DHAKA METROPOLITAN DEVELOPMENT PLAN STRATEGIC ENVIRONMENTAL ASSESSMENT

Transcription

1 FINAL REPORT DHAKA METROPOLITAN DEVELOPMENT PLAN STRATEGIC ENVIRONMENTAL ASSESSMENT Prepared for: The World Bank Washington, DC Prepared by: SENES Consultants Limited In association with Techno Consult International Limited Dhaka Bangladesh August 2007 Printed on Recycled Paper Containing Post-Consumer Fibre

2 Table of Contents ABBREVIATIONS...I EXECUTIVE SUMMARY...I CHAPTER 1 INTRODUCTION Rational for the Strategic Assessment Study Objectives of the Study Approach and Methodology of SEA Output Report Structure CHAPTER 2 SITUATION ANALYSIS OF DHAKA S ENVIRONMENT Urbanization in Dhaka Land-use and Land Management Water Resources and Quality Air and Noise Quality Flooding and Drainage Formulation of Environmental Priorities CHAPTER 3 URBAN PLANNING IN DHAKA Overall Planning Process in Dhaka Regional Plans Structure Plan & Urban Area Plan Sectoral Planning Institutional Set up for Governance & Urban Planning Analyzing Stakeholder Influence in Planning and Plan Implementation Process Analysis of Planning Framework in Context of Environmental Priorities CHAPTER 4 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK Land and Land use Management Water Resources and Quality Flooding and Drainage CHAPTER 5 SEA FINDINGS AND RECOMMENDATIONS Background Summary of SEA Findings Environmental Priorities that Need to be Addressed by DAP Recommendations BIBLIOGRAPHY.... B-1 GLOSSARY.... G-1 APPENDIX... A Final Aug 2007 i SENES Consultants Limited

3 List of Tables Table 2-1 Environmental Priorities in Dhaka Table 2-2 DAP Zones and Categorisation List of Figures Figure 2-1 Spatial Growth of the Dhaka Figure 2-2 Administrative Map of the DMDP Region Figure 2-3 Spatial Disposition of Development Zones within DMDP Figure 2-4 Air Pollution from Vehicles in Dhaka Figure 2-5 Ranking Matrix for Stakeholder Perception Figure 3-1 DMDP and DAP Planning Areas Figure 3-2 Urban Governance Setup and Flows of Authority Figure 3-3 Interaction between Planning Institutions Figure 3-4 Principal Agencies Related to Urban Planning in DMDP Region Figure 3-5 RAJUK Organizational Structure Figure 3-6 Stakeholder Analysis Matrix Figure 3-7 Proposed Flood Retention Ponds as Demarcated in FAP 8A Figure 3-8 Proposed Flood Retention Ponds as Demarcated in DMDP Structure Plan Figure 3-9 Proposed Flood Retention Ponds as Demarcated in Eastern Bypass Project List of Boxes Box 1-1 Institution-Centered SEA Box 2-1 Slums in Dhaka A Glimpse Box 2-2 Location of Industries in Dhaka Box 2-3 Land Use and Land Management Environmental Concerns Box 2-4 Water Pollution from Industries in Dhaka Watershed Box 2-5 Water Quality Environmental Concerns Box 2-6 Role of Rickshaw Pullers in Urban Transportation Box 2-7 Air and Noise Environmental Concerns Box 2-8 Flooding and Drainage Environmental Concerns Box 3-1 RAJUK SWOT Analysis Final Aug 2007 ii SENES Consultants Limited

4 Abbreviations ADB AQMP BLD BOD BSCIC BUET BWDB BWTA CETP COD DAP DCC DEPZ DIEWRMP DITP DMDP DND DOE DMP DPHE DTCB DUTP DWASA ECA EPZ FAP GDP GoB HSD IDA IGES IPCC IWM JICA JNURM LGED MLGRDC Asian Development Bank Air Quality Management Project Billion Liters per Day Biological Oxygen Demand Bangladesh Small & Cottage Industries Corporation Bangladesh University of Engineering & Technology Bangladesh Water Development Board Bangladesh Water Transport Authority Centralised Effluent Treatment Plant Chemical Oxygen Demand Detailed Area Plan Dhaka City Corporation Dhaka Export Processing Zone Dhaka Integrated Environment and Water Resources Management Project Dhaka Integrated Transport Project Dhaka Metropolitan Development Plan Dhaka Narayanganj Demra Department of Environment Dhaka Metropolitan Police Department of Public Health Engineering Dhaka Transport Coordination Board Dhaka Urban Transport Project Dhaka Water and Sanitation Authority Environment Conservation Act Export Processing Zone Flood Action Plan Gross Domestic Product Government of Bangladesh Housing and Settlement Directorate International Development Association Institute of Global Environmental Strategies Intergovernmental Panel on Climate Change Institute of Water Modelling Japan International Cooperation Agency Jawaharlal Nehru National Urban Renewal Mission Local Government Engineering Department Ministry of Local Government, Rural Development and Co Final Aug 2007 i SENES Consultants Limited

