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OVERVIEW OF UPCOMING COMMERCIAL PROJECTS

AROUND THE SUNDARBANS

A report by the Wildlife Trust of Bangladesh and the Zoological


Society of London

June 2011
By Nazneen Ahmed, Md. Reaj Morshed, Christina J. Greenwood

Overview of Upcoming Commercial Projects Around The Sundarbans

June 2011

Table of Contents
EXECUTIVE SUMMARY .................................................................................................................... 5
1.
1.1.
1.2.

INTRODUCTION & DOCUMENT OBJECTIVE ....................................................................... 7


Introduction.............................................................................................................................. 7
Objective of this document....................................................................................................... 8

2.
THE SUNDARBANS ............................................................................................................... 9
2.1.
Mangroves............................................................................................................................... 9
2.2.
The Rich Biodiversity of the Sundarbans ............................................................................... 11
2.3.
Conservation Efforts .............................................................................................................. 12
2.3.1. The Royal Bengal Tiger......................................................................................................... 12
2.3.2. Dolphins ................................................................................................................................ 14
2.4.
Communities around the Sundarbans.................................................................................... 16
2.4.1. Socio-Economic Value of the Sundarbans............................................................................. 16
2.4.2. Community-based natural resource management efforts....................................................... 21
2.4.2.1. EU/FD SEALS project........................................................................................................ 21
2.4.2.2. USAID IPAC project........................................................................................................... 21
2.4.2.3. Other Projects.................................................................................................................... 21
3.
3.1.
3.2.
3.3.
3.4.
3.5.
3.6.
3.7.
3.8.

BACKGROUND OF LEGAL TOOLS .................................................................................... 23


Bangladesh Environment Conservation Act........................................................................... 23
Ecologically Critical Area of the Sundarbans ......................................................................... 23
Environment Conservation Rules........................................................................................... 24
Forest Act 1927 ..................................................................................................................... 24
Bangladesh Wildlife Conservation (Amendment) Act 2010 .................................................... 25
Assessment of existing legislation of Bangladesh showing requirement for Red Category
Environmental Clearance process ......................................................................................... 26
Other related Bangladesh acts, policies and ordinances which the proposed power plant, silo
and shipyard may contravene................................................................................................ 28
Other related acts .................................................................................................................. 30

4.
BAGHERHAT POWER PLANT............................................................................................. 31
4.1
Overview ............................................................................................................................... 31
4.1.1 Ownership ............................................................................................................................. 32
4.1.2 Implementation progress ....................................................................................................... 32
4.2
Brief of environmental impacts............................................................................................... 32
4.2.1 Air.......................................................................................................................................... 32
4.2.2 Waste.................................................................................................................................... 32
4.2.2.1 Coal Combustion Waste (CCW) ............................................................................................ 33
4.2.2.2 Requirements for waste management ................................................................................... 33
4.2.2.3 Reduce Re-use and Recycling of CCWs ............................................................................... 34
4.3
Brief of environmental impacts............................................................................................... 35
4.4
Recommendations................................................................................................................. 35
5.
5.1
5.1.1
5.1.2
5.2
5.2.1
5.2.2

PHULBARI COAL PROJECT ............................................................................................... 37


Overview ............................................................................................................................... 37
Ownership ............................................................................................................................. 38
Implementation progress ....................................................................................................... 38
Brief of environmental impacts............................................................................................... 38
Risk of an accident ................................................................................................................ 38
Spillage during transport and transfer.................................................................................... 39
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5.2.3
5.3

June 2011

Impacts of Dredging and Dumping ........................................................................................ 39


Recommendation .................................................................................................................. 39

6.
CHANDPAI SHIPYARD ........................................................................................................ 40
6.1
Overview ............................................................................................................................... 40
6.1.1 Ownership ............................................................................................................................. 40
6.1.2 Implementation progress at time of writing ............................................................................ 41
6.2
Brief of environmental impacts............................................................................................... 41
6.2.1 Water Pollution...................................................................................................................... 42
6.2.1.1 Oil Spill .................................................................................................................................. 42
6.2.2 Air Pollution ........................................................................................................................... 42
6.2.3 Noise Pollution ...................................................................................................................... 43
6.2.4 Solid Waste ........................................................................................................................... 43
6.2.5 Invasive Species ................................................................................................................... 43
6.2.6 Impact on Ecology ................................................................................................................. 43
6.2.7 Impact on the proposed dolphin sanctuary ............................................................................ 43
6.3
Recommendation .................................................................................................................. 43
7.
7.1
7.1.1
7.1.2
7.2
7.2.1
7.2.2
7.2.3
7.2.4
7.3

CHANDPAI SILO .................................................................................................................. 44


Overview ............................................................................................................................... 44
Ownership ............................................................................................................................. 44
Implementation progress ....................................................................................................... 44
Brief of environmental impacts............................................................................................... 45
Context and setting................................................................................................................ 45
Access and Transport............................................................................................................ 45
Utilities................................................................................................................................... 46
Ecology ................................................................................................................................. 46
Recommendation .................................................................................................................. 48

8.
8.1
8.2

OTHER PROSPECTIVE INDUSTRIES ................................................................................. 49


Overview ............................................................................................................................... 49
Conclusion............................................................................................................................. 50

WORKS CITED................................................................................................................................. 51
WEBSITE REFERENCES ................................................................................................................ 53

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List of Figures
Figure 1: Relative abundance of tigers in the Sundarbans (Barlow et al. 2008)............................................. 13
Figure 2: Gangetic dolphin hotspots in the Sundarbans (BCDP unpublished).............................................. 15
Figure 3: Proposed Dolphin Sanctuaries in the Sundarbans (BCDP unpublished)....................................... 16
Figure 4: The Sundarbans Impact Zone map........................................................................................................ 17
Figure 5: Household dependency on forest products (Sundarban Biodiversity Conservation Project
2001)..................................................................................................................................................................... 19
Figure 6: Occupation distribution among forest resource extracting households (Sundarbans
Biodiversity Conservation Project 2001)....................................................................................................... 20
Figure 7: Map showing the Sundarbans ECA....................................................................................................... 24
Figure 8: Location of the proposed government projects (Source: WTB field visit)..................................... 31
Figure 9: Map of SRF showing the waterway from Akram point to Mongla port and to the Mongla fairway
buoy. .................................................................................................................................................................... 37
Figure 10: Shipyard site with some settlements; Passur river in the middle and the Sundarbans on the
horizon (Photo: Nazneen Ahmed, WTB)........................................................................................................ 40
Figure 11: Shipyard site comprising shrimp farms (photo: Nazneen Ahmed, WTB)..................................... 41
Figure 12: Left Silo; right- Shipyard; short columns form temporary boundary in between.................... 42
Figure 13: Opening to the silo, Sundarbans on the horizon (photo: Nazneen Ahmed, WTB)...................... 44
Figure 14: Right: Silo land; left: (not acquired) water body consisting of shrimp farms.............................. 45
Figure 15: Land filling being done for silo (photo: Nazneen Ahmed, WTB).................................................... 46
Figure 16: Tiger track distribution in the four Forest Department ranges, 2007 ............................................ 47
Figure 17: Tiger tracks recorded in the khals crisscrossing the four forest ranges, 2007........................... 47
Figure 18: Fresh water pond dug out for silo workers (photo: Nazneen Ahmed, WTB) ............................... 48
Figure 19: Land purchased along the Passur river by Energy Pac (photo: Nazneen Ahmed, WTB).......... 49
Figure 20: Land purchased along the Passur river by Lithi Group (photo: Nazneen Ahmed, WTB) .......... 49

List of Tables
Table 1: Threatened Mammals of the Sundarbans .............................................................................................. 11
Table 2: Threatened Amphibians and Reptiles of the Sundarbans .................................................................. 11
Table 3: Threatened Birds of the Sundarbans...................................................................................................... 12
Table 4: Ecological Zones of the Sundarbans Depending on Salinity Level .................................................. 12
Table 5: List of Districts, Upazillas and Population within the Sundarbans Impact Zone............................ 18

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EXECUTIVE SUMMARY
Over the years Bangladesh has lost a significant amount of forests and biodiversity to a growing
human population, agriculture and development. Today, apart from a few fragmented patches of
green scattered across the country, the Sundarbans constitutes nearly half of Bangladeshs remaining
natural forest. Besides being the largest mangrove forest of the world, the Sundarbans supports
millions of livelihoods, provides important fisheries and forest products, and buffers the country from
cyclones. For example, during cyclone Sidr in 2007, hundreds of thousands of lives along with crores
of taka in infrastructure damage were saved by the presence of the forest in comparison to damages
caused by the 1970 cyclone. Recognising its importance the United Nations Educational, Scientific
and Cultural Organisation (UNESCO) declared the East, West and South sanctuaries of the
Sundarbans as World Heritage Site in 1999.
The principal legislation that provides protection to the natural environment of Bangladesh including
the Sundarbans and its periphery is the Bangladesh Environment Conservation Act (BECA) 1995.
Under this Act the Ministry of Environment and Forest (MoEF), through Gazette Notification, 1999,
declared 10 km boundary area around the Sundarbans as an Ecologically Critical Area (ECA). In
addition there are around 187 statutory laws, by-laws and treaties that take environmental concerns
into consideration.
The ECA status recognizes the importance of the Sundarbans and provides additional protection to
the area surrounding the forest and has prohibited there such activities as could threaten the forest
and habitat of wild animals. The prohibited activities include: cutting down or collecting natural forest
and trees; all types of hunting/poaching, killing, capturing and collecting of wildlife; all activities that
can change or damage animal habitat and plants; all activities that change or damage the natural
characteristics of land and water; establishing organizations or industries that pollute air, water, land
and sound; and any type of activity that is harmful for fish or other marine animals.
However, Bangladesh now faces a crucial choice between the need to meet the nations demand for
power and the need for conserving its remaining natural forests to help secure its nation from the
increasing threats of climate change.
As a result, the Government of Bangladesh (GoB) is contemplating the construction of an IndiaBangladesh joint venture coal-fired power plant adjacent to the Sundarbans ECA and is moving
forward with a silo and a shipyard inside the Sundarbans ECA. In addition it is also considering the
proposal for an off-shore reloading facility of a UK based energy company, Asia Energy (Bd) Pty. Ltd.
to transfer coal in the heart of the Sundarbans Reserved Forest.
Case studies of similar projects in other countries show us that the proposed development activities
could have grave consequences for the Sundarbans and its wildlife. These projects clearly
contravene the provisions of BECA 1995 and international treaties which were formed and signed by
the GoB to secure this very forest.
A team from the Wildlife Trust of Bangladesh (WTB) paid a visit to the proposed sites for these
projects to confirm their locations in the ECA. The visit revealed that other private companies have
also acquired land in the ECA thus indicating that these pieces of land are also planned for
development in the near future. It is believed that the construction of the Padma Bridge which
improves transport connections to the area is responsible for this surge in commercial interest.
In a time in Bangladeshs history when climate change is one of the biggest threats to the country, the
Sundarbans is more valuable than ever. The Sundarbans is a national asset and any activity that
threatens the Sundarbans, threatens national security. Therefore, this document elaborates the
details of each proposed project, explores the common environmental impacts by studying project
Environmental Assessment Reports (EIAs) of other countries and by accumulating field observations
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and conversations with the local residents of the project sites. It also provides a set of
recommendations for each project. It is to be noted that the environmental impacts discussed here do
not form and should not replace professional EIAs. Indeed the carrying out of proper EIAs is included
in the recommendations.

