of Dhaka are to some extent impacted by the deteriorating water level. "The poor people have few options for accessing clean water are the most vulnerable", Xian Zhu said. The overall urban planning process should take strategic planning to prevent the high risk of the flooding in certain areas of the Dhaka", Xian Zhu told the workshop. Dhaka is undergoing massive expansion and its current population of 12 million will increase to 20 million by 2020, making it the world’s third largest city, Khawaja Minnatullah, senior environmental specialist of the World Bank said. Speakers at the workshop suggested introduction of strategic urban planning for Dhaka to promote environmentally sustainable growth of the capital. "Unplanned growth, uncoordinated activities and also unabated environmental pollution-the economic cost associated with environmental degradation may amount to more than four per cent of the total GDP", he added. He pointed out that institutional reforms and strengthening of the key planning agencies like RAJUK is urgent for sustainable urban planning in Dhaka. 34445 –Final – Aug 2007 5-20 SENES Consultants Limited Dhaka-Strategic Environmental Assessment The Financial Express, Dhaka Strategic urban planning must for sustainable growth FE Report Strategic urban planning is urgently needed for Dhaka to promote environmentally sustainable growth of the country as well as of the capital city, according to the World Bank (WB). "Greater Dhaka currently represents more than 40 per cent of Bangladesh’s national gross domestic product (GDP). The overall urban planning process should take strategic planning principles into account to prevent the high risk of flooding to certain fringe areas of the Dhaka Metropolitan Development Plan. Such floodings are likely to be further aggravated by climate change impacts in the medium to long term", said World Bank (WB) Country Director Xian Zhu during a workshop Thursday. A S M Rashidul Hai, Secretary, Ministry of Housing and Public Works, was present as Chief Guest of the workshop on "Strategic Environment Assessment of Dhaka Metropolitan Development Plan," jointly organised by RAJUK and the WB. A H M Rezaul Kabir, Secretary, Ministry of Environment and Forest and Muhammad Abul Quasem, Director General, Local Government Division, also spoke in the inaugural session, chaired by K A M Haroon, Chairman, RAJUK. Dhaka is also undergoing a massive expansion and its current population of 12 million will reach 20 million by 2020, making it the world’s third largest city with unplanned growth, uncoordinated activities and unabated environmental pollution. The economic costs associated with environmental degradation may amount to more than 4 per cent of GDP, said WB’s senior environmental specialist. The unplanned urbanisation has raised two sets of environmental challenges in Dhaka city. The first arises from urban development projects in different sectors and industries which treat potential environmental effects as externalities and only try to mitigate these effects as an afterthought and do not include it as an integral part of their project. The second set of environmental issues stem from the acute pressure on natural resources resulting from the indiscriminate use/misuse of these resources. The government undertook the Strategic Environmental Assessment (SEA), supported by the WB and implemented by RAJUK, to underpin the complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka city. The study found the urgent need for institutional reforms and strengthening of key planning agencies like RAJUK, to ensure that urban planning in Dhaka is undertaken in a holistic manner. 34445 –Final – Aug 2007 5-21 SENES Consultants Limited