5 MoW MSL MSW NWRC PM 2.5 PM 10 PSRP PWD RAJUK REHAB RHD RMG SEA SMPA SPZ STP TAPP TMC UAP UDD UGI UNDP UNCHS WASA WARPO WTP operatives Ministry of Housing & Works Mean Sea Level Municipal Solid Waste National Water Resource Council Particulate Matter <2.5 Micron Particulate Matter <10 micron Poverty Strategic Reduction Strategy Paper Public Works Department Rajdhani Unnayan Katripakkha Real Estate Housing Association of Bangladesh Road and Highways Department Readymade Garment Industry Strategic Environment Assessment Strategic Metropolitan Planning Authority Special Planning Zones Strategic Transport Plan Technical Assistance for Plan Preparation Technical Management Committee Urban Area Plan Urban Development Directorate Urban Governance Index United Nations Development Programme United Nations Centre for Human Settlement Water and Sanitation Authority Water Resource Planning Organisation Water Treatment Plant Final Aug 2007 ii SENES Consultants Limited

6 1 Rational for SEA Study Dhaka-Strategic Environmental Assessment Executive Summary 1. Dhaka is one of the ten mega-cities in the world. Growing at a very fast rate, the population of Dhaka urban area is predicted to increase to about 21 million by 2015 from the current population of 11.3 million. Dhaka s rapid development, its fast-changing urban landscape and the associated critical environmental challenges call for holistic urban planning, strengthening of institutions responsible for urban development and good governance. 2. The rapid unplanned urbanization has raised two sets of environmental challenges in Dhaka: The first arises from urban development projects in different sectors and industries which treat potential environmental effects as externalities and which only try to mitigate these effects as an afterthought, not as an integral part of the project. The second stems from the acute pressure on natural resources resulting from the indiscriminate use/misuse of these resources. 3. This given, a high-level Strategic Environmental Assessment (SEA) was proposed by the Government of Bangladesh for the Dhaka Metropolitan Development Planning (DMDP) area with the aim to: understanding the complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka; providing future guidance to the urban development process so that it incorporates both urban planning and environmental priorities; providing strategic inputs to projects like the Dhaka Integrated Environment and Water Resources Management Project (DIEWRMP) which is currently being scoped; and proposing a strategy by which environmental priorities could be incorporated in Detailed Area Plans (DAPs) currently being executed. 4. The SEA was drawn up as a participative process involving extensive stakeholder consultations. It provided a platform for dialogue between policy makers, planners, stakeholders and civil society at large on environmental priorities; and on how and why these priorities could be affected by the implementation of plans and policies (World Bank, 2005). The SEA findings will enable the World Bank to conduct a policy dialogue with the Government of Bangladesh on urban development issues in Dhaka Final Aug 2007 i SENES Consultants Limited

7 2 Objectives of the Study 5. The specific objectives of this SEA are to: Dhaka-Strategic Environmental Assessment recommend policies, institutional arrangements and governance conditions needed for ensuring environmental sustainability of Dhaka s urban development; provide overall direction to the DAP formulation and other sectoral projects; and ensure public participation and dialogue on urban development planning through a process of extensive stakeholder consultations. 3 Methodology 6. One of the main objectives of this study is to assess the process of formulating the Detailed Area Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the environmental priorities identified by this study and the stakeholders could be incorporated in these plans. As the SEA was being initiated, it became evident that the whole process of preparing the DAPs was, from the start, handicapped by existing systemic shortcomings. Further, it became evident that the current process of DAP preparation would not be able to deliver the expected outcomes. The shortcomings identified were grouped under two headings: 1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated urban planning framework. Additionally, there is a lack of any stated mechanisms for coordinating with other sectoral agencies and their planning processes; and 2. Problems at the implementation level: these are a poorly informed plan preparation process, inappropriate survey design and inadequate allocation of technical resources by RAJUK (Rajdhani Unnayan Katripakkha). 7. In order to analyse and understand these shortcomings and to identify the environmental priorities in the Dhaka metropolitan area, the following methodology was used. The analytical component of the SEA was constituted of three areas of investigations: 1. An analysis of the key environmental problems in the DMDP area based on secondary information available in various published studies and documents and an analysis of their linkages to policies, legislation and plans. 2. An assessment of the adequacy of existing urban plans and the planning process at the strategic level in order to make recommendations for improved planning and governance. 3. An assessment of the efficacy of the on-going DAP formulation process, review of the design and technical planning capacity in RAJUK; and identification of the areas and needs in RAJUK where interventions for capacity development would be beneficial to overall urban management. 8. The participatory component of the investigation, with inputs from all major stakeholders, helped to prioritise the environmental concerns. It highlighted the areas of institutional failures in urban and environmental planning and drew attention to issues of governance and the role of vested interests Final Aug 2007 ii SENES Consultants Limited