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1.

INTRODUCTION & DOCUMENT OBJECTIVE

1.1.

Introduction

June 2011

Bangladesh is the most vulnerable country to climate change impact. Being in the largest delta in the
world located at the downstream of the second largest river system, the country [will be] subject to a
series of climatic events. By 2050, 70 million people could be affected annually by floods; 8 million by
drought; up to 8% of the low-lying lands may become permanently inundated.
Seventy-percent of Bangladeshis depend on natural resources (wetlands and forests) for their
livelihoods. Degradation of natural capital and biodiversity has a serious and direct impact on the food
security, nutrition and income of the poor. An estimated 70 million rural households rely on food and
income from the wetlands to survive in one of the worlds poorest countries. Sustainable management
of the bio-diverse natural capital is, therefore, central to poverty reduction in the Bangladesh context.
[8]
The forests, wetlands and rivers of Bangladesh not only provide food security and income, but also
provide other services to the nation and region. These include such ecosystem services as
summarised in the TEEB 2010 report for policymakers and quoted here (TEEB 2010):
Intact wetlands or dune belts (ecological infrastructure) protect against the impact of floods,
storms and other natural hazards.
Diverse natural vegetation secures groundwater recharge and protects against soil erosion
and dam siltation.
Robust natural systems with a diversity of plants and animals help provide a buffer against
the effects of climate change and other disturbances.
Investment in a sustainable management of natural resources in Bangladesh is therefore not a luxury;
rather it is life insurance for a country whose future is so absolutely dependent upon a functioning
environment. Climate change only makes the issue all the more urgent. Conservation of natural
resources is therefore now an issue of national security.
Yet, since the 1970s Bangladesh has dramatically lost a significant amount of its natural forests to a
growing human population, over exploitation of natural resources, loopholes in policies and
legislations and unplanned development (MoEF 2004, Lockwood 1998, Sunderland 2011). The
complete deforestation of Madhupur Sal (Shorea robusta) forest is one example of the sad decline of
the countrys natural forest and wildlife. Once a thick, deciduous monsoon forest and home to sloth
bears, spotted deer and even leopards, today the Sal Forest has been converted into rubber and
eucalyptus plantations (Lockwood, 1998).
The rate of forest loss in the last decade (1990-2000) was over 7% in Bangladesh, which not only
exceeded the average for Asia, but also the global average (MoEF 2004). Though Bangladesh claims
to have 18% of forested land (Iftekhar and Islam, 2004a) according to National Forest and Tree
Resources Assessment conducted over the period 2005-2007, at present Bangladesh holds
approximately 10% of forested land (Sunderland 2011). This is likely due to the fact that natural
capital has not been properly accounted for during the policymaking process and its value is not
included in land use planning and in the calculation of the countrys economic growth. With
the present rate of deforestation at 2%, Bangladesh runs the risk of losing all its natural forests by
2020 (World Bank and Bangladesh Centre for Advanced Studies 1998).
At the same time Bangladesh is facing crises in development. One notable area is its energy sector,
where it is exploring ways to meet the countrys growing energy needs. Yet, if these projects are
selected without taking into account their effect on the natural assets of the country and indeed if
they have an adverse effect on the countrys remaining nature - then it is highly likely that they will
prove to be unsustainable in the long run. In fact, if implemented, these projects could pose severe

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risks to the food security of the country as well as weaken Bangladeshs irreplaceable natural
defenses against climate-change calamities.

1.2.

Objective of this document

This document has been written in response to a number of development projects that are planned
for in and around Sundarbans and which seem to have been developed without accounting for their
impact on and the value of this mangrove forest. The documents objective is to encourage
policymakers to make development decisions that fully account for the value of natural assets in this
case the Sundarbans - and therefore that are sustainable for the country over the longer term. It
provides a broad introduction to the value of the Sundarbans mangrove forest in order to set the
context for questioning some upcoming development projects planned for the area. It then goes on to
give an overview of related legal instruments before then providing brief overviews for each of the
upcoming development projects, including their potential environmental impacts and
recommendations.
Please note these are not meant to replace full scale feasibility studies or environmental impact
assessments.

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2.

THE SUNDARBANS

2.1.

Mangroves

June 2011

The Sundarbans mangrove forest lies in the southwest of Bangladesh the largest delta in the world
formed by three great rivers - the Ganges, the Brahmaputra and the Meghna (BTAP 2009). The
Sundarbans is at the lower end of this delta. This forest constitutes around 51% of the Reserved
Forests in the country (Iftekhar and Islam 2004).
The Sundarbans is the largest mangrove forest of the world; it is 10 times bigger than the second
largest mangrove forest which is in Malaysia (Gain 2002). The total area of the Sundarbans in both
India and Bangladesh is 10, 000 sq. kilometers, of which the Bangladeshi portion is 6017 sq.
kilometers (Islam 2008). Out of this portion 4143 sq. km of the area is land (Gain 2002), while the rest
1874 sq. km of the area form 430 water ways like rivers, creeks and canals (Islam 2008).
Mangrove forest is classified as one of the richest supporters of food chain in coastal and marine
waters (G. Dickinson 1998, Islam 2008). While the flora of the mangrove wetland forest serve as
primary producers of phytoplankton and marine algae, the zoo plankton and deep water creatures
serve as secondary and tertiary producers (Parikh 2003, Islam 2008).
Despite its ecological benefits mangrove wetlands in Bangladesh have been reduced by 45% in the
last few decades. In fact around 1000 sq.km of the land today used for shrimp cultivation was
originally mangrove wetlands (Islam 2008). The Chokoria mangrove forest that once existed in the
Coxs Bazar is a sad example of mangrove deforestation in Bangladesh.
Likewise, the Sundarbans serves a variety of functions (see Box 1): the trees of this mangrove forest
are sources of timber and fuel wood for the local people and they also fulfill a good amount of the
national timber demand, generating about 41% of the total forest revenue (Hunter 1998, Iftekhar
and Islam 2004). The main trees of this mangrove forest are Sundari (Heritiera fomes), Bain
(Avicennia tomentosa), Amur (Amoora cucullata), Bali (Hibicus tiliaceus), Bhara (Rhizophora
mucronata), Bonjam (Clerodenron inerme), Dabur (Cerbera odallam), Garan (Ceriops
roxburghianus), Gewa (Excoecaria agallocha), Kankra (Bruguiera gymnorhiza), Pasur (Carap
abovata) and Sondal (Afzelia bijuga) (Hunter 1998). Golpatta and sungrasses are other forest
materials which villagers and businessmen extract for various reasons.
The Sundarbans was declared as a RAMSAR site in 1992, and in 1997 UNESCO declared the
Sundarbans as a world heritage site. There are three wildlife sanctuaries in the Sundarbans Sundarbans West (71500 ha), Sundarbans South (37000 ha) and Sundarbans East (31000 ha)
which were set up under the Wildlife Act 1973/4. Sundarbans is also currently running for the election
of Worlds Seven Natural Wonders.

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Source: Bangladesh Tiger Action Plan 2009-2017


In addition to meeting various social and economic needs, this and other mangrove forests have a
very unique quality of storing a large amount of carbon. This quality makes them play a significant role
in keeping the earths climate in check. The carbon storage capacity per sq. km of a mangrove forest
is 50 times higher than a tropical forest (Pidgeon 2009). Also mangroves, unlike tropical forests,
sequester the carbon into the soil rather than storing the carbon in the body of the plant. So when a
mangrove tree dies, only a small amount of the carbon is released to the environment (Pidgeon
2009).
Bangladesh Forest Department (FD) conducted a survey named Sundarbans Forest Carbon
Inventory-2009. USDA Forest Service and USAID assisted the FD in this survey. According to this
survey the Sundarbans can capture 56 million ton of carbon per year which has a value of 150 billion
taka in international market (Carbon Trading and the Sundarbans 2011). Based on the results of this
survey the GoB is considering the prospects of carbon trading market by utilising the Sundarbans
mangrove forests unique carbon capturing capacity. Indonesia earned US$ 1 billion by carbon
trading (Carbon Trading and the Sundarbans 2011).

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However, in the recent decades human activities like unsustainable forest resource extraction and
rapid growth of shrimp farms around the Sundarbans are responsible for severe depletion of the
forest (Islam 2008). Adding to these threats is the growing demand for oil and gas exploration and
other economic activities as discussed later in this document.

Box 1 Extract from the Bangladesh Tiger Action Plan 2009-17 mentioning the ecological
benefits of the Sundarbans mangrove forest.
As well as protecting a unique array of biodiversity, saving the Sundarbans will also secure essential
ecological services such as (1) trapping of sediment and land formation, (2) protection of
human lives and habitation from regular cyclones, (3) acting as a nursery for fish and other aquatic
life, (4) oxygen production, (5) waste recycling, (6) timber production, (7) supply of food and
building materials, and (8) carbon cycling (Biswas et al. 2007; Islam and Peterson 2008). Such
services are of global and national importance, and fundamental to the livelihoods of the local
people living along the Sundarbans border; several million people directly depend upon the
collection of timber, fuel wood, fibers, fish, shells, wax, honey, and other non-timber forest
products. This resource extraction feeds both local needs and industry, with the forest
producing almost half of the total timber and fuel wood for Bangladesh (Canonizado and Hossain
1998).

2.2.

