36 Environmental Due Diligence
Environmental legislation, such as the Bangladesh Environment Conservation Act, 1995 (amended in 2002) requires that development projects obtain environmental clearances from the Department of Environment (DoE). Under the Environment Conservation Rules 1997 (updated in 2002 and 2003), projects which include construction and expansion of flood control embankments are categorised as ‘Red’, and must have an Environmental Impact Assessment (EIA) study in order to obtain an environmental clearance certificate. The construction works in coastal polders under Blue Gold fall into this 'Red Category', and therefore EIA studies were mandatory.
Objectives of EIA Studies[edit | edit source]
The objectives of EIA studies were to assess the environmental aspects of proposed rehabilitation interventions, specifically by:
- Preparing an environmental and social baseline of the project area
- Assessing potential environmental impacts as well as cumulative, induced and reciprocal impacts for the proposed interventions;
- Identifying mitigation measures to minimise the negative impacts and enhance the positive impacts; and
- Preparing an Environmental Management Plan[Notes 1] which included mitigation and enhancement plans, compensation and contingency plans and a proposal for monitoring activities.
Process for Obtaining Environmental Clearances[edit | edit source]
Guidelines for preparing EIAs for water sector projects were developed by the Flood Planning Coordination Organisation (FPCO) in 1992 and updated by the Water Resources Planning Organisation (WARPO) in 2003. The 1997 guidelines formulated by the Department of Environment (DoE) mainly concerned industrial projects and were of limited relevance to Blue Gold activities. For the purposes of Blue Gold, WARPO's EIA guidelines were adopted, for which the following information was presented in the EIAs:
- Feasibility study
- Initial Environmental Examination
- Environmental Impact Assessment (EIA) report which fully addresses the terms of reference approved by DoE
- Environmental Management Plan (EMP)
- No Objection Certificate (NOC) from the respective Union Parishad.
Environmental Impact Assessments (EIAs) were prepared for each polder[Notes 2]. The BWDB Program Coordinating Director (PCD), in his capacity as the authorised representative of the lead implementing agency, was responsible for submitting the EIAs to the Dhaka headquarters of the Department of the Environment (DoE), which then assigned responsibility to the appropriate DoE divisional office in Khulna and Barisal to review the EIAs, conduct physical verifications, and hold consultation meetings with stakeholders. A positive report on the environmental and socio-economic impact by the DoE divisional office, allowed DoE Dhaka to issue an Environmental Clearance Certificate (ECC).
EIA Preparation[edit | edit source]
The responsibility for preparing the Environmental Impact Assessments (EIAs) was assigned to the Centre for Environmental and Geographic Information Services (CEGIS) for the first 12 polders[Notes 3] during 2015/16. CEGIS was responsible for the whole process of preparing and submitting the EIA to DoE, and obtaining the ECC.
| EIAs Conducted by CEGIS | |||
| Khulna | |||
| 22 | September 2015 | ||
| 26 | June 2016 | ||
| 29 | June 2016 | ||
| 30 | September 2015 | ||
| 31 Part | June 2016 | ||
| Patuakhali | |||
| 43/1A | April 2016 | ||
| 43/2A | June 2015 | ||
| 43/2B | April 2016 | ||
| 43/2D | June 2015 | ||
| 43/2E | April 2016 | ||
| 43/2F | June 2015 | ||
| Satkhira | |||
| 22 | June 2016 | ||
During 2019/2020, BWDB's Directorate of Planning -3 (DP-3) office carried out the fieldwork and prepared EIAs for the remaining 10 polders[Notes 4]. The role of BWDB's DP-3 office included fieldwork, reporting, preparing and submitting the application and documentation to DoE, and defending the submission at the DoE office in Dhaka.
| EIAs Conducted by BWDB | ||
| Khulna | ||
| 6 | 25 | August 2020 |
| 7 | 27/1 | January 2020 |
| 8 | 27/2 | |
| 9 | 28/1 | January 2020 |
| 10 | 28/2 | January 2020 |
| 11 | 34/2 part | January 2020 |
| Patuakhali | ||
| 18 | 55/2A | January 2020 |
| 19 | 55/2C | August 2020 |
| 20 | 47/3 | August 2020 |
| 21 | 47/4 | August 2020 |
The advantage of this second modality is that the implementation of the environmental management plan, adherence to conditions stipulated by DoE and monitoring of environmental compliance are more strongly embedded within BWDB. Future arrangements for institutionalising this function in BWDB are summarised below.
A government department can form a separate EIA cell and obtain DoE's concurrence to conduct an EIA. The cell should - in accordance with 2003 WARPO guidelines - include a water resources engineer, environmentalist, agriculturist, fisheries biologist, socio-economist, GIS Specialist and field researchers. Under the leadership of the BWDB program/project director, the EIA cell could be assigned the study, and be responsible for all aspects of the fieldwork and reporting through to obtaining the DoE ECC.
Notes[edit | edit source]
- ↑ Environmental Management Plan provides plan for the pre-construction, construction and operation phases against the impacts on the IESCs pertaining to water resources, land and agriculture resources, fisheries resources, ecological resources and socio-economic conditions together with a necessary monitoring program.
- ↑ With the exception of Polder 27/1 and 27/2, the EIA for which covered both polders.
- ↑ P2, P22, P26, P29, P30, P31-Part, 43/1A, 43/2A, 43/2B, 43/2D, 43/2E and 43/2F
- ↑ P27/1 and P27/2, P28/1 and P28/2, P34/2, P55/2A, P55/2C, 25, 47/3, 47/4
See more[edit | edit source]
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