8 4 FINDINGS 4.1 Shortcomings and Gaps at the Strategic Level 9. The Structure and Urban Area Plans do not provide any land use zoning principles which could be applied to design subsequent development. There are contradictions and lack of clear definitions. The Plans demarcate broad areas for future development but inherent contradictions/loopholes have provided scope for manipulation and encroachment. 10. Guidelines have been provided in the Plans, but there are no directives for implementing them; hence, the Guidelines have been ignored by the implementing agencies. The plans have become dated and have limited relevance to resolving the present urban management problems. 11. The sectoral policies in the Structure Plan do not relate them to the urban planning aspects. Most sectoral plans concentrate on finding local and short-term solutions to urban problems, particularly within the DMDP. RAJUK by its constitution, however, has the power to coordinate with the sectoral agencies whose plans affect the urban area. There has been a failure of leadership. Further, the Structure and Area Plans do not contain any discussion on vertical and horizontal transmission of the decision-making process and the decisions themselves. 12. Implementation of urban and regional plans needs considerable co-ordination and collective design and decision-making by all agencies. There are no stated mechanisms for coordination or any over-arching planning framework which would have enabled agencies to collaborate and co-ordinate their plans. The result has been fractured, haphazard and environmentally unsustainable urban spread and inadequate infrastructural development. 13. The strategic level plans did not tackle the problem of multiple administrative authorities within the DMDP and how their developmental efforts could be managed at the regional level. Thus, the overall problems noted above are exacerbated by the fact that DMDP is carved up into smaller administrative units (municipalities and Pourashavas). Of concern is that piecemeal planning and un-coordinated infrastructure development are taking place, often to the detriment of long-term environmental sustainability. 14. The haphazard growth is further reinforced by the national funding mechanism for Annual Development Programmes, which include urban projects. The projects are approved by the relevant ministries or the Planning Commission on budgetary criteria. The outcome is that there is limited urban overview of what is happening on the ground. 15. Urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic approaches to development; multiplicity of agencies; collusive relations between government agencies and vested interest groups; low levels of environmental awareness among sectoral and local authority planners; and very limited effort to achieve real public good. 16. The five teams of DAP consultants appointed by RAJUK need additional guidelines for local area plan formulation; increased information on framework for developing a coherent Final Aug 2007 iii SENES Consultants Limited

9 regional approach; better mechanisms to coordinate the plans of adjoining local / sector authorities; and support and coordination from RAJUK to deal with large sectoral organisations like DWASA or with local authorities. 4.2 Plan Development and Implementation Problems 17. The problems at the implementation level relate to: 18. Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened, was gradually downgraded and to this day the Planning Department remains technically understaffed. There has been no updating or enhancement of qualifications of the current planners. Their notions of urban planning are techno-centric and dated, and complexities of social planning do not sit easily in their thinking. In fact they were ill-equipped to design the DAP preparation process. Consequently, the Terms of Reference are over-ambitious. The technical resources allocated are inadequate and dated. 19. Moreover, the planners have not provided any guidelines to the consultants for demarcation of environmentally-sensitive areas where urban development should be restricted. These include wetlands, flood flow zones, retention ponds, canals and natural drainage channels. There is thus the danger that the DAPs could further exacerbate the problems of urban environmental management. 20. In the absence of any directives, and reflecting the generally low environmental awareness, the DAP consultants appear to have limited understanding of the pollution-intensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. 21. Of greater concern is that the DAP preparation is not guided by any strategic level planning framework. This means that the five groups of consultants are each contained within their own zones, rather than within a regional approach. This means that piecemeal development will be continue even under the new plans. 22. Challenge for DAP consultants: In view of the complexities involved in formulating the DAPs, the SEA team concludes that the local consultants selected for this purpose do not appear to have comprehensive technical capability or the experience to complete the terms of reference. 23. Poor leadership of the Technical Committee: The DAP planning process was found to have a very weak interface with the sectoral planning agencies and, as a result, is unlikely to produce plans that can be integrated with the sectoral strategies and plans. This is because: (a) the Technical Management Committee which is charged to oversee plan preparation has been ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared; and (b) the DAP consultants have also been unable to establish useful contacts with sectoral agencies to address the sectoral issues of the local level plans Final Aug 2007 iv SENES Consultants Limited