The Rich Biodiversity of the Sundarbans

The Sundarbans is not like other mangrove forests in the other parts of the world, it has a unique
collection of biological diversity and wildlife resources (REF this or remove/reword). It is the home to
almost 30 principal kinds of trees (Hunter 1998), 49 mammal, 59 reptile, 8 amphibian, 315 bird, and
200 to 300 fish species (BTAP 2009, Chaudhuri et al. 1994, Hussain and Acharya 1994, Khan 2004).
A number of these species are listed as threatened species by IUCN. The following tables show a list
of the threatened species which are inhabitants of Sundarbans.
Table 1: Threatened Mammals of the Sundarbans
English Name
Royal
Bengal
Tiger
Irrawaddy
Dolphin
Finless Porpoise
Barking Deer
Gangetic
Dolphin

Scientific Name
Panthera tigris

Local Name
Bagh

Global Status
Endangered

Shushuk

Local Status
Critically
endangered
Critically
endangered
Endangered

Orcaella
brevirostris
Neophocaena
phocaenoides
Muntiacus
muntjak
Platanista
gangetica

Shushuk

Maya Harin

Endangered

Unknown

Shushuk

Endangered

Endangered

Unknown
Data deficient

(IUCN Bangladesh 2000)


Table 2: Threatened Amphibians and Reptiles of the Sundarbans
Class

English Name

Amphibia

Green Frog

Scientific
Name
Euphlyctis

Local Name

Local Status

Global Status

Sabuj Bang

Endangered

Unknown
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Reptilia

Estuarine
Crocodile
River Terrapin
Rock Python
King Cobra
Spot-tailed Pit
Viper

hexadactylus
Crocodylus
porosus
Batagur baska
Python
molurus
Ophiophagus
hannah
Trimeresurus
erythrurus

June 2011

Unknown

Ajagar

Critically
Endangered
Critically
Endangered
Endangered

Raj Gokhra

Endangered

Unknown

Viper Shap

Endangered

Unknown

Lonapanir
Kumir
Baro Kaitta

Endangered
Lower risk

(IUCN Bangladesh 2000)


Table 3: Threatened Birds of the Sundarbans
English Name
Blyths
Kingfisher
Ruddy
Kingfisher
Masked Finfoot
White-bellied
Sea Eagle
Painted Stork

Scientific Name
Alcedo hercules

Local Name
Maachranga

Local Status
Endangered

Global Status
Vulnerable

Halcyon
coromandra
Heliopais
personata
Haliaeetus
leucogaster
Mycteria
leucocephala

Lal Machranga

Vulnerable

Unknown

Goilo Hansh

Endangered

Vulnerable

Sindhu Eagle

Endangered

Unknown

Rangila Bok
Shona-jongha

Critically
Low Risk
Endangered
(IUCN Bangladesh 2000)

The Sundarbans forest can be categorized as both estuarine and swampy and it lies below the mean
high tide level. A major part of this forest gets swept by tidal water twice everyday as it lies below
mean high tide level (Gain 2002). Because of this interaction with salt water, the ecology of the
Sundarbans is very sophisticated. Depending on the salinity level the Sundarbans can be divided into
3 ecological zones (Table 4).
Table 4: Ecological Zones of the Sundarbans Depending on Salinity Level
Ecological Zone
Oligohaline
Mesohaline
Polyhaline

Salinity Level (mg/litre)


500-5000
5000 15000
15000-30000
(Gain 2002)

2.3.
2.3.1.

Conservation Efforts
The Royal Bengal Tiger

The Sundarbans is the home to one of the worlds largest cats commonly known in Bangladesh as
the Royal Bengal Tiger (Panthera tigris tigris). The Bengal tigers have become intertwined with
Bengali culture and heritage (Islam 2008): tiger is our national animal and we also have it as an
emblem for the Bangladesh Cricket Boardas we compare heroism with tigers courage. However, little
we do know about the plight of this majestic creature. Around the world the wild tigers are threatened
by the decreasing amount of forests, by poaching and also by the poaching of their prey (Mohsanin

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2011). As a result the tiger is now an endangered species, with only 3000 - 5000 individuals being
alive today in the whole world (IUCN 2011).
Bangladesh has one of the worlds largest single populations of wild tigers, around 300-500, and
therefore conservation of tigers in Bangladesh is important not only on a national level, but also on
the global stage (BTAP 2009).Tigers are an integral part of the Sundarbans ecology. They act as an
umbrella species for the Sundarbans ecology as they require large areas of land to live and also
occupy the top position of the food chain. So tigers play an active role to keep the ecology of the
Sundarbans in a balanced state (BTAP 2009).

Figure 1: Relative abundance of tigers in the Sundarbans (Barlow et al. 2008)

Tigers need a large area of land to live. Each female tiger claims a territory for herself and one male
tiger claims a territory for himself over the territory of 3-4 female tigers (Barlow 2008). Tigers live
across the whole forest (Figure 1).
It is notable that some of the highest densities of tiger are outside of the three wildlife
sanctuaries illustrating that the whole of the Sundarbans reserved forest is counted as tiger
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habitat and so conservation efforts span the whole area to ensure a future for this endangered
species.
In Bangladesh conservation efforts have been taken both on the Government and the non
Government level to conserve Bengal tigers.
The Sundarbans Tiger Project (STP) is a joint tiger conservation initiative of the Wildlife Trust of
Bangladesh, Zoological Society of London (ZSL) and the Bangladesh Forest Department. The project
is directed by the Forest Department and it utilizes wildlife staff from the Wildlife Trust of Bangladesh,
ZSL and University of Minnesota to advise on project strategies and train staff. Its work is spread
across a number of fields including awareness raising, institutional development and policy, and tigerhuman conflict mitigation.
Besides this the World Bank is also providing Bangladesh with a soft loan of USD 36 million for
wildlife conservation by their Non-Lending Technical Assistance, Regional Projects, Global Tiger
Initiative and Bangladesh Climate Change Resilience Fund.

2.3.2.

Dolphins

In the waters of the Sundarbans, many sweet water dolphins are found. They are called Shushuk by
the local people because of the sound they make. It is the only place in the world where two kinds of
fresh water dolphins cohabit - the Gangetic dolphin and the Irrawaddy dolphin (MoEF 2008). Dolphins
are at the apex of aquatic ecosystems and like tigers, they play an important role in regulating the
population of other aquatic species. Therefore they serve as indicators of a healthy ecosystem
(Omacha 2008). However, sadly both of these dolphins are endangered in Bangladesh (IUCN
Bangladesh 2000). The Sundarbans is an important habitat for these dolphins. Figure 2 shows the
locations of the Gangetic dolphin hotspots.
To save these dolphins from extinction, the Wildlife Conservation Societys Bangladesh Cetacean
Biodiversity Project (BCDP) is working with the Bangladesh Forest Department (FD) to set up three
protected areas. These protected areas will be set up in the hotspots for these dolphins (Figure 3).

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Figure 2: Gangetic dolphin hotspots in the Sundarbans (BCDP unpublished)

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Figure 3: Proposed Dolphin Sanctuaries in the Sundarbans (BCDP unpublished)

2.4.
2.4.1.

Communities around the Sundarbans


Socio-Economic Value of the Sundarbans

The Sundarbans has a unique human-environment relationship due to the fact that over 3.5 million
people living in the adjacent area use this forest for livelihood and of this 3.5 million almost 1.4 million
people are directly dependent on the forest (Sadik and Rahman 2010). Among the different forest
products extracted from the Sundarbans, timber and fish alone are worth USD 100 million and USD
304 million respectively (Islam 2008).
The Sundarbans Impact Zone (SIZ) is distributed across 17 upazillas in 5 districts in the Khulna
division (Sundarban Biodiversity Conservation Project 2001) (Figure 4). People living in the impact
zone directly or indirectly depend on the forest for their livelihood (see Box 1).

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Figure 4: The Sundarbans Impact Zone map

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Table 5: List of Districts, Upazillas and Population within the Sundarbans Impact Zone

District

Satkhira

Upazilla

Union

Shaymnagar

13

Assasuni

10

Kaliganj

12

Mongla
Sharankhola

Rampal
Dacope
Koyra

216

Pirojpur

Female

241

52,285

220,957

110,633

110,324

249

52,163

225,596

115,054

110,542

77

31,015

149,030

80,819

68,211

45

21,960

114,083

61,799

52,284

181

75,472

349,551

178,676

170,875

133

37,873

167,070

84,922

82,148

107

30,130

157,489

83,193

74,296

38,394

192,534

95,993

96,541

51,757

248,112

127,579

120,533

29,799

140,574

72,717

67,857

66

34,477

162,025

82,687

79,338

49

15,201

69,803

34,721

35,082

191

50,765

237,613

120,830

116,783

94

55,617

263,527

131,940

131,587

40

31,642

155,256

79,081

76,125

10

133

45,542

212,232

107,127

105,105

154

2,334

713,977

3,379,233

1,728,065

1,651,118

6
4
16
10

10

Paikgaccha

10

212

Batiaghata

169

Patharghata

Bamna

Barguna
Sadar

10

Mathbaria

11

Total

Male

153,487

131

Naserabad

Total

160,294

Bhandaria

Population

313,781

Khulna

Barguna

Total
House hold

59,885

Bagerhat
Morelgonj

Total
Village

(Population Census 2001)

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The Sundarbans Biodiversity Conservation Project undertook a survey to find out the total
dependency on the forest of the people living in the SIZ. The survey shows that 18.1% of the
households in the SIZ extract forests resources directly from the forest.

Figure 5: Household dependency on forest products (Sundarban Biodiversity Conservation Project


2001)

The occupations of these forest resource extractors are shrimp fry collection, honey collection,
golpata (Nypa palm) collection, shell/crab collection, fishing, boating, dadondar (money lending) and
medicinal plant collection. The distribution of these occupations is shown in Figure 6. This shows the
heavy reliance upon the aquatic resources of the Sundarbans which in turn depend upon healthy
waterways.