10 4.3 Environmental Priorities that Need to be Addressed by DAP 24. The importance of getting the DAP planning process right is underscored by serious environmental problems already affecting Dhaka and its surrounds. The environmental priorities as identified by this study are given below Land and Land use Management 25. Increasing overcrowding in the already developed areas: The growth within the already developed areas has taken place in a random manner, sometimes in contravention of existing development control legislation or by using loopholes in the legislation. As a result, land resources within the city have been put under stress, wetlands within the city have become filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress resulting in significant strain on environmental resources. 26. Unplanned development in fringe areas and encroachment: With decreasing scope for inner city growth, large areas in the environmentally sensitive fringe zone are being targeted as they have been marked for development in the Structure Plan. Such areas have also seen an increase in land prices as a result of speculation and land grabbing, making it difficult to accommodate poor and vulnerable sections of the society in these areas. Indiscriminate landfilling is already leading to loss of natural drainage channels and sink areas that increase the vulnerability to flooding Water Resources and Quality 27. Surface water pollution: The river systems and the water bodies in the Dhaka Watershed are so contaminated by discharge of industrial effluents and untreated sewage that it cannot be treated to potable standards. The role of the DAP lies in initiating a dialogue with industry and a process to identify locations for future industries. 28. Reliance on and depletion of groundwater: As surface water cannot be used to supply drinking water, DWASA has become increasingly reliant on abstracting groundwater. As the supply is unable to meet the growing demand, there has been an increase in number of privately owned tube wells. Local authorities outside DWASA area are also dependent on groundwater. Continued abstraction over a long period could lead to contamination of groundwater. RAJUK and DAP have no say in DWASA s Master Plan. Furthermore, DWASA has made no provisions in its plan to supply the slums areas Inadequate Sanitation and Sewage Network 29. At present the sewage network infrastructure being planned by DWASA only takes into account the existing urbanised areas. There are no systematic plans to set up a network in the developing and fringe areas which are marked for future development. In addition, the five new Sewage Treatment Plants that are being proposed as part of DWASA s Master Plan do not consider additional sewage coming in from developing or fringe areas. As a result, with new Final Aug 2007 v SENES Consultants Limited

11 areas becoming urbanized, there will be continued discharge of untreated sewage resulting in continued pollution of the surface water resources in and around the city. 1 The DAP preparation process could be used as an opportunity whereby a more comprehensive network covering future growth areas could be designed if DWASA, RAJUK and DAP consultants found a common platform Increasing Vulnerability to Floods 30. As far as the role of DAP preparation is concerned, the consultants would concentrate on their respective areas for planning. It is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood retention ponds, which are central to local area plans, would be difficult to undertake, given the compartmentalised planning approach. 5 Recommendations 31. In keeping with the main objective of the study, the recommendations have focused on improving the DAP planning process. These have been subsumed under two groups indicating the urgency of action required. 5.1 Immediate Action Develop DMDP Region Land Use Map and Demarcate and Publish Notification of Ecologically/Environmentally Sensitive Areas 32. Loose planning guidelines and loopholes in the Structure and Urban Plans have allowed the urban encroachment of environmentally sensitive areas which include flood flow zones, wetlands and low-lying areas which act as sink for storm water runoff; natural drainage channels and canals. The local area plans cannot progress unless these areas are clearly identified, demarcated and notified. The proposals and plans on how this demarcation should take place already exist with the responsible agencies and Boards. 33. To overcome this problem, the development of a DMDP Regional Land Use map should be a priority. This map should clearly demarcate eco-sensitive areas and these should be notified through a government gazette as a no-development zone. This action is required as a top priority to ensure no more filling of wetlands, destruction of agricultural lands, and the continued haphazard growth of the DMDP Region Resolve Conflict Arising From Multiple Functions of RAJUK 34. RAJUK has been very active in promoting and participating in the development of commercial properties like shopping centres and malls. While these developments have been lucrative for both RAJUK and the private developers, they have often overlooked the planning guidelines and have encroached on environmentally sensitive areas. Clearly, there is conflict of interests between RAJUK s role as a promoter and its role as the principal agency for urban Final Aug 2007 vi SENES Consultants Limited