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Figure 6: Occupation distribution among forest resource extracting households (Sundarbans


Biodiversity Conservation Project 2001)

Average family size of such forest resource extracting households is 4.9, with male to female ratio of
110:100 and with 37.1% of the forest resource extracting population being children under 14 years of
age. 85.1% of the women extracting forest resources are shrimp fry collectors (Sundarbans
Biodiversity Conservation Project 2001).
The forest resource extractors need to get a permit from the FD before they can go inside the SRF
and extract forest resources. They have to inform the FD about what kind of resource they want to
extract and then the FD issues them a permit for that specific type of resource and also the amount of
resource they can collect. The resource extractors have to pay a certain amount of fees for this
permit. There are some other rules the resource extractors need to follow and their permits are
cancelled upon violation of these rules (FD field staff, pers comms).
Bangladesh has always been prone to natural disaters with the GoB having spent over USD 10 billion
over the last three decades to tackle natural calamities that come in the form of flood, drought and
tropical cyclones. In fact, with its constant records of severe cyclones and floods Bangladesh has
already earned the reputation of being one of the most climate vulnerable countries in the world.
(MoEF 2008).
With this regard the Sundarbans plays another vital role by protecting the coastal zone of Bangladesh
from cyclones and natural disasters like Aila and Sidr. Without Sundarbans these cyclones would
have caused massive damages in the form of- loss of life, destruction of infrastructure and property.
Sundarbans role as a buffer from cyclone is one of the benefits which economists have begun to put
a value on. The European Commission and the FD together did a study to assess the value of the
Sundarbans as protection against cyclones. The report compared the losses and casualties caused
by two cyclones in 1970 and 2007; one cyclone which passed over Sundarbans, and the other
cyclone which hit Chittagong where there are no longer any mangroves (Bangladesh Forest
Department, 2010). Bangladesh had another Mangrove forest named Chokoria Sundarbans in the

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Chittagong region. This mangrove forest sized approximately 21000 acres no longer exists, mainly
because of shrimp farming (Gain 2002).
In 1970 a cyclone with a speed of 224 km/hr hit Chittagong (non-Sundarbans region). It incurred a
loss of 0.5 million human lives (MoEF 2008).
In 2007, the cyclone Sidr hit Khulna and greater Barisal with a similar speed of 210 to 230 km/hr. This
cyclone hit Sundarbans first and then passed over the human habitations. The cyclone Sidr lost most
its force on the forest and by the time it reached human localities it had already lost much of its
intensity. This resulted in a lesser death toll of 3363 individuals.
The below box shows the number of lives lost in terms of monetary values. It does not include the
loss and damage of properties (Bangladesh Forest Department, 2010).
Cost of cyclone dated 12 November, 1970 = 0.5 Million (Lives) * 680,000 = Taka 3400 crore
Cost of cyclone dated 15 November, 2007 = 3363 (Lives) * 680,000 = Taka 2.286840 crore
The cost of every human life is calculated by using the per capita income of 250 USD per year over
the life span of 40 years. This amounts to 10,000 USD, or Taka 680,000. Thus, assuming that each of
the lost lives had a life insurance of Taka 6.8 lakh, the total number of lives lost (0.5 million) amounts
to Taka 3400 crore during the cyclone over the non-Sundarbans region (Bangladesh Forest
Department 2010).
The implication is that the Sundarbans saved a huge number of lives by absorbing much of the force
of the cyclone. If this is converted into GDP terms then approximately Taka 3400 crore (USD
500,000,000) was saved. To this figure could also be added the money saved from reduced damage
to property and business.
2.4.2.

Community-based natural resource management efforts


2.4.2.1.

EU/FD SEALS project

Sundarbans Environmental And Livelihood Security (SEALS) is a project co-funded by European


Union (EU) and GoB. The objective of this SEALS project is to promote sustainable resource
extraction of the Sundarbans Reserved Forest (SRF) through generating alternative livelihoods for the
people living in the SIZ who are dependent on the resources of the SRF for their livelihood and also
by reducing disaster risk of SIZ communities. The project started operating from 10 November 2010
and will continue for 54 months. Total grant money for this SEALS project is 10,444,444 Euro (USAID
2011). The project will be implemented by the Bangladesh Forest Department (FD).
2.4.2.2.

USAID IPAC project

USAID funded Integrated Protected Area Co-Management (IPAC) project aims to develop a national
network of forest and wetland protected areas. They aim to build a strong co-management approach
to achieve their development goals. The project started from June 2008 and will end after 5 years in
June 2013. IPAC will work with FD, local community and other stakeholders to build a strong comanagement platform, which will strengthen conservation efforts and will help to achieve sustainable
development.
2.4.2.3.

Other Projects

There are some other conservation efforts for the development and conservation of the SRF

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Sustainable Development and Biodiversity Conservation in Coastal Protection Forests,


Bangladesh: This project is co-funded by Government of Germany and GoB. The
implementation of this project will be undertaken by- GIZ, local stakeholders and FD with the
help of USAID/IPAC and EU (SEALS).
World Bank is also helping Bangladesh for the conservation and development of the SRF by
their Non-Lending Technical Assistance, Regional Projects, Global Tiger Initiative and
Bangladesh Climate Change Resilience Fund.

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3.

June 2011

BACKGROUND OF LEGAL TOOLS

Bangladesh has over 100 legislations that are related to the environment (Chowdhury 2002). In
addition the country is signatory to a number of international treaties to protect the natural
environment. Despite this the country has lost a significant number of forests and wildlife, the major
reasons being non-cohesive policies and a burgeoning population. A good number of the national
policies bear no coordination and consistency among themselves which make them ambiguous and
difficult for implementation (MoEF 2004).
Speaking of Sundarbans, this mangrove forest was first declared as Reserved Forest in 1878 under
the Forest Act VII of 1865 (Islam 2008). It has been under scientific management for more than 150
years (Hussain 1991, Iftekhar and Islam 2004a).

3.1.

Bangladesh Environment Conservation Act

The law that exists to give protection to the natural environment in Bangladesh is the Bangladesh
Environment Conservation Act (BECA), 1995. The Act was made effective from June 1995 and
replaces the previous Environment Pollution Control Ordinance, 1977 (Chowdhury 2002).
Under the BECA, 1995 the Department of Environment (DoE) was formed with its Director General
(DG) as its head. The DG is vested with the power of taking appropriate measures to conserve the
environment, control and mitigate pollution and maintain environmental standards (Sections 3 and 4
of BECA 1995).
To be specific, explaining the role and function of the DG, Sub Section 2 (g) of Section 4, states,
(g) Advising the Government to avoid such manufacturing process, commodities and substances as
are likely to cause environmental pollution;
BECA articulates and expands upon the environmental management and sustainable development
goals of the 1992 Environmental Policy. In particular, it defines the environmental regulatory regime
and DoEs mandate with respect thereto.

3.2.

Ecologically Critical Area of the Sundarbans

Among the measures instituted by the Environment Conservation Act is a provision for the
Declaration of Ecologically Critical Areas (ECAs) under Section 5 of BECA 1995:
5. Declaration of Ecologically Critical Areas - (1) If the Government is satisfied that due to
degradation of environment the ecosystem of any area has reached or is threatened to reach a critical
state, the Government may by notification in the official Gazette declare such areas as Ecologically
Critical Areas.
(2)
The Government shall specify, through the notification provided in Sub-clause (1) or
by separate notification, which of the operations or processes cannot be initiated or continued in the
Ecologically Critical Area (Bangladesh Environment Conservation Act, 1995).
With respect to the Sundarbans, the government via gazette notification dated 30 August, 1999
declared 10 kilometres area from the boundary of the reserved forest of Sundarbans as Ecologically
Critical Area (ECA). This ECA does not include the whole reserved forest though. Nevertheless the
status of ECA has brought the 10 km boundary around the Sundarbans under special legal protection
and any activity that threatens or has the potential to threaten the forest ecosystem is prohibited there
(Gazette Notification, MoEF 1999).

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However, the proposed location of the power plant project just kisses the boundary of the ECA while
the project locations for the silo and the shipyard fall inside the ECA (personal visit).

Figure 7: Map showing the Sundarbans ECA

3.3.

Environment Conservation Rules

The Environment Conservation Rules formed in 1997 are the supporting rules for BECA 1995. The
Rules explain the process for obtaining environmental clearance for a project.

3.4.

Forest Act 1927

The Forest Act 1927 was formed particularly to manage and regulate the activities inside the
Reserved Forest including the transit of forest products and the levy that is applicable to timber and
other forest products. The Act also consists of provisions related to conservation of the Reserved
Forests in Bangladesh.
`
Under Sections 3 and 4 of the Forest Act 1927 the Bangladesh Forest Department (FD) have been
vested with the power to declare, through official Gazette notification, any forested land, waste land
or any land appropriate for afforestation and belonging to the Government as Reserved Forest.
3. Power to reserve forests.-The 2 [Government] may constitute any forest-land or waste-land 3[or
any land suitable for afforestation] which is the property of Government, or over which the
Government has
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proprietary rights, or to the whole or any part of the forest-produce of which the Government is
entitled, a reserved forest in the manner hereinafter provided.
4. Notification by Government. -(l) Whenever it has been decided to constitute any land a reserved
forest, the 1[Government] shall issue "notification in the 2[official Gazette]
Section 26 of the Act explains the activities that are prohibited inside a Reserved Forest
26. Acts prohibited in such forests. [(1) Any person who, in a reserved forest- (a) kindles, keeps or carries any fire except at such
seasons as the Forest-Officer may notify in this behalf;
(b) trespasses or pastures cattle, or permits cattle to trespass;
(c) causes any damage by negligence in felling any tree or cutting or dragging any timber;
(d) quarries stone, burns lime or charcoal, or collects, subjects to any manufacturing process, or
removes any forest produce other than timber; or who enters a reserved forest with firearms without
prior permission
from the Divisional Forest Officer concerned, shall be punishable with imprisonment for a term which
may extend to six months and shall also be liable to fine which may extend to two thousand taka, in
addition to such compensation for damage done to the forest as the convicting Court may direct to be
paid.
(1 A) Any person who-(a) makes any fresh clearing prohibited by section 5 ; or
(b) removes any timber from a reserved forest; or
(c) sets fire to a reserved forest, or, in contravention of any rules made by the Government in this
behalf, kindles any fire, or leaves any fire burning, in such manner as to endanger such a forest;
or who, in a reserved forest
(d) fells, girdles, lops, taps or burns any tree or strips off the bark or leaves from, or otherwise
damages the same;
(e) clears or breaks up any land for cultivation or any other purpose 1 [or cultivates or attempts to
cultivate any land in any other manner] ;
(f) in contravention of any rules made in this behalf by the Government, hunts, shoots, fishes, poisons
water or sets traps or snares; or
(g) establishes saw-pits or saw-benches or converts trees into timber without lawful authority, shall be
punishable with imprisonment for a term which may extend to five years and shall not be less than six
months, and shall also be liable to fine which may extend to fifty thousand taka and shall not be less
than five thousand taka, in addition to such compensation for damage done to the forest as the
convicting Court may direct to be paid.]
The economic projects about to take place in and around the Sundarbans would consist of the some
or most of the prohibited activities listed herein. Therefore, it can be said that such projects clearly go
against the existing legislations.

3.5.

Bangladesh Wildlife Preservation (Amendment) Act 1974

Under the Wildlife Preservation (Amendment) Act 1974 the Government in 1996 had declared East,
West and South zones of the Sundarbans as Wildlife Sanctuary.
The Wildlife Conservation (Amendment) Act 2010 replaces the previous Wildlife Preservation
(Amendment) Act 1974. Sections 14 and 15 of the present Wildlife Conservation (Amendment) Act
2010, have empowered the FD to regulate and limit the access to and activities in such Protected
Areas as Wildlife Sanctuary.
(14) Prohibitions related to Sanctuary In the Sanctuary no one is allowed to
a) Grow crops
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b)
c)
d)
e)

Establish or manage industries


Collect, destroy or extract plant
Light a fire of any type
Take any fire-arms in the Sanctuary without the permission of the Chief Warden or of any
officer authorised by him
f) Disturb or scare any wildlife or use any chemical, ammunition, weapon or drug/medical
substance that can cause harm to the wildlife habitat
g) Introduce/Enter with any exotic species of wildlife or plant
h) Introduce domestic cattle or keep domestic cattle straying
i) Dump chemical substance harmful to wildlife
j) Dig the ground or investigate for extracting mineral resource
k) Cut down any plant or part of any plant except for the purpose of Silvi Cultural Operation to
increase the natural expansion/growth of plants
l) Introduce/Enter with any Alien or Invasive species
(15) Entrance in the Sanctuary, etc I. Except the person mentioned below, no one can enter or reside in the forest:
a) Any officer acting responsibly under the law or rules
b) Any person permitted by the Chief Warden or any officer authorised by him
c) Any person involved in conservation and nominated by the Forest Department
d) Any person travelling by road, highway or waterway constructed in the Sanctuary
e) Any person involved in conservation or management of the Sanctuary who has been
permitted by the Chief Warden or any officer authorized by him
(16) Management of Sanctuary
I.
For each sanctuary the Government will implement a management plan.
II.
The Chief warden will carry out the overall responsibility of the management planning,
implementation and management and in order to implement the plan, he can allow, to some
extent, the following:
a) Except for commercial use of any tourism shop, cottage, or hotel construction, he can
give permission to form/construct road, building, boundary/fence or entrance-impeding
archway and boundary limits or other works of similar types that are needed for the
management of the sanctuary
b) He can make the necessary arrangements needed to ensure the safety of the wildlife
or their habitat
c) In order to protect wildlife, develop their habitat, protect their breeding spot, keep their
breeding spots free from disturbance during breeding period, and ensure food security,
he can, to some extent, create gardens that are suitable to be food for wildlife.
d) Upon discussing with the co management committee, he can take the necessary
initiatives to regulate fishing activities, movement of water transports or with the help of
prohibitions, can protect turtle, crocodile, dolphin, whale, Ganges dolphin etc and other
marine animals of both salt and fresh water; or
e) Can identify and prohibit any activities that are located within 2 km of the Sanctuary
area and are detrimental to the environment.

3.6.

Assessment of existing legislation of Bangladesh showing requirement for


Red Category Environmental Clearance process

Point 1: The Schedule 1 of BECA 1995 has classified industries or projects as Red, Orange A,
Orange B, or Green depending on their location and impact on environment.
According to Schedule 1 of the BECA 1995, the proposed coal based power plant of Bagerhat falls in
the Red Category i.e. with the potential to have the most serious effect on the environment and
therefore in need of the most rigorous environmental clearance process.

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Point 2: Section 12 of the BECA 1995 renders it compulsory for ALL industries to obtain an
Environmental Clearance Certificate.
12. Environmental Clearance Certificate - No industrial unit or project shall be established or
undertaken without obtaining, in the manner prescribed by rules, an Environmental Clearance
Certificate from the Director General.
The process of obtaining an Environmental Clearance Certificate is more rigorous for those projects
that fall within the Red Category. Therefore even if the Bagerhat power plant project is Government
owned, the rules of BECA 1995 are equally applicable to it.
Point 3: According to sub rules 4 and 6 (d) of Rule 7 of the Environment Conservation Rules 1997,
the procedure for issuing Environmental Clearance Certificate requires the submission of the
following:
(4) For industrial units and projects falling in the Orange A, Orange B and Red categories, firstly a
Location Clearance Certificate and thereafter an Environmental Clearance Certificate shall be issued:
6 (d) For Red Category:
(i) report on the feasibility of the industrial unit or project (applicable only for proposed industrial unit or
project);
(ii) report on the Initial Environmental Examination (IEE) relating to the industrial unit or project, and
also the terms of reference for the Environmental Impact Assessment of the unit or the project and its
Process Flow Diagram;
or
Environmental Impact Assessment report prepared on the basis of terms of reference previously
approved by the Department of Environment, along with the Layout Plan (showing location of Effluent
Treatment Plant), Process Flow Diagram, design and time schedule of the Effluent Treatment Plant of
the unit or project, (these are applicable only for a proposed industrial unit or project);
(iii) report on the Environmental Management Plan (EMP) for the industrial unit or project, and also
the Process Flow Diagram, Layout Plan (showing location of Effluent Treatment Plant), design and
information about the effectiveness of the Effluent Treatment Plan of the unit or project (these are
applicable only for an existing industrial unit or project);
(iv) no objection certificate of the local authority:
(v) emergency plan relating adverse environmental impact and plan for mitigation of the effect of
pollution;
(vi) outline of relocation, rehabilitation plan (where applicable);
(vii) other necessary information (where applicable);
With respect to the above statements, the proposed Bagerhat power plant claims it will receive the
Environmental Clearance Certificate in a few days time though it failed to submit an Environmental
Impact Assessment (EIA) report in the court proceedings. So, it is questionable as to how it is
obtaining an Environmental Clearance Certificate without submitting the necessary documents as
prescribed in the Environment Conservation Rules 1997.
Point 4: According to Section 8 of BECA 1995, an individual, affected or likely to be affected from the
pollution or environmental degradation, can apply to the DG demanding for a remedy for the damage
or possible damage.
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8. Information to the Director General regarding environmental degradation or pollution (1) any
person affected or likely to be affected as a result of pollution or degradation of the environment may,
in the manner prescribed by rules, apply to the Director General for remedy of the damage or
apprehended damage.
(2) The Director General may hold a public hearing and take other measures for disposing of an
application made under this section.
This statement thereby allows local villagers and other concerned parties to voice their concern over
the proposed power plant and its negative impact on the agricultural land and the surrounding natural
eco system.
Point 5: Under Section 15 of BECA, which states the penalties of violation of the provisions of the
Act, the proposed power plant should be brought to trial if it violates any of the BECA provisions.
Point 6: The Agriculture, Water Resource & Rural Institution Division of the Ministry of Planning also
has an environmental section to check the environmental aspects of the projects of the Government
of Bangladesh [1].
Point 7: Following the Public Interest Litigation (PIL) signed by the petitioner, Mr Mozahadul Islam, in
the High Court Order, in addition to the Rule Nisi, let a Suo Motu Rule be issued to protect the
location from the proposed Bagerhat power plant.
Point 8: The petitioner has the scope to accuse the authorities of violating a number of laws that
ensure peoples participation in the decision making process, provide for compensating affected
people for all sorts of loss and protecting the national heritage.

3.7.

Other related Bangladesh acts, policies and ordinances which the proposed
power plant, silo and shipyard may contravene

Point 9: Other Acts, policies and Ordinances that address the importance of environment include:
I.

The National Energy Policy, 1996 has committed to ensure environmentally friendly energy
generation programmes that cause the least damage to environment. The Policy admits that
unplanned and unrestrained use of fossil fuels is responsible for environmental degradation.
However, now this Policy stands as a stark contradiction to the Governments proposal for the
coal-fired power plant.
II.
Section 8 of the Territorial Waters and Maritime Zones Act 1974 provide legal penalty against
pollution of territorial waters.
III.
In addition to BECA, Section 150 of the Motor Vehicle Ordinance 1983, Section 8 of the
Smoke Nuisance Act and Section 3 of the Protection and Conservation of Fish Act 1950
prohibit pollution of air, water and soil from agricultural, fishery, industry, vehicle and other
sources.
IV.
The Industrial Policy 1999 seeks to promote sustainable industrial development considering
points like environmental concerns and resource availability.
V.
Some of the objectives of The Land Use Policy 2001 are:
a) To prevent the current tendency for gradual and consistent decrease of cultivable land for
production of food to meet the demands of the expanding population;
b) To introduce a zoning system in order to ensure the best use of land in different parts of the
country, according to their local geological differences, to logically control the unplanned
expansion of residential, commercial and industrial construction;
c) To ensure that land use is in harmony with the natural environment;
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d) To protect natural forest areas, prevent river erosion and to prevent the destruction of hill and
hillocks;
Point 9: It should be realised that biodiversity supports all life including our own. Biodiversity
conservation is a case of national security.
Therefore, in order to continue benefitting from the ecological services that biodiversity provides,
Bangladesh has become a signatory to most major international conventions, treaties, and protocols
on environment.
Conventions include:
Convention on Biological Diversity (CBD): Signed by Bangladesh in 1992, the objective of this
treaty is the conservation of biodiversity which is identified as being essential to socioeconomic development.
Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES):
Bangladesh acceded to CITES in 1982.
Ramsar Convention: The Sundarbans has been designated as a Wetland of International
Importance under this convention, which Bangladesh ratified in 1992.
The Ramsar
Convention provides a framework for the conservation and wise use of wetland resources.
Kyoto Protocol: In 2001 Bangladesh ratified this protocol which aims to reduce greenhouse
gases contributing to climate change. Forests across the country including the Sundarbans
represent an important carbon sequestration site for the country.
The Millennium Development Goals also include the need to conserve biodiversity.
Policies include:
The National Biodiversity Strategy and Action Plan 2004,
The Poverty Reduction Strategy Paper 2005,
The Bangladesh Tiger Action Plan 2009-17,
Bangladesh Climate Change Strategy and Action Plan 2008.
All these policies are highly interrelated and most of their goals and targets overlap and complement
each other. Excerpts from some of these policies are mentioned below:
1. The National Biodiversity Strategy and Action Plan (NBSAP) 2004
Three of the six major objectives of the NBSAP are
Conserve, and restore the biodiversity of the country for well being of the present and future
generations;
Ensure that long-term food, water, health and nutritional securities of the people are met
through conservation of biological diversity;
Maintain and to improve environmental stability for ecosystems.
2. The Poverty Reduction Strategy Paper 2005
One of its ten goals is
Ensure comprehensive disaster risk management, environmental
mainstreaming of these concerns into the national development process.