12 development. To remove this conflict, to introduce sound urban planning and to enhance transparency in the execution of its development functions, its role as a promoter needs to be reassessed Strengthen the DAP Planning Process as there is Too Much at Risk 35. The planning process is incomplete; hence, there is still an opportunity to improve the process and achieve some of the stated objectives. Real value addition to the process will take place if the capacity for environmentally sustainable and socially sensitive planning is enhanced in RAJUK as it is the lead agency. 36. Consultants with more appropriate competencies need to be appointed. Plan formulation needs a team with better technical know-how, better understanding of the complexities of urban planning, and which has a critical approach to project execution. The point is to build on the work that has already been completed in the last two years. 37. One of the main problems faced by the present consultants is that they are unable to work with/ have access to, the sectoral agencies. The membership of the Technical Committee, who is charged to provide the link, should be re-assessed for effectiveness and, if necessary, changed. The modus operandi should be made more transparent and information on progress and outcomes disseminated. 38. The leadership of RAJUK needs to be more active in the process. The inability of RAJUK to play a leadership role in the past has led other agencies to take planning initiatives on their own without any coordination with RAJUK. Constitutionally, it has considerable power but has rarely used it for systematic urban management. RAJUK needs to re-direct its energy to facilitate the work of its consultants with sectoral agencies and other local authorities. This will not be easy as the latter are fairly antagonistic to RAJUK. It will therefore, be essential to enable and encourage RAJUK to liaise with other agencies and open doors for the DAP process. 39. The issues of slum area development and provision of low income housing are not being addressed either by RAJUK or any of the other sectoral agencies. This means that land allocation and infrastructure planning for these areas might not feature in local area plans. One of the responsibilities of RAJUK is the provision and overview of low income housing. It will be necessary to persuade RAJUK to execute its responsibilities Engaging Stakeholders in Urban Planning 40. Throughout this project it has been observed that political economy has played a huge part in the haphazard development of the City of Dhaka. Further, the people with vested interests have been hijacking the process of planning due to lack of transparency. 41. It is recommended that during the reform of the planning process including resolving the conflict of mandate within RAJUK, a transplant process for engaging key stakeholders in the planning of regional areas should be put in place Final Aug 2007 vii SENES Consultants Limited

13 As pointed out in the workshop, the ward committees at the Pourashavas level have been quite effective at engaging local community in local planning initiatives. Similar initiatives are required at Dhaka and municipal level. Further, transparency can be achieved if the DMDP region landuse plan with demarcation of no development zones is notified and made available to the public. The public can use this information and stop illegal development. Public can approach judiciary if necessary to stop development in the no-development zone Bring Other Actors on Board 42. Crucial to the success of formulating local area plans is the participation of local authorities. An entry point for dialogue with these authorities could be programmes for capacity building in environmental planning and regional development. Thought needs to be given to what would be the most efficacious way of doing this. 43. DWASA is one of the biggest players in the provision of urban infrastructure. There is currently very little communication between the two organisations. It will be important to bring DWASA, RAJUK and the DAP team to a common platform. 44. The flood management strategies expectedly have a regional approach. However, there are measures which need to be put in place and actions taken at the local level to achieve overall reduction in vulnerability to flooding. In order to incorporate such measures in DAPs, it will be necessary for RAJUK, LGED and other principal organisations responsible for management of water resources to work together to assist the DAP team. 5.2 Actions in Short/medium term Develop Strategic Planning Directives for Urban Growth 45. The DAP formulation process will ultimately rely on a strategic planning framework to provide the directives, tools and guidance. While the local area plans will be important working tools, change will occur and new plans will have to be formed. This strategic framework would be a point of reference for local authorities; for DAP consultants; and for future urban growth for the stated period. It is recommended that the new framework be coherent, tight and address the inadequacies of the past and current urban planning approaches and processes Funding Procedures for Local Development Projects 46. Development projects, which include urban project, initiated by local governments and local level sectoral agencies, are funded by their ministries or sometimes the Planning Commission on strictly budgetary criteria. There is no mechanism to appraise its environmental impact or the sustainability of such projects. For long-term environmental sustainability, it will be important to address this problem. However, mainstreaming environmental issues will be a pre-requisite to initiating any systemic change Final Aug 2007 viii SENES Consultants Limited

14 Chapter 1 Introduction 1 This section of the report establishes the basis for the SEA study. It also explains the objectives and scope of the study and relates it to the future support for the Government of Bangladesh to ensure sustainable urban development. The methodology adopted for the study and the rationale behind it has also been highlighted. 1.1 Rational for the Strategic Assessment Study 2 Dhaka is one of the 10 mega-cities in the world. Growing at a very fast rate, Dhaka s urban population is predicted to increase from 11.3 million today to about 21 million by In view of Dhaka s rapid development, changing urban landscape and critical environmental and governance challenges, the need for institutional strengthening and requisite city planning is becoming increasingly important. 3 Rapid urbanization has raised two sets of environmental challenges in Dhaka. The first arises from specific urban development investments which treat potential environmental effects as externalities. The second set of broad range of environmental issues stem from pressure on water and land resources and indiscriminate use/misuse of these resources. The complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka needed to be assessed in order to ensure that Dhaka s development follow a sustainable path. It was felt that a holistic urban planning approach that incorporates environmental and sustainability priorities right from the local level can play a significant role to reverse the degradation of the urban ecosystem of Greater Dhaka. 4 Consequently, a Strategic Environment Assessment (SEA) of the urban development plans that focuses on key institutional planning issues an institution-centred SEA (see Box 1.1) and one that incorporates the political economy dimension in the assessment was seen by the Government of Bangladesh and RAJUK as adding value to the technically-oriented output of the ongoing local level planning in the form of preparation of Detailed Area Plans (DAPs). The understanding was that an institution-centred SEA would provide a platform for dialogue and interaction between policy makers, planners, stakeholders and civil society at large on environmental priorities and on how and why these priorities would be affected by the implementation of plans and policies (World Bank, 2005) and thus formulating strategic actions which can off set these adversities in the plans. The SEA study was launched on November 1, 2006 and is presently nearing completion Final Aug SENES Consultants Limited