sustainability

and

In terms of environmental issues it is important to keep in mind that in a country where the majority of
the poor are highly dependent on natural resources, the improved management of natural resources
is a prerequisite for poverty reduction.
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Communities living in urban slums, people living in areas prone to severe floods, drought, salinity
and bank erosion and river/estuarine islands, tribal communities living in hills and forests,
communities of landless and migrant workers, depend on natural resources for livelihood.
In order to address environmental issues relevant to the conservation of nature it is important to
appropriately integrate environmental issues in all policies including macroeconomic policies Not
only environmental analysis should take place at the policy level but also environmental
considerations need to be included in project design and implementation. It is essential to introduce
public hearings for projects with possible major environmental impacts. In this respect it is also
essential to prepare Environmental Impact Assessment (EIA) documents on all projects and
programmes available in the public domain.
3. The Millennium Development Goals 2000
Though the links are implicit, biodiversity conservation plays a crucial role in ensuring the targets set
by the MDGs. Though the MDG-7 deals specifically with ensuring environmental sustainability,
however, the relevance of biodiversity in achieving other MDGs cannot be underestimated.
Goal 7 Ensure Environmental Sustainability
Targets: Integrate the principles of sustainable development into country policies and programs and
reverse the loss of environmental resources; Halve, by 2015, the proportion of people without
sustainable access to safe drinking water; have achieved, by 2020, a significant improvement in the
lives of at least 100 million slum dwellers
Goal 7 aims to integrate the principles of sustainable development into the country level policies and
programmes and reverse the loss of environmental resources. Thus implementation of the NBSAP
will contribute directly to the Goal. The goals of biodiversity conservation are also mainstreamed in
the other targets of the MDG; for example, poverty alleviation, food security, education, gender, health
and global alliance are ingrained therein as cross cutting themes, the benefits of which are accrued to
the society at large.

3.8.

Other related acts

To ensure the proper implementation of BECA 1995 the Environment Court Act 2000 has proposed to
set up environmental courts in all six divisions of Bangladesh. These courts would manage the
environmental crimes under BECA 1995 and also other laws as may be notified by the Government in
official Gazette (Chowdhury 2002).

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4.
4.1

June 2011

BAGHERHAT POWER PLANT


Overview

India and Bangladesh have proposed a joint venture project of 1,320 megawatt coal-fired thermal
power plant at Rampal, Bagerhat in the south west of Bangladesh. For this purpose the concerned
authority has also acquired approximately 1800 acre of land in the first phase in Sapmari and
Koigoddashkathi mouja of Rajnagar and Burirdanga Unions respectively of Rampal Thana in
Bagerhat district [2].

Figure 8: Location of the proposed government projects (Source: WTB field visit)

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4.1.1

June 2011

Ownership

This project is a joint collaboration of Bangladesh Power Development Board (BPDB) and National
Thermal Power Corporation (NTPC), India (Bagerhat coal-fired power plant may jeopardise
Sundarbans 2011).
4.1.2

Implementation progress

The EIA report on the project from the Bangladeshi side is being prepared by CEGIS. On the Indian
side, a feasibility study is being carried out [3]. Land acquisition has started though no boundary walls
have been built till now (local journalist, pers comms).
It is expected that if the Indian PM pays a visit to Bangladesh in July, he will accompany the
Bangladeshi PM to the plant site and will inaugurate the project (local journalist, pers comms).
The land consists of mostly shrimp farms belonging to private owners and a small amount of
agricultural land in which crops are being grown now. Some portions of the land are owned by the
Mongla Port Authority (local journalist, pers comms).

4.2

Brief of environmental impacts

This is a brief overview of some of the environmental impacts of the power plant.
This is not meant to take the place of a full environmental impact assessment. CEGIS is
responsible for completing the full environmental impact assessment.
4.2.1

Air

During the process of generating energy from coal-fired power plants, a good amount of poisonous
gases are emitted in the air. According to the Union of Concerned Scientists [4] the amounts of toxic
products released in the air from a typical 500 megawatt coal plant are as follows:

3.7 million tons of carbon dioxide (CO2)


10,000 tons of sulfur dioxide (SO2)
10,200 tons of nitrogen oxides (NOx)
500 tons of small airborne particles
220 tons of hydrocarbons
720 tons of carbon monoxide (CO)
170 pounds of mercury
225 pounds of arsenic
114 pounds of lead, 4 pounds of cadmium, and other toxic heavy metals

These gas emissions increase the density of Particulate Matter (PM) in the air and carry the PMs
across hundreds to thousands of kilometres downwind of the plants. High concentration of PMs in the
air is one of the reasons for mortality from heart diseases, lung cancer and many other respiratory
diseases (Penney, Bell and Balbus 2009). Besides, other gases mentioned above are responsible for
causing acid rain and smog [4].
4.2.2

Waste

Water pollution and soil pollution from coal fired power plants are mainly associated with wastes
generated from the different operations of the power plant. So, proper waste management can reduce
both water pollution and soil pollution.

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4.2.2.1

June 2011

Coal Combustion Waste (CCW)

a) Large volume CCWs


b) Low volume CCWs
a) Large Volume CCWs:

Fly ash
Bottom ash
Boiler slag
Flue gas desulfurization (FGD) waste
I.
Dry FGD
II.
Wet FGD

b) Low Volume CCWs:

Coal pile runoff


Coal mill rejects/pyrites
Boiler blow down
Cooling tower blow down and sludge
Water treatment sludge
Regeneration waste streams
Air heater and precipitator wash water
Boiler chemical cleaning waste
Floor and yard drains and sumps
Laboratory wastes
Waste water treatment sludge
4.2.2.2

Requirements for waste management

Normally all these wastes are dumped either in landfills or surface impoundments. Some
requirements need to be fulfilled for the proper installation and functioning of these facilities.
Requirements for Landfills:
Liners
Groundwater monitoring
Groundwater-protection standards
Corrective actions
Closure/post-closure
Inspections of the unit
Bonding/financial assurance
Air monitoring
Surface water monitoring
Quality assurance standards for liner and cover construction
Storm-water permits
Requirements for pre-operational and operational plans
Periodic ash testing
Storm-water runoff controls
Construction documentation
Leachate collection systems
Operating plans

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Requirements for Surface Impoundments


Groundwater protection standards
Corrective actions
Closure/post-closure
Inspections of the unit
Bonding/financial assurance
Construction/closure
Quality assurance/quality control
Discharge quality monitoring (Elcock and Ranek 2006)
4.2.2.3

Reduce Re-use and Recycling of CCWs

Technologies are available to reduce, reuse and recycle all these wastes generated. If properly
planned and implemented, large amount of these wastes will reduce and less wastes will need to be
dumped in landfills and surface impoundments. Some of the waste re-use, reduce and recycling
processes followed in different parts of the world are presented below.
Fly Ash:
Fly ash has been successfully used in cement industry for over 50 years. Annual usage of fly ash in
cement and concrete in the USA and in Europe are more than 6106 tons and 9106 tons respectively
(Ian and Lindon 2004). Fly ash is used in the concrete industry for
Cement
Ready mix concrete
Precast
On-site applications like mining and dry construction materials (Lutze and vom Berg 2004).
It increases the overall quality of the construction materials. Use of fly ash in the cement industry also
helps reducing green house gases as substituting Portland cement by fly ash reduces the CO2 by
reducing the production of clinker. Replacing 1 ton of Portland cement reduces the overall CO2
emissions by approximately 1 ton (Cao, Selic and Herbell 2008). Natural resources like Gravel and
Sand are also saved (Cao, Selic and Herbell 2008)
Bottom Ash:
Technologies are available for converting bottom ash into fly ash, so after conversion it can be used
as fly ash also it increases the overall quality of fly ash and has no negative effect on fly ash (Kochert
2009). According to USEPA the following benefits can be achieved tooFiller material for structural applications and embankments
Aggregate in road bases, sub-bases, and pavement
Feed stock in the production of cement
Aggregate in lightweight concrete products
Snow and ice traction control material
FGD:
After desulphurization of Flue gas calcium sulphate or calcium sulphite salts can be produced. These
can be used as:

Embankment and road base material.


After dewatering can be used in wallboard manufacturing
Can replace gypsum for cement production.
Wallboard manufacturing (USEPA 2011)
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Boiler Slag:
Boiler slag can also be used for different purposes:
Component of blasting grit and roofing granules
Mineral filler in asphalt
Fill material for structural applications and embankments
Raw material in concrete products
Snow and ice traction control material (USEPA 2011).

4.3

Brief of environmental impacts

If the large volumes CCWs are dumped in the landfill or surface impoundments without treatment or
without taking recycling actions, there will be huge pressure on the landfills or surface impoundments.
Using proper liners, such as clay liner, geo-synthetic liners or composite liners can reduce the risk of
seepage, but even with high quality materials and high quality workmanship, there is always a chance
of leakage in the liner (Reddy 1996). In developing countries, the quality and monitoring of
workmanship is sometimes questionable leading to the probability of leakage during the installation of
liners. This will expose the groundwater to pollution and eventually will pollute the surface water
including rivers.
The cooling tower blow down water is incredibly hot, up to 20-25 degrees Fahrenheit [4]. This is much
hotter than the surface water that receives it and if not cooled down before discharging into the
surface water can cause thermal pollution and decrease fertility and increase heart rates in fish [4].
Chemicals added to the cooling tower water to decrease algae growth, for example- Chlorine, etc, can
also pollute the water [4].
The power plant needs large amount of water every day for different purposes. This water will be
collected either from ground water storage or surface water i.e. rivers. Using ground water will
drastically lower the ground water level. If surface water is used and not properly screened, it will also
take in a lot of fish eggs, larvae and small fish, which in turn, will be harmful for the fish population [4].