15 Box 1-1 Institution-Centered SEA Strategic Environmental Assessment (SEA) describes analytical and participatory approaches that aim to integrate environmental considerations into policies, plans and programmes and evaluate their inter-linkages with economic and social considerations. Source: OECD (2006, p: 30) As compared to project level EIA, SEA of a high level strategic decision making such as policies or development plans requires understanding of institutional settings and associated political economy factors. In the context of weak institutional and governance frameworks, powerful stakeholders and elites often capture policies and plans for their benefit prevailing over other vulnerable stakeholders. An institution-centred SEA is a response for environmental assessment of strategic decision making processes heavily influenced by political and institutional factors. The Bank is currently testing and validating this approach through its pilot program on SEA and Dhaka MDP SEA is a pilot. The following key questions have guided the SEA team in assessing the institutional capacity to manage environmental priorities: Are existing planning processes adequate for the formulation of environmentally sound spatial and urban development plans? and, Why these plans do not get fully implemented or why they undergo changes during implementation? 5 There have been several other factors that lead to recognizing the need for conceptualizing a Strategic Environmental Assessment of the Dhaka Metropolitan Development Plans (DMDP). They are described below: RAJUK 1, the Dhaka capital development authority, had commissioned five Detailed Area Plans (DAPs) for preparation and delineation of local level urban plans. However, it was felt that an umbrella environmental framework was required to assist in the planning process, in integrating the environmental and stakeholder concerns and other regional and sectoral plans in the DAPs The World Bank is developing the Dhaka Integrated Environment and Water Resources Management Project (DIEWRMP) which looks at the opportunity to address urban planning issues incorporating environmental and social dimensions to improve the quality of life of people in Dhaka. However, the program has limited scope to address the overall urban planning issues. The agencies responsible for delivering the urban services feel that the institutional weaknesses and other political economy constraints were a major impediment in the implementation of plans, thus resulting in adverse impacts on the environment. 1 RAJUK was established in It is the development authority for Dhaka covering an area of 1528 sq Km. The present jurisdiction of RAJUK includes three districts (Dhaka, Narayanganj and Gazipur), five municipalities (Pourashavas of Savar, Kadamrasul, Narayanganj, Tongand Gazipur) and the Dhaka City Corporation Area Final Aug SENES Consultants Limited

16 Therefore, RAJUK, a body setup under the aegis of the Ministry of Housing and Urban Planning, evinced their interest in an institution-centred SEA for the DAPs. 1.2 Objectives of the Study 6 The SEA is a decision making tool being used for the first time by the Government of Bangladesh (RAJUK and Ministry of Housing and Urban Planning) to strategize and provide direction to the preparation and implementation of the DAPs. It is also a key policy instrument which will enable the World Bank to conduct a focused policy dialogue, provide recommendations for institutional strengthening and address political economy governance concerns in the context of the implementation of DAPs in the Dhaka Metropolis. 7 The specific objectives of the SEA are to: recommend policies, institutional arrangements and governance conditions needed for ensuring environmental sustainability of Dhaka s urban development; provide overall direction to the DAPs for the formulation of mitigation measures of environmental risks associated with urban development in Dhaka; provide inputs for the project preparation of the DIEWRMP; and ensure public participation and dialogue on urban development planning through a process of wide stakeholder consultations, including weaker and vulnerable stakeholders. 8 The principal audience of this SEA is the Government of Bangladesh and RAJUK which will benefit from strategic planning directions emerging from the study and the working out of an overall environmental management framework which takes into account the environmental opportunities and constraints within which the DAPs may be prepared and implemented. Other Government agencies (Department of Environment, Ministry of Housing and Urban Planning), sectoral agencies (DWASA, BWDB, etc.) and local government bodies (Dhaka City Corporation, Pourashavas) will benefit by developing a better appreciation of the environmental challenges and opportunities associated with the implementation of various level urban plans. The SEA was developed as a strategic decision-aiding instrument for planners, decision makers and stakeholders to enable them to take planning decisions more transparently in order to achieve the common objective of better quality life of city residents and reconcile development planning challenges with environmental protection and sustainability. 1.3 Approach and Methodology of SEA 9 The methodology for the study was adopted through a dynamic and flexible process in order to focus on the key issues related to urban planning and related considerations that has led to the present environmental degradation in Dhaka. Initially, the SEA study was supposed to focus on the DAP planning process, presently underway, and propose an environmental management framework through which sustainability considerations could be built into the plans thereby helping to arrest the environmental degradation of Dhaka Final Aug SENES Consultants Limited

17 10 However, as the study progressed, it became evident that there were a number of gaps in the planning framework and in the DAP process that were causing delays in the formulation of the DAPs. Principal reasons for this slow development of the DAP formulation process are: (i) the lack of higher level planning strategy; and (ii) over-ambitious Terms of Reference, poor process design and inadequate allocation of technical resources by RAJUK. These findings were then investigated. After an extensive review of the higher level planning framework and an analysis of the institutions responsible for planning, it became evident that there were additional constraints, such as inadequate transmission of plans, lack of regional focus, institutions working at cross-purposes and sometimes in conflicting roles, which, if not resolved through interventions at the higher level would prevent the mitigation of risks to the urban environment. 11 An examination of the Terms of Reference provided to the DAP consultants and a review of the details of DAP formulation process showed considerable shortcomings in design and implementation which needed to be addressed for satisfactory completion of local area land use plans. 12 Consequently, it was thought prudent to focus the SEA upstream on the higher level planning framework and develop a better understanding of the interactions and potential conflicts between different agencies and institutions responsible for Dhaka s planning and plan implementation functions. As a result, the study focuses on development of an integrated strategic planning framework in both plans and the institutions responsible for formulating them with the end objective of promoting sustainable urban development in Dhaka. 13 To undertake systematic technical analysis of environmental, planning concerns and political-economic considerations in Dhaka and at the same time incorporate the views of the stakeholders in the development of Dhaka the SEA process comprised of the Analytical Component and Participatory Component. The analytical component looked at measures required to incorporate environmental and planning considerations into the preparation and implementation of the DAP; examined how the DAP formulation process could be improved, and also looked at the need for strategic interventions at the higher planning and institutional levels. The participatory component, adopted through a range of deliberations with stakeholder groups, complemented the consultative process of the DAP organized by RAJUK and the DAP consultants, thereby helping to make the planning process for DAPs more transparent and inclusive Final Aug SENES Consultants Limited

18 1.3.1 Analytical Component 14 The analytical component of the SEA has three areas of investigation. One, aimed to make a thorough analysis of the key environmental problems in the DMDP area based on secondary information available in various published studies and documents and analyze their linkages to policies, legislation and plans. Two, assessed the adequacy of existing urban plans and the planning process at the strategic level in order to make recommendations for improved planning and governance. Three, assessed the efficacy of the on-going DAP formulation process; reviewed the design and technical planning capacity in RAJUK; and identified the areas and needs in RAJUK where interventions for capacity development would be beneficial to overall urban management. 15 Thus, the main outputs of these analyses are: environmental priorities identified; transmission mechanisms 2 of existing planning and institutional arrangements to environmental priorities assessed; the effects of DMDP and other sectoral plans on environmental priorities assessed, given the institutional and planning framework in Dhaka and considering the potential reactions of stakeholders; recommendations for adjustments in the planning and institutional framework for DAP to contribute to sustainable urban development of Dhaka; and recommendations for improving planning capacity in RAJUK and in local authorities. 16 Environmental issues and stakeholders environmental concerns have been assessed by environmental components: landuse and land management; water resources and quality; air and noise quality; and drainage and flooding, and by sectors: water supply, sewage and sanitation, solid waste, drainage and flooding, transport, industry; and spatial planning. In identifying environmental concerns, the perceptions of key stakeholders, particularly the most vulnerable, have been incorporated using the participatory component. 17 Following the identification of environmental priorities, based on stakeholder concerns in Dhaka, these were analyzed on a two-pronged approach. On the one hand, the analytical aspects focused on the ability of the institutional and planning framework to address the environmental concerns as urban development was undertaken taking into account the issues of governance, role of vested interests and complicit relations between government agencies and the private sector. On the other hand, the views of the stakeholders on the severity of the environmental degradation and the need to bring transparency into the planning process were taken into account while developing the priorities. 2 The transmission mechanism from a policy or plan to a priority issue is the manner in which the confluence of institutional, governance and political economy characteristics of a country impact on the interpretation and implementation of the policy or plan and its associated legal instruments and regulations and, thus, will determine to a large extent the effects of the policy or plan on the priority issue. In a situation of weak governance and institutions, changing policy or formulating plans without addressing the underlying transmission mechanism will usually not have any significant effects on the existing outcome with respect to the priority issue Final Aug SENES Consultants Limited