4.4

Recommendations
A well researched and well planned EMP is required.
Good quality workmanship should be ensured while installing the waste management
technologies.
Proper lining of canals, landfills, and surface impoundments should be ensured.
Recycling and re-using of all the recyclable and re-useable wastes should be done to reduce
the pressure on landfills and surface impoundments.
The most effective way to deal with large amounts of sulphur in gas emissions is by using fluegas desulphurization (FGD). The FGD can reduce sulphur dioxide emissions by 90%,
consequently also reducing health risks.
Enact a CO2 performance standard that requires plants commencing construction from now to
achieve strict carbon standards determined by the DoE.
It is recommended that sufficient time, human and financial resources are invested into the
Feasibility Study and EIA. The EIA for a power plant includes a number of studies. The below
table and accompanying text, taken from the analysis work done for a power plant in Africa
(Bohlweki Environmental 2005), illustrates what studies can be expected to be included in an
EIA. The Scoping Study mentioned corresponds most closely to the Feasibility Study step of
the Bangladesh process.

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5.
5.1

June 2011

PHULBARI COAL PROJECT


Overview

An open-pit coal mine in Phulbari in the north west corner of the country, complete with coal rail-river
transport and coastal coal offloading project, has been proposed by the Global Coal Management
(GCM), a UK company, which is operating in Bangladesh through one of its subsidiaries, the Asia
Energy (Bd) Pty.Ltd. It is a challengng project and demands highly sophisticated regulations and
monitoring (Bangladesh Phulbari Coal Project 2006).
Besides the coal pit, there are also activities planned for the Sundarbans Reserved Forest as
described in the SEIA (Bangladesh Phulbari Coal Project 2006) and quoted here: The Coal Terminal
site in Khulna lies within the city boundaries on the Bhairab River, which is approximately 300 m wide
in this region. A fleet of barges will transport coal from the proposed Coal Terminal in Khulna, down
the Bhairab, Rupsa and Pussur rivers to a deep anchorage near Akram Point, a distance of
approximately 58 nautical miles (107 km).The deep water anchorage at Akram Point will be at least
1.3 km from the nearest shoreline which itself is 16 km north of the Sundarbans World Heritage Area.
The shipping channels will pass at least 1.5 km from these protected areas. The floating transfer
vessel (FTV) will be located at a natural deep trough at the southwestern side of Akram Point, 32
nautical miles (59 km) north of the Mongla Fairway Buoy in the Bay of Bengal.
The figure illustrates the waterways from Akram Point (Bangladesh Phulbari Coal Project 2006)

Figure 9: Map of SRF showing the waterway from Akram point to Mongla port and to the Mongla
fairway buoy.

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5.1.1

June 2011

Ownership

Asia Energy (Bd) Pty. Ltd., subsidiary of the Global Coal Management (GCM), a UK company
(Bangladesh Phulbari Coal Project 2006).
5.1.2

Implementation progress

The project is awaiting the final official approval of the Bangladeshi Government (Bangladesh
Phulbari Coal Project 2006).

5.2

Brief of environmental impacts

According to the Summary Environmental Impact Assessment (SEIA) prepared by the Asia Energy for
the ADB in August 2006, the project would relocate 40,000 people (9000 households) and cover an
area of 5,192 hectares (ha). The open pit would cover an area of 2,180 ha.
However, there is some dispute over the actual number of people who will be displaced by the
project. Following the Expert Committee Report, September, 2006 of the Bangladeshi Government it
was discovered that over 129,000 persons would be directly affected and 220,000 persons would be
indirectly affected. This is because the mine would cause severe scarcity of water in the already
water-scarce region by exploiting the underground water.
Coal excavation will take place at a depth of 300 metres below the earths surface. The mine is
expected to run for at least 36 years. Operating at this level, it is likely that the underground aquifer
will get contaminated with pollutants from the coal mine thereby leading to fresh water crisis in the
area (Moody 2008).
The Phulbari coal project has immense potential to harm the environment of the Phulbari area. But for
this report we are only considering the impacts this project may have on the Sundarban region. The
deep water anchorage site within the Sundarbans Reserved Forest and activities to develop this
anchorage site- both during construction and operation phase, may have serious environmental
impacts.
It maybe argued that the Akram site is outside of the three Sundarbans wildlife sanctuaries, however,
the whole of the Reserved Forest is of great value to the national:
millions of local people rely upon the fisheries in the rivers outsides of the sanctuaries (see
earlier chapter).
the Reserved Forest in its entirity is used by habitat for wildlife as illustrated by the high
densities of tigers and dolphins outside of the sanctuaries (see earlier chapter).
the Reserved Forest in its entirity provides valuable ecosystem services to the nation in
including protection against cyclones, prevention of coastal erosion, and storage of carbon
(see earlier chapter).
5.2.1

Risk of an accident

The potential risk from any type of accident in the transportation channel may have serious
environmental impact. An accident may occur at anytime during the transportation of coal from the
Mongla port to the deep anchorage point at Akram point. Probability of an accident occurring between
a barge and transport vessel is low but very much possible. The severity of such occurrence is very
high. Also during major climatic events may occur at any time. The response procedure mentioned in
ESIA by Asia Energy Corporation for such accidents is not sufficient to minimize the environmental
hazards it will bring to the Sundarbans (Moody 2008), on the other hand, response procedure for
major climatic events in the ESIA report is not enough either (Moody 2008).

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5.2.2

June 2011

Spillage during transport and transfer

Spillage of coal in the river may occur at any time during the transportation phase and also during the
transfer of coal between barge and ships. Boats will be refueled at Akram point and oil spill may occur
during the process. Oil/fuel can spill out from the fuel tank after an accident. Such spillage may
change the turbidity of the water, dissolved oxygen, salinity and pH level of the water (Moody, 2008).
5.2.3

Impacts of Dredging and Dumping

The current depth of the Passur river does not allow ships with heavy load capacity. So it will have to
undergo dredging to allow the ships to navigate properly. Dredging in the river bed may cause
disturbance in the aquatic and maritime environment. Oxygen depletion, increase in turbidity, salinity
change may occur (Moody 2008). Dredging may discourage some migratory fishes to come to that
area of the river (Moody 2008).
The dredged soil will be dumped in the Swatch of No Ground at a depth of 90 metres chart datum
(Bangladesh Phulbari Coal Project 2006), which is a submarine canyon, just south of the GangesBrahmaputra river mouth. It has a width of 6-7km and an area of approximately 9000 square
kilometer. But no prior research has been to measure the carrying capacity and over tipping point of
the Swatch, so without any research if this dumping is continued then it might damage the swatch.
The swatch is a major fishing ground (Banglapedia 2006) and initiatives like this have the potential
destroy the fish population.
For elaborate environmental impact of the Phulbari coal project, a research work assessing the
impacts with the following name can be accessed:
Phulbari Coal Project by Jennifer Kalafut and Roger Moody, 2008.
There is another summary EIA prepared by the Asia Energy in 2006 for the Asian Development Bank
(ADB) which is available on the internet.

5.3

Recommendation

It is recommended to the Government to conduct a cost-benefit analysis including the environmental


aspects to assess the feasibility of the project because (a) the project will displace agricultural land of
one of the key rice producing areas of Bangladesh, and (b) the off-shore reloading point located in the
heart of the Sundarbans has potential to cause damage to this valuable forest. The offshore reloading
facility at Akram point should be removed from inside the SRF.

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6.
6.1

June 2011

CHANDPAI SHIPYARD
Overview

The GoB has proposed the construction of a shipyard at Joymonirghol in Chandpai range of the
Sundarbans. The site of the shipyard and Chandpai Silo (described in a later chapter) are located
side by side. The shipyard will be constructed on the bank of Passur river, just opposite side to the
Sundarbans (WTB, personal visit).

Figure 10: Shipyard site with some settlements; Passur river in the middle and the Sundarbans on
the horizon (Photo: Nazneen Ahmed, WTB)

6.1.1

Ownership

The project belongs to the Khulna Shipyard Limited (KSY). Khulna Shipyard Limited (KSY) is an
independent Government commercial enterprise. KSY is under Ministry of Defence, Government of
Bangladesh and is operated by Bangladesh Navy from 1999. Currently it works directly under the
Naval Headquarters. They specialise in building and repair of ships, marine services and
manufacturing of various engineering items [5]. The Joymonirghol shipyard will be used as a front
base for the current shipyard in Mongla port of KSY. KSY is currently capable of manufacturing 2000
ton capacity ships but the current depth of Rupsha River and the current height of Rupsha Bridge are
not suitable for the navigation of such big ships. So, different parts of a ship will be transported to the
Joymonirghol Shipyard for repairing [6].

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Figure 11: Shipyard site comprising shrimp farms (photo: Nazneen Ahmed, WTB)

6.1.2

Implementation progress at the time of writing

Land has been allocated by Bangladesh government to Bangladesh Navy for the construction of the
Shipyard and land acquisition has already been completed (personal visit).

6.2

Brief of environmental impacts

This is a brief overview of some of the environmental impacts of the project.


This is not meant to take the place of a full environmental impact assessment.
The location of the shipyard is at Joymonirghol, 13 km from Mongla. The shipyard is on the bank of
the Passur river, the Sundarbans is located on the other side of the river. So the river is the only
division between the shipyard and the Sundarbans. This location falls inside the ECA and
contravenes the ECA rules (Gazette Notification, MOEF 1999).
A typical shipyard always has some pollution potential, and proper management plan is needed to
minimise or eliminate the pollutants. In the following part of this document, some pollution potentials
for a typical shipyard like the one being built in Joymonirghol will be described. These pollution
potentials have been predicted by analysing EIA reports of shipyards prepared in other parts of the
world. Pollution criteria have been picked carefully so that they relate to the project under discussion
and no confusion is arisen by adding something that is completely out of context and unrealistic for
this project. Some of the EIA reports consulted are:
EIA report prepared by Pacific Environmental PTE Ltd for a Shipyard in Johor Bahru,
Malaysia.
Draft EIA report by L&T-Ramboll Consulting Engineering Ltd for Shipyard cum port complex at
Kattupalli, TamilNadu, India

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Figure 12: Left Silo; right- Shipyard; short columns form temporary boundary in between
(photo: Khairul Alam, WTB)

6.2.1

Water Pollution

Ships will be built and repaired in the shipyard. Liquid waste will be generated while performing
different operations like- dumping of ship waste (sewage/sullage), oil contaminated bilge water, hold
cleaning and tank cleaning residues, spillage upon refuelling or lubricating oil changes, etc. Also the
shipyard will have a lot of employees, so, many other structures will be needed in the nearby area to
support and facilitate all these employees and crews of the ships. Large amount of liquid waste will
generate from these facilities and if proper treatment plans are not taken then these wastes will
pollute the river water as well as the ground water. During the construction of phase if dredging is
done then it will affect the turbidity of the water. The overall water quality in the Sundarbans is
already in a critical state as there is scarcity of fresh drinking water- especially in the dry season.
6.2.1.1