19 18 Issues that have been considered in the assessment comprises of the following: intra- and inter-institutional planning coordinating mechanisms; transparency and stakeholder involvement in the planning and approval process; institutional capacity to identify sustainable development and environmental priorities; ability to adapt planning processes to changing priorities; implementation, monitoring and enforcement capacity; and gaps in high level plans to address environmental priorities such as surface water pollution and under groundwater depletion to guide the formulation of low level plans. 19 The analysis has been subsequently synthesized into institutional and planning strategies with concrete proposals for the short, medium and long-term to be incorporated in the formulation and implementation of spatial planning of DAPs. These analyses will also assist in the preparation of the DIEWRMP and guide RAJUK in the preparation and implementation of the DAPs Participatory Component 20 For the SEA process to be successful, the participation of RAJUK, key urban development agencies, and potentially affected stakeholders was considered to be important. Accordingly, the participation of weak and vulnerable stakeholders in the SEA was ensured in order to take into account their concerns on urban planning and how they relate it to environment protection. A detailed inventory of stakeholders to the SEA process was prepared, the linkages that exist between them were studied and their stake and influence on the planning process understood. The workshops also provided important insight into the shortcomings of the DAP formulation process and indicated serious stakeholder concerns about the overall planning and implementation competencies. This was followed by a series of consultations to understand their concerns about planning and environmental issues pertaining to Dhaka urban area. 21 Significantly, the process provided SEA stakeholders with an open and transparent dialogue platform to discuss spatial and urban development planning issues, understand linkages with environmental degradation that the city has experienced and thereafter set a positive direction to the long-term strategic planning of the city. Details of stakeholder consultations are provided in Appendix Final Aug SENES Consultants Limited

20 Box 1-2 The SEA Consultation Process Dhaka-Strategic Environmental Assessment Appreciating the need for promoting an inclusive and transparent urban planning process for the city of Dhaka, a focused consultation process was planned out and formed an important component the SEA study. The consultation process of the SEA was conducted simultaneously to the consultation carried out by the DAP consultants. While the DAP consultation focused on consultation with the public to understand and incorporate their requirements in the plan preparation process, the SEA consultations focused more on the understanding strategic level issues and considerations like political economy factors that were preventing the preparation or successful implementation of holistic plans, thereby resulting in adverse impacts on the urban environment. The consultations thus focused mainly on higher level i.e institutional/organized stakeholders. However to understand the concerns and viewpoints of the public, especially the vulnerable groups (slum dwellers, rickshaw pullers etc) some group consultations were conducted during the course of the study. Individual Consultations: The individual consultations were conducted with all probable stakeholders to understand their sphere of influence and the knowledge and skill set which they can bring into the SEA Process. Initial Stakeholder Workshop: The initial stakeholder workshop was organized for informing the stakeholders of the objectives of this study and to understand the perception of the citizens about the environmental concerns facing Dhaka. Sensitization Meeting: This meeting was intended to sensitize the members of the Technical Management Committee overseeing the DAP preparation about the SEA. One-on-One Meetings: One on-one Meetings were organized at the initiation of the assessment of environmental concerns to understand the need and aspiration of the stakeholders from the DAP and SEA process. Sectoral Stakeholder Workshop: The sectoral stakeholder workshop was organized to identify some key action areas and policy level initiatives for their implementation for various urban development sectors. DAP Area Meetings: The results of the sector-wise workshop were disseminated through these meetings to be held in each of the areas where a DAP is being formulated. Stakeholder Workshop: This workshop was held after the completion of the Draft Final Report to broadly discuss the possible recommendations of the SEA. It was convened with participation by the sectoral and DAP area wise stakeholders. The workshop's main result was to draw up a consensus on the recommendations to be incorporated in the SEA. Final Consultation Workshop: This final consultation workshop has been planned for mobilizing the support of the decision makers and further disseminating the recommendations of the SEA among stakeholders and taking feedback about the findings and recommendations of the SEA study before finalizing the SEA report. 1.4 Output 22 The deliverable from this activity is twofold. The SEA report informs RAJUK and appropriate government agencies with strategic issues and guidelines for the preparation and implementation of DAPs. Secondly, it provides a tool for decision making to Dhaka s urban development agencies led by RAJUK to discuss and negotiate the institutional and governance requirements for sustainable urban planning. The study will provide specific recommendations for institutional and governance strengthening for environmental sustainability of urban development of Dhaka Metropolitan Area Final Aug SENES Consultants Limited

21 23 The Technical Management Committee (TMC) set up by the Government of Bangladesh (GoB) for supervising and managing the DAP preparation has been engaged in reviewing the results of this study and would be tasked with implementing policies to address SEA recommendations and monitoring of the implementation of these recommendations. The SEA will also inform the preparation of a Policy Note from the World Bank to the GOB on strategic environmental planning in Dhaka. 1.5 Report Structure 24 The remainder of the report is structured as follows: Chapter 2 : Situation Analysis of Dhaka s Environment Chapter 3 : Urban Planning in Dhaka Chapter 4 : Risk and Opportunities of Planning Framework Chapter 5 : Recommendations from the SEA Study Appendix 1 : Public Consultation in SEA Final Aug SENES Consultants Limited