Oil Spill

Oil spill from dredgers, barges and workboats during construction phase and from ships during
operational phase can occur, and this spilled oil has serious pollution potential. Spilled oil will pollute
the river water and can cause serious health hazards to the fish population and the wild life in the
Sundarbans.
6.2.2

Air Pollution

During construction phase exhaust emission from diesel-run engines used for construction purpose
will be a major source of air pollution. Also there will be fugitive dust suspensions. During operational
phase, fumes will be generated from welding, shot blasting, painting works. Also air pollutants may

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generate from vehicle movement inside the yard area. Bad air quality may cause health hazards to
the wild life and can have serious impact on the local flora.
6.2.3

Noise Pollution

Noise pollution may become one of the biggest problems for the shipyard both in construction and
operational phase, as, huge noise will be generated during construction of shipyard, manufacture and
repair works for ships. Also noise will be generated during ship movement through the river. Increase
noise in the area may scare away wild animals from the nearby area.
6.2.4

Solid Waste

Solid waste will be generated from the ships, production and repair works in the shipyard and other
facilities in the yard. A proper solid waste management plan is needed to minimize the pollution from
these solid wastes. If not treated properly these solid wastes can cause- soil pollution, water pollution
and air pollution.
6.2.5

Invasive Species

The increased ship movement in the area may bring some invasive species with them and introduce
them to the ecology of the Sundarbans.
6.2.6

Impact on Ecology

During construction phase of the shipyard development activities like capital dredging, dredge soil
disposal, development of off-shore structures, reclamation and construction of breakwaters may be
required and these activities may harm the ecology of the area. Shoreline changes due to the
construction and operation of the shipyard may also have impact on the ecology.
6.2.7

Impact on the proposed dolphin sanctuary

From Figure 2, which shows the dolphin hotspots in the SRF and Error! Reference source not
found., which shows the location of the shipyard, we can understand that the proposed project will
have a high likelihood of impacting on the dolphin population. Also the FD is planning to declare three
dolphin sanctuaries in the SRF (Figure 3), which falls very close to the proposed shipyards site.

6.3

Recommendation

This site for the shipyard falls inside the Sundarbans ECA and thus it is very close to the forest
boundary. Whilst there is no feasibility report or EIA yet available, given the Sundarbans ECA rules
prohibit such activity within the ECA the immediate recommendation is then to move the project
outside of the ECA.
Even if it is to be placed further upstream and outside of the ECA, this shipyard has potential to harm
the environment and the ecology of the Sundarbans area. So it is highly recommended that a piece of
feasibility work be completed to select a site and design a shipyard which does not put Sundarbans at
risk. It is suggested that sites further along the coast - where there are no longer mangroves and
which are not located upstream from mangroves - be assessed for suitability.

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7.
7.1

June 2011

CHANDPAI SILO
Overview

The Ministry of Food and Disaster Management has allowed the construction of a concrete grain silo
of 50,000 metric ton capacity along with the construction of jetty, a conveyor bridge at Mongla Port
with ancillary facilities. Under this project the following activities will be conducted: (a) collecting
Pneumatic unloader, ship loader and related instruments and (b) hiring consultants for the above
activities. The projects duration is from Jan 2010 to Dec 2013 at a cost of 19, 946 lakh Taka [7].
The location of the silo is at Joimonirghol, 13 km from Mongla port [8].

Figure 13: Opening to the silo, Sundarbans on the horizon (photo: Nazneen Ahmed, WTB)

7.1.1

Ownership

The project belongs to the Ministry of Food and Disaster Management, GoB has received funds from
Japan Debt Cancellation Fund (JDCF) which is a debt relief measure under the Government of Japan
[7].
7.1.2

Implementation progress

A total 42.28 acres of land area has been acquired at Joimonirghol village, Union: Chila, Thana:
Mongla, Forest Range: Chandpai, District: Bagerhat (personal visit). The silo site is separated from
the Sundarbans just by the Passur river while the wetlands of the site fully consist of shrimp farms.
Sand is currently being dumped into the wetlands to fill them up and a fresh water pond is being dug
for the silo workers. The majority residents of the area are shrimp farmers and fishermen (personal
visit).
Both the silo and the shipyard sites are located adjacent to each other.

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7.2

June 2011

Brief of environmental impacts

It is difficult to comprehend the full impacts of the silo without the advantage of an EIA or an IEE
which at the time of writing this document was not made public and was unavailable.
The project may have environmental impacts in two phases: (i) during construction and (ii) after
construction. Some of the common impacts related to pollution are discussed in sub section 5.2
above while below is a brief summary of the scopes that will allow the pollution.
This is not meant to take the place of a full environmental impact assessment.
7.2.1

Context and setting

The project site falls in the ECA and contravenes the ECA rules (Gazette Notification, MoEF, 1999).
Additionally in order to facilitate the silo, additional structures and transportation ways have to be
constructed including a bridge that will run across the Mongla channel, a 24-hour ferry service, wider
highway and culverts [8].

Figure 14: Right: Silo land; left: (not acquired) water body consisting of shrimp farms
(photo: Nazneen Ahmed, WTB)

7.2.2

Access and Transport

Currently the Passur river serves as an anchorage point and allows navigation for fishing trawlers,
medium-sized cargo vessels and hand-driven boats. There is only one 8-feet concrete road that runs
directly from Mongla to Joymonir Ghol in Chandpai. As part of infrastructure development there is a
plan for widening the road to 16 feet (personal visit).
Considering that the proposed silo is meant solely for storing grains, we assume that the silo structure
itself will not pose any environmental threats to the Sundarbans.
However, as the project site is not in an industrial zone and rather surrounded by the Sundarbans on
the east, west and south (see Figure in Section 3), we assume the silos associated activities such as
infrastructure development in the ECA would lead to increased traffic both on land and in water.
These in turn may have implications like oil spills, water, air and noise pollution (for details see sub
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section 5.2) and are likely to have adverse impacts on the tranquil water, sound, air environments of
the surrounding Sundarbans.
7.2.3

Utilities

Currently at Chandpai there is no power and natural gas supply which makes it all the more irrelevant
to set up an industrial structure in a place like the ECA. The project will have to undergo additional
developments for power and in the absence of gas workers and visitors of the silo will have to seek
alternatives to gas for cooking. In that case wood from the Sundarbans, which is just across the river,
may prove to be an easy option thereby increasing the likelihood of more pollution and ecosystem
disturbance (personal visit).

Figure 15: Land filling being done for silo (photo: Nazneen Ahmed, WTB)

7.2.4

Ecology

Chandpai is one of the four FD ranges of the Sundarbans. As mentioned in Section 2 the Sundarbans
supports a wide variety of flora and fauna including the critically endangered Bengal tigers (BTAP
2009). Indeed both the Sundarbans of India and Bangladesh are regarded as top priority conservation
sites for the survival of this endangered species (Barlow 2008).
A tiger abundance survey conducted jointly by the FD and the University of Minnesota in 2007 reveal
that tiger tracks have been recorded in the location for the proposed silo and shipyard, thus proving
that the periphery of the project site also serves as a territory of tigers as shown in the figure 16
(BTAP 2009) below.

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Figure 16: Tiger track distribution in the four Forest Department ranges, 2007

Figure 17: Tiger tracks recorded in the khals crisscrossing the four forest ranges, 2007

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Therefore development activities like the silo, shipyard and the power plant in the ECA would most
likely also negatively affect the crucial tiger habitat.

7.3

Recommendation

This site for the shipyard falls inside the Sundarbans ECA and thus it is very close to the forest
boundary. Whilst there is no feasibility report or EIA yet available, given the Sundarbans ECA rules
prohibit such activity within the ECA, the immediate recommendation is then to move the project
outside of the ECA.
Even if it is to be placed further upstream and outside of the ECA, this shipyard has potential to harm
the environment and the ecology of the Sundarbans area. So it is highly recommended that a piece of
work be completed to select a site and design a shipyard which does not put Sundarbans at risk. It is
suggested that sites further along the coast - where there are no longer mangroves and which are not
located upstream from mangroves - be assessed for suitability.

Figure 18: Fresh water pond dug out for silo workers (photo: Nazneen Ahmed, WTB)

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8. OTHER PROSPECTIVE INDUSTRIES

8.1

Overview

In addition to the projects mentioned above, massive land acquisition along the river Passur has been
done by the private companies Energy Pac and Lithi Group though their purpose for this acquisition is
not clear. Even villagers are not aware of the reason of these buy-outs. Apparently the acquisition is
done through middle-men who in turn are politically affiliated. All pieces of land consist of shrimp
farms (WTB, personal visit).

Figure 19: Land purchased along the Passur river by Energy Pac (photo: Nazneen Ahmed, WTB)

Figure 20: Land purchased along the Passur river by Lithi Group (photo: Nazneen Ahmed, WTB)

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Apparently the local villagers believe that this land would go under water sooner or later so it is better
to sell their land earlier and get settled elsewhere before the disaster strikes. This is the main reason
why they are selling off their land at cheap prices (local villagers, pers.comms).

8.2

Conclusion

With the existence of the Sundarbans, Bangladesh holds 4% of the worlds remaining mangrove
forests (Islam 2008). However, with the construction of the Padma Bridge looming in the near future, it
would seem that the whole coastal zone of Khulna may experience rapid and unplanned
industrialisation which in the long run may end up in Sundarbans disaster.
The fate of Chokoria Sundarbans and Sal forests of Madhupur serve as a clear message to the policy
makers as to what needs to be done to sustain Bangladeshs last remaining forests and retain the
countrys identity as a green country so often described by its poets.
In order to achieve this, a genuine will is required by all parties involved. Subsequently an integrated
environmental strategy with coordination of all ministries needs to be developed for all proposed and
upcoming development projects in the peripheries of the Sundarbans. Furthermore, it needs to be
ensured that all projects undergo the policy and legislative guidelines mentioned in all relevant
legislations.
The conservation of the unparalleled ecosystem of the Sundarbans would mark the beginning of the
countrys first step to sustainable development.

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Website References
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[5] http://www.ksybn.com/
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[7] http://www.mofdm.gov.bd/related_links.html
[8] http://bangladeshbudgetwatch.wordpress.com/2009/08/31/govt-to-build-50000-tonne-food-silonear-mongla-port/
[9] http://www.usaid.gov/bd/programs/environ.